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sentinel: Canada's AML/CFT regime is anchored in the PCMLTFA, supervised by FINTRAC as both financial intelligence unit and AML/ATF supervisor, applying a FATF-aligned risk-based approach. Budget 2025/Bill C-12 and the Budget 2025 Implementation Act (Royal Assent March 26, 2026) sharply toughen the regime: greatly increased AMP caps, mandatory compliance agreements, compliance orders, universal FINTRAC enrolment, and FINTRAC joining the Financial Institutions Supervisory Committee. Enforcement escalated markedly in 2025, concentrated in the crypto/MSB sector.
Outlook
The original illicit-finance analysis stays in FIM and is routed via cross-monitor flags. Within WPM, the watch item is the downstream compliance-cost impact on the non-bank PSP and stablecoin-issuer perimeter as universal enrolment and the raised AMP caps bite.
AML/CFT & Financial Crime
This module's sole finding this cycle is sourced from the Sentinel.gi feed rather than from original research: FINTRAC's administrative-monetary-penalty ceiling rose materially under Bill C-12, from $1,000 to $40,000 for minor violations and up to $4,000,000 for serious violations (wpm-2026-W32-006). Consistent with this monitor's scope guardrail, the illicit-finance and money-laundering-typology analysis behind this penalty-regime change is not re-analysed here; readers seeking that analysis should consult the Sentinel feed and the dedicated financial-integrity monitor's coverage of Canada's AML architecture directly.
From a payments-supervision perspective, the significance of this development is narrower but still material: every RPAA-registered payment service provider, alongside every other PCMLTFA reporting entity, now faces a substantially heavier AML compliance-cost overlay layered on top of its existing Retail Payment Activities Act supervisory obligations. This is a compounding rather than a replacing change — RPAA-registered PSPs must continue to meet their payments-specific reporting and enforcement obligations under the Bank of Canada's supervision while simultaneously absorbing the higher FINTRAC penalty exposure.
Outlook
Watch for confirmation, via a primary FINTRAC or Canada Gazette source, of the exact AMP figures under Bill C-12, and for any indication of how the compounded AML and payments-supervision compliance burden is affecting RPAA-registered PSPs' operating costs specifically.
Sources and findings (6)
- T2https://www.mondaq.com/canada/money-laundering/1739410/a-line-in-the-sand-fintracs-shift-to-aggressive-aml-enforcementretrieved
- T?FIM (sentinel.gi) per-JID baseline profile — Canada — Canada's AML/CTF/CPF regime rests on the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), enforced by FINTRAC as FIU/supervisor. June 2024 PCMLTFA amendments expanded FINTRAC's information-sharing powers. A federal public beneficial-ownership registry (Bill C-42, CBCA amendment) operates alongside fragmented provincial corporate registries. A 2015 Supreme Court ruling exempts legal counsel and Quebec notaries from AML obligations, a persistent structural gap FATF has repeatedly flagged.
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: absent-field-provenance
- T2FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-002) — Enforcement: FINTRAC — 35 crypto-asset and money-services businesses
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: regulatory-failure
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap