Guides  /  Rules & compliance
Plain-English education for Ontario realtors — guidance, not legal advice. Rules, figures and timeframes change; confirm the current position with RECO and Ontario e-Laws, and your broker of record is the final word.

FINTRAC Obligations for Ontario Realtors

1. Who is covered

FINTRAC obligations apply to real estate brokers, sales representatives, and real estate developers. In practice this means the brokerage carries the reporting-entity obligations, and the individual broker/salesperson must follow the brokerage's compliance program. Obligations arise when acting as an agent in the purchase or sale of real estate (residential or commercial) and, for developers, when selling to the public.

2. Compliance program (mandatory foundation)

Every reporting entity must have a documented compliance program. It is the basis for meeting all other obligations. It must include: 1. A designated compliance officer. 2. Written policies and procedures (kept up to date and approved). 3. A risk assessment of the business's money-laundering / terrorist-financing (ML/TF) risks (clients, products, delivery channels, geography), with enhanced measures for high-risk situations. 4. Ongoing training for employees/agents. 5. A two-year effectiveness review of the program (independent of those being reviewed).

Verify the current program elements at FINTRAC — the required components are defined by regulation.

3. Verifying client identity

Registrants must verify the identity of persons and entities for prescribed transactions and activities. Notably, since October 1, 2025, real estate representatives must also verify the identity of an unrepresented party to a transaction (a buyer or seller taking part in the deal who is not represented by their own real estate professional). Confirm the current triggers at FINTRAC.

Individuals — accepted methods

FINTRAC recognizes several methods (use one, and record the details): - Government-issued photo identification method — examine an authentic, valid, current government-issued photo ID and record the type, number, issuing jurisdiction, and expiry. - Credit file method — a Canadian credit file that has existed for a sufficient period, matched to the person's name, address, and date of birth. - Dual-process method — two reliable, independent sources confirming a combination of name, address, and/or date of birth. - Reliance on an affiliate/member or on another reporting entity's prior verification, where permitted.

Entities (corporations, other entities)

4. Receipt of Funds Record

Whenever the brokerage receives funds in respect of a real estate transaction (in any amount), it must keep a Receipt of Funds Record, generally including: - Date funds were received; - The payer's name/details and, if an individual, address, date of birth, and occupation (or nature of business for an entity); - Amount and currency; - How the funds were received (e.g., cash, cheque, wire, electronic funds transfer) and any account details; - The other parties to the transaction and the purpose/details of the transaction.

The industry commonly uses the OREA Receipt of Funds Record (Form 635) to capture this. (Form number verified against OREA/FINTRAC form references; confirm the current form version with OREA.)

5. Records to keep and retention period

Keep, at minimum: - Identification information records (for individuals and entities); - Receipt of Funds Records; - Large cash transaction records (see below); - Copies of any reports submitted to FINTRAC; - Third-party determination records where applicable; - Beneficial ownership and, where required, politically exposed person (PEP) records.

Retention: at least five (5) years. Generally five years from the date the record was created, or — for client/business relationship records — five years after the last transaction / end of the business relationship. Records must be retrievable and producible to FINTRAC within 30 days of a request. Electronic records are acceptable if a paper copy can readily be produced.

6. Large Cash Transaction Reporting ($10,000+)

If the brokerage receives $10,000 or more in cash in a single transaction (or in amounts that it knows are related and total $10,000+ within 24 hours — the 24-hour rule), it must: - Keep a large cash transaction record, and - File a Large Cash Transaction Report (LCTR) to FINTRAC within the prescribed time (generally 15 days).

An equivalent regime applies to large virtual currency transactions ($10,000+). If someone is authorized to receive cash on the brokerage's behalf, cash they receive is treated as received by the brokerage. Verify the current threshold and filing deadlines at FINTRAC.

7. Suspicious Transaction Reporting (STR)

An STR must be filed when there are reasonable grounds to suspect that a transaction (or attempted transaction) is related to a money-laundering or terrorist-financing offence — regardless of amount. FINTRAC expects an STR to be submitted as soon as practicable after the suspicion is established. STRs have no minimum dollar threshold and the "attempted" transactions are reportable even if the deal does not close. There is also a separate obligation to report terrorist property where applicable. Do not "tip off" the client that an STR has been or may be filed.

8. Third-party determination

For prescribed records/reports, the registrant must take reasonable measures to determine whether a third party is involved — i.e., whether someone other than the person in front of you is instructing or benefiting (e.g., someone providing the funds or directing the transaction). If a third party is identified (or suspected but unconfirmed), record the relevant details (the third party's identity, relationship to the client, and the basis of the determination) per the compliance program's policies.

9. Standard forms / records realtors use

Ontario realtors typically use the OREA standard FINTRAC forms to capture these records. Verified form references: - Form 630 — Individual Identification Information Record (verified). - Form 631 — Corporation/Entity Identification Information Record (verified). - Form 635 — Receipt of Funds Record (verified). - Form 634 — Politically Exposed Person Record (referenced by OREA training; verify the current number/title with OREA).

Note: Numbering can change between OREA form-set editions. Where a specific number cannot be confirmed against current OREA materials, identify the record by its FINTRAC name (Identification Information Record, Receipt of Funds Record, Large Cash Transaction Record, Third-Party Determination Record, Beneficial Ownership Record) rather than a form number, and verify current forms with OREA and current obligations with FINTRAC.

Sources

Sources: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) guidance for real estate — [fintrac-canafe.canada.ca](https://fintrac-canafe.canada.ca/guidance-directives/guidance-directives-eng); the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its Regulations; CREA anti-money-laundering guidance. Reference material only — **not legal or compliance advice.** Thresholds, methods, and record contents change (a significant set of changes took effect **October 1, 2025**). **Verify current requirements at [fintrac-canafe.canada.ca](https://fintrac-canafe.canada.ca/) before relying on any point below.**

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