Sanctioned property, MSB checks and ATM reporting

Summary#

This Order, SI/2025-2 - Order Fixing the Days on Which Certain Provisions of Various Acts Come into Force, sets the start dates for parts of three federal laws that change anti‑money‑laundering rules. It brings in a sanctioned‑property reporting rule, stronger criminal‑record checks for money services businesses, and new reporting for companies that handle white‑label ATMs to FINTRAC.

The Order fixes the 60th day after the day this Order is made for one provision, and October 1, 2025 for the other listed provisions.

What it does#

• Brings into force a new sanctioned‑property reporting requirement under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Reporting entities will need to report property covered by sanctions (including sanctions under the United Nations Act, the Special Economic Measures Act, and the Justice for Victims of Foreign Corrupt Officials Act) to FINTRAC.
• Requires domestic money services businesses (MSBs) to provide criminal record checks when they register or re‑register with FINTRAC:
  • Checks must cover senior officers and anyone who directly or indirectly controls 20% or more of the MSB.
  • MSBs must also obtain checks for their agents (and for corporate agents, the equivalent senior people).
  • Information must be submitted at registration and every two years on re‑registration.
  • Records supporting the checks must be issued by a competent authority within the last 6 months and kept for 5 years (details are in the regulations).
  • People with certain criminal convictions (for example, some money‑laundering, terrorist‑financing, tax evasion, trade fraud, or securities fraud offences) are barred from certain roles or investments in MSBs.
• Adds a criminal offence for knowingly violating the MSB criminal‑check rules (added to the PCMLTFA through the Budget Implementation Act, 2024). Penalties can include fines of up to $250,000 (summary) or $500,000 (indictment) and imprisonment up to two years less a day (summary) or up to five years (indictment).
• Makes acquirers for white‑label ATMs reporting entities under the PCMLTFA. That means these acquirers must report and keep records that FINTRAC can use to detect ATM‑linked money laundering.
• The detailed regulatory rules that explain how these changes work were prepublished in the Canada Gazette, Part I on July 6, 2024 and are published alongside this Order.

Who's affected#

• Reporting entities under the PCMLTFA, including banks and other financial institutions that already report to FINTRAC.
• Domestic money services businesses (MSBs) — and their agents, senior managers, and major owners (those with 20% or more).
• Companies that acquire or connect white‑label ATMs to payment networks (acquirers). These firms become new reporting entities.
• Individuals who want to own, invest in, or manage MSBs — especially those with relevant criminal records.
• FINTRAC, which will supervise and enforce the new requirements.

If it is unclear whether a specific business or person is covered, the regulations and FINTRAC guidance provide more detail.

Why it matters#

• It increases checks and paperwork for MSBs and for new reporting firms (white‑label ATM acquirers). That can mean extra time and compliance costs for those businesses.
• It could bar people with certain criminal convictions from owning or running MSBs. That aims to reduce the risk that criminal actors use MSBs to launder money.
• Making white‑label ATM acquirers reportable gives authorities more data to detect and stop cash‑based money‑laundering schemes linked to those machines.
• The sanctioned‑property reporting rule helps Canada spot and respond to sanctions evasion sooner, including to meet international obligations.
• FINTRAC can use these reports to share intelligence with law enforcement and can impose penalties for non‑compliance.