On March 26, 2025, the Government of Canada published new regulations in the Canada Gazette, Part II that create new obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the “Act”) and associated Regulations. These regulatory amendments (i) introduce AML/ATF regulatory requirements for factoring companies, cheque cashing businesses, and financing and leasing companies, (ii) implement measures to enhance the ability of reporting entities to voluntarily share information with each other to detect and deter money laundering, terrorist financing, and sanctions evasion, while maintaining privacy protections for personal information, including an oversight role for the Office of the Privacy Commissioner of Canada, and (iii) strengthen corporate beneficial ownership transparency by implementing a requirement for reporting entities to report material discrepancies between their records and a corporation’s registry filings to the federal beneficial ownership registry in circumstances where they assess there is a high risk of a money laundering or terrorist financing offence. Please see below for further detail. 

Obligations for factors, cheque cashers and financing or leasing entities 

Starting April 1, 2025, factors, cheque cashers and financing or leasing entities must fulfil obligations under the Act and associated Regulations. To assist these sectors in understanding and complying with their obligations under the Act, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) published the following new guidance: 

• Factors 

• Cheque cashers 

• Financing or leasing entities 

Private-to-private information sharing 

Businesses subject to the Act can now voluntarily disclose information between each other to more effectively detect and deter money laundering, terrorist financing and sanctions evasion, while maintaining privacy protections for personal information. To engage, businesses must first develop and submit for review by FINTRAC and approval to the Office of the Privacy Commissioner of Canada a code of practice outlining conditions under which they may disclose personal information. For more information, please see the following: 

• Modernization and upcoming changes impacting reporting entities 

• Submit a code of practice under the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (Office of the Privacy Commissioner website) 

Corporate beneficial ownership 

Starting October 1, 2025, the Regulations will require businesses subject to the Act to report material discrepancies between their records and a company’s registry filings to the federal beneficial ownership registry maintained by Corporations Canada in circumstances where they assess there is a high risk of a money laundering or terrorist financing offence. FINTRAC will communicate more information and guidance on these changes in advance of the coming-into-force date. Please refer to the Regulations below:  

• SOR/2025-68 – Canada Gazette, Part 2, Volume 159, Number 7: Regulations Amending the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations and the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations  

• SOR/2025-67 – Canada Gazette, Part 2, Volume 159, Number 7: Proceeds of Crime (Money Laundering) and Terrorist Financing Reporting of Goods Regulations 

Please note that the Regulatory Impact Analysis Statement (RIAS), which covers both sets of regulations, is included at the end of the second link above. 

If you have any questions, please contact Pragya Anand.