What FINTRAC Now Expects
Compliance Program
A documented program with a designated Compliance Officer and defined oversight responsibilities.
Client Identification
Identity verification at onboarding for all clients entering a business relationship.
Ongoing Monitoring
Continuous monitoring of client relationships and transaction activity for suspicious behaviour.
STR Filing
Reporting of Suspicious Transaction Reports (STRs) and Listed Person or Entity Property Reports to FINTRAC.
Record Keeping
Retention of all required compliance documents and records for a minimum of five years.
Staff Training
AML/ATF training for all relevant employees covering red flags, reporting triggers, and escalation procedures.
Why This Matters
The inclusion of title insurers closes a long-standing gap in Canada’s real estate compliance chain. With property ownership increasingly used in complex financial structures, regulators are demanding end-to-end transparency — from realtors and brokers to mortgage lenders and now, title insurers.
This development ensures that title insurance arrangements cannot be exploited to obscure beneficial ownership or facilitate the movement of illicit funds through Canadian real estate.
What Title Insurers Should Do Now
- Conduct an internal gap assessment against FINTRAC’s new obligations
- Appoint a Compliance Officer and formalise your compliance framework
- Establish written procedures for verifying clients and monitoring suspicious activity
- Train staff on reporting triggers and red flags unique to title insurance
- Document everything — FINTRAC’s emphasis is on traceable evidence of compliance controls and oversight
Need Support Aligning with FINTRAC’s New Requirements?
At C&G Professional Services, we help financial and non-financial entities align with FINTRAC’s latest regulatory expectations. If you are a title insurer or part of a real estate compliance network, now is the time to prepare. Contact Claudius Otegbade, Lead Partner.