Canada Accelerates Amendments to Its Anti-Money Laundering and Anti-Terrorist Financing Regime

On March 7, 2025, Canada’s Department of Finance announced finalized regulatory amendments under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) that accelerate the in force date for several key changes to April 1, 2025 — six months sooner than the originally proposed in force date of October 1, 2025.

These include amendments to bring new sectors within scope of Canada’s anti-money laundering and terrorist financing legislation, meaning entities previously not subject to the PCMLTFA must now establish and implement compliance programs on a very compressed timeline that is six months earlier than anticipated. In particular, factoring companies, cheque cashing businesses, and financing and leasing companies now falling within scope of the PCMLTFA will need to develop their policies and procedures, as well as have their risk assessments in place, by April 1, 2025.

While there are some changes to the specific measures in the finalized regulations, the overall substance of the amendments generally tracks the original version that was pre-published in the Canada Gazette on November 30, 2024. These are described in our earlier Blakes Bulletin: But Wait, There’s More: Significant Amendments to Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime.

The amendments and finalized in force dates are summarized below.

• New Regulated Entities: Factoring companies, cheque cashing businesses, and financing and leasing companies will be subject to the PCMLTFA and must implement compliance programs, including conducting a risk assessment of their business, adopting policies and procedures, implementing KYC measures and transaction reporting, and keeping records (in force April 1, 2025).
• Information Sharing: Powers will enable reporting entities to share information with each other to detect and deter money laundering, terrorist financing, and sanctions evasion (in force immediately).
• Powers of Canada Border Services Agency (CBSA): Additional authorities will combat trade-based financial crime by creating new PCMLTFA regulations for reporting of goods (in force April 1, 2025).
• Beneficial Ownership Discrepancies: Reporting entities will be required to report discrepancies between information provided to reporting entities and Corporations Canada’s beneficial ownership registry (in force October 1, 2025).

The regulatory impact analysis statement (RIAS) accompanying the finalized regulations links the accelerated timelines to the Prime Minister’s February 4, 2025, Directive on Transnational Crime and Border Security, which stated the urgent need to disrupt profits laundered by organized crime in connection with illegal trade in drugs such as fentanyl. The amendments provided in the finalized regulations were identified as key measures to support this Directive. The RIAS also linked the amendments to the need for Canada to implement international standards in line with the Financial Action Task Force (FATF) ahead of Canada’s next mutual examination by the FATF scheduled for later this year.

The RIAS states that the Department of Finance, CBSA and the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) will work with regulated entities to ease implementation on this “accelerated and exceptional timeline” and that FINTRAC will focus on engagement and outreach on the new compliance obligations during the first calendar year following their coming into force, including consultation to develop regulatory guidance. The RIAS states that FINTRAC will publish guidance in respect of some newly regulated sectors prior to the coming into force dates of the regulations.

The finalized regulations will be officially published in Canada Gazette, Part II on March 26, 2025.

For more information, please contact the authors or any other member of our Financial Services Regulatory group.