Changes to the administrative monetary penalties framework

• FINTRAC's new administrative monetary penalties (AMP) framework, introduced by the Strengthening Canada’s Immigration System and Borders Act (Bill C-12), takes effect for violations occurring after March 26, 2026.
• For violations entirely before this date, FINTRAC will continue to apply its existing AMP policy and processes.
• The new framework grants FINTRAC enhanced enforcement tools, including the authority to impose mandatory compliance agreements and potential compliance orders for prescribed violations.
• FINTRAC is currently updating its AMP policy and guidance in consultation with industry stakeholders to reflect these legislative changes.
• Reporting entities must continue to fulfill all obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its Regulations.

Reporting entities found to have committed prescribed violations after March 26, 2026, will be compelled to enter into compliance agreements and may also face compliance orders.

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) is implementing a significant overhaul of its administrative monetary penalties (AMP) framework, a change ushered in by the `Strengthening Canada’s Immigration System and Borders Act` (Bill C-12). This legislation, which received Royal Assent on March 26, 2026, introduces a new approach to penalties under the `Proceeds of Crime (Money Laundering) and Terrorist Financing Act` (PCMLTFA).

FINTRAC has confirmed that the new legislative requirements will apply to all violations occurring after March 26, 2026. For any infractions that took place entirely before this specific date, the agency will continue to utilize its existing AMP policy, established penalty amounts, and procedural guidelines. This creates a dual-regime system, necessitating careful attention to the timing of any alleged non-compliance.

Since December 30, 2008, FINTRAC has possessed the legislative authority to impose administrative monetary penalties on reporting entities that fail to comply with the PCMLTFA and its associated Regulations. The `Strengthening Canada’s Immigration System and Borders Act` significantly enhances FINTRAC’s enforcement capabilities, with these changes coming into force on March 26, 2026, for future violations.

A key development under the new `FINTRAC new AMP framework March 2026` is the introduction of mandatory compliance agreements and potential compliance orders. Specifically, reporting entities found to have committed prescribed violations after March 26, 2026, will be compelled to enter into compliance agreements and may also face compliance orders. FINTRAC is actively updating its AMP policy and developing new guidance to detail how penalties will be administered under this updated legislative framework, engaging in ongoing consultations with reporting entities and industry stakeholders throughout this process.

Reporting entities must continue to diligently meet all their obligations as stipulated by the PCMLTFA and its Regulations. FINTRAC's supervisory assessments, which review past activities, will determine the applicable penalties regime based on both the examination period and the precise date of any violation. The agency will continue to assess compliance by applying the AMP policy that corresponds to the specific period under review.

Given that supervisory assessments inherently examine historical activity, the relevant policy — either the existing one or the `PCMLTFA administrative monetary penalties changes` — will be determined by whether the review period falls entirely before or after March 26, 2026. FINTRAC has committed to ensuring that each examination is assessed using a single set of compliance expectations for the entire review period, aiming to support clarity and consistent supervisory outcomes for `FINTRAC compliance agreements orders Canada`.

The introduction of the `FINTRAC new AMP framework March 2026` marks a critical juncture for all `Reporting entity obligations FINTRAC new policy`. The shift to mandatory compliance agreements for prescribed violations occurring after the specified date represents a significant escalation in enforcement. Compliance officers must immediately review and update internal policies and procedures to align with these forthcoming changes.

Legal counsel advising clients on potential non-compliance with FINTRAC regulations must ascertain the exact date of any alleged violation to determine which penalty regime applies. The dual nature of the enforcement framework, with distinct rules for violations before and after March 26, 2026, underscores the importance of precise record-keeping and a thorough understanding of the updated regulatory landscape. This proactive approach is essential to mitigate risks associated with the `Bill C-12 FINTRAC penalties`.

Compliance officers must immediately review and update internal policies and procedures to align with FINTRAC's new administrative monetary penalties framework, which applies to violations occurring after March 26, 2026, and introduces mandatory compliance agreements and orders. Lawyers advising clients on potential FINTRAC non-compliance must ascertain the precise date of any alleged violation to determine which penalty regime applies.

Source: Original reporting via FINTRAC's official guidance