Thousands of Canadian businesses subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act have never had to formally register with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Bill C-12, the Strengthening Canada’s Immigration System and Borders Act, is set to change that.

According to Alessa, the legislation received Royal Assent on 26 March 2026 and introduces a mandatory enrolment regime, complete with periodic renewal and the threat of revocation.

At present, only domestic and foreign money services businesses (MSBs) must register with FINTRAC before operating. All other reporting entities carry PCMLTFA obligations without any formal enrolment. Bill C-12 inserts sections 11.4001 to 11.4015 into the PCMLTFA, requiring every person or entity covered by section 5 of the Act to enrol.

That captures a broad sweep of sectors, from financial entities and securities dealers to casinos, real estate brokers and accountants. Limited exceptions apply, including for individuals acting solely as employees or agents of another reporting entity, while MSBs already registered will not need to enrol again.

Timing remains uncertain. Universal enrolment will take effect in line with regulations yet to be published in the Canada Gazette, Part II, making this a preparation window rather than a filing deadline.

Other elements of Bill C-12 are already live, including a new administrative monetary penalty (AMP) framework and a requirement for compliance programmes that are reasonably designed, risk-based and effective, both effective from 26 March 2026.

The enrolment lifecycle covers a formal application, renewal before expiry, notification of changes within 30 days, and responses to FINTRAC information requests.

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