Tougher AML Rules for Casinos and Real Estate

Summary#

These are final amendments to the rules that support the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. They widen customer checks, record‑keeping and reporting rules for a range of businesses (including casinos, real‑estate professionals and businesses that deal in virtual currency). The regulation was registered on May 20, 2020 and published in the Canada Gazette on June 10, 2020.

What it does#

• Extends tougher customer due‑diligence rules (including checks for politically exposed persons and beneficial owners) to several non‑bank businesses such as real estate brokers, sales representatives and developers, casinos, accountants and accounting firms, dealers in precious metals and precious stones, and certain Crown agents.
• Changes when a business relationship is considered to start in the real‑estate sector so that a single transaction can trigger ongoing monitoring and record‑keeping.
• Raises and clarifies casino ID rules so casinos must verify identity when they receive $3,000 or more in a single transaction.
• Brings virtual currency transfers closer to international practice by requiring originator and beneficiary information on transfers (the so‑called “travel rule”) and new record‑keeping and risk‑based procedures for virtual currency service providers.
• Clarifies and expands what must be reported about cross‑border movements of cash and monetary instruments (for example, amounts in both foreign currency and Canadian dollars, travel dates, and names/addresses of originators, couriers and intermediaries).
• Updates administrative penalty schedules and makes a range of technical and drafting fixes to the existing anti‑money‑laundering regulations.
• Creates ongoing monitoring duties (risk‑based) for many of the newly covered businesses and sets some transaction thresholds (for example, $100,000 cash/virtual currency checks in some contexts, $1,000 for certain funds transfers).

Who's affected#

• Businesses newly or more clearly covered include accountants, British Columbia notaries, casinos, dealers in precious metals and precious stones, real‑estate professionals and developers, and certain money services businesses (including virtual‑currency dealers).
• The national financial intelligence and compliance body, FINTRAC, and law‑enforcement agencies will receive broader and more detailed records and disclosures.
• Travellers who move large amounts of cash or monetary instruments across the border are affected by clarified declaration requirements.
• The regulatory cost estimate applies to about 18,006 reporting entities, most of which are small businesses (about 17,948).

Why it matters#

• The changes are intended to close known gaps (notably in casinos and real estate) and to bring Canada into closer alignment with international standards set by the Financial Action Task Force (FATF). That alignment helps avoid international scrutiny and supports cross‑border cooperation.
• The federal government estimates the regulations will impose about $18,069,097 (present value) in compliance and administrative costs over 10 years. For small businesses the estimated present‑value cost is about $994 per affected firm (annualized about $141).
• In practical terms: affected businesses will need to update policies, records and IT systems, train staff, and collect more identity and ownership information before or when they do certain transactions. This is meant to make it harder for criminals to hide the people behind suspicious transactions.
• Timing: the regulation text says it comes into force on the day it is registered (May 20, 2020). The regulatory statement published with the amendments says some related changes are phased: cross‑border reporting changes on June 1, 2020, and most other changes on June 1, 2021. The Gazette text and the regulatory statement together show the final rule and a phased implementation; if you need to act on these rules, check the official orders or FINTRAC guidance for the exact effective dates that apply to your sector.