The 2024–2025 Expansion: Who Is Newly Covered

The 2024–2025 expansion arrived in three waves. First, on October 11, 2024, the mortgage sector — mortgage administrators, mortgage brokers and mortgage lenders — came under FINTRAC obligations through SOR/2023-194, which added sector-specific provisions at PCMLTFR ss. 64.1–64.6 and hooks the sector into PCMLTFA s. 5(i) via PCMLTFR s. 64.1. One sourcing trap: this date no longer appears on FINTRAC's 'changes' page, which now covers only the Budget 2023/Fall Economic Statement 2023, Budget 2024, Budget 2025 and Borders Act initiatives. The authoritative statement is on FINTRAC's mortgage sector requirements page.

Second, on April 1, 2025, obligations came into force for factors, cheque-cashing businesses, and financing or leasing entities, implementing the Budget 2024 amendments through SOR/2025-68. Third, on October 1, 2025, the remaining regulations took effect, creating obligations for acquirers of private automated banking machines (PABMs) and for title insurers, implementing the Budget 2023 and Fall Economic Statement 2023 amendments through SOR/2024-266 and SOR/2024-267.

Two of the new sectors were not given classes of their own — they were folded into the existing MSB framework, which means registration comes first. For cheque cashing, PCMLTFR s. 29.1 (as amended by SOR/2025-68) makes cheque-cashing services a prescribed service for PCMLTFA s. 5(h)(v) and (h.1)(v), alongside crowdfunding platform services. A person or entity in the business of providing cheque-cashing services is therefore an MSB (or foreign MSB) and must register with FINTRAC.

PABM acquirer services took a different drafting route to the same destination: they are written directly into the Act's MSB definition at PCMLTFA s. 5(h)(iv.1) and (h.1)(iv.1), covering businesses providing acquirer services in relation to a private automated banking machine — a term defined in PCMLTFA s. 2(1). Related record-keeping provisions include PCMLTFR s. 33(k). The operational consequence for both sectors is the same: the full MSB obligation set attaches, not a narrow sector-specific slice.

Because factors arrived on the same date as cheque cashers, they are often assumed to be MSBs. They are not. PCMLTFR s. 24.1 makes a factor 'engaged in a business or profession' for the purposes of PCMLTFA s. 5(i) — a separate reporting-entity class with no MSB registration route. 'Factor' is defined in PCMLTFR s. 1(2) as a person or entity engaged in the business of factoring, with or without recourse against the assignor, and the sector's reporting and record-keeping obligations sit in PCMLTFR ss. 24.11–24.14, with identity verification at s. 93.1.

Financing or leasing entities are likewise their own class, under PCMLTFA s. 5(j). Coverage turns on the three branches in PCMLTFR s. 24.15: financing or leasing (a) property other than real property or immovables, for business purposes; (b) passenger vehicles in Canada; or (c) property, other than real property or immovables, valued at $100,000 or more. Business-purpose equipment finance is caught without a value floor; outside business purposes, coverage runs through the passenger-vehicle and $100,000 branches, and real property is excluded from all three. Obligations sit in PCMLTFR ss. 24.16–24.2 and s. 93.2.

Title insurers were added by SOR/2024-267, s. 11, which inserted PCMLTFR ss. 64.7–64.8 and 102.2, in force October 1, 2025. Mortgage administrators, brokers and lenders have operated under PCMLTFR ss. 64.1–64.6 since October 11, 2024.

Every newly covered business inherits the same core architecture. PCMLTFA s. 9.6(1) requires every s. 5 person or entity to establish and implement a compliance program, and s. 9.6(2) requires that program to include policies and procedures to assess money laundering and terrorist financing risk in the course of the business's activities. PCMLTFR s. 156(1)(c) requires assessing and documenting that risk against the prescribed factors: clients, business relationships and correspondent banking relationships; products, services and delivery channels; the geographic location of activities; affiliate risk (for financial entities under PCMLTFA s. 5(a)–(g)); and any other relevant factor. Note that 'new technologies' is not one of these enumerated factors — a planned new development or new technology instead triggers the separate pre-implementation assessment in PCMLTFR s. 156(2), which must be completed and documented before launch.

Where the business considers a s. 9.6(2) risk to be high, PCMLTFA s. 9.6(3) requires the special measures prescribed in PCMLTFR s. 157: written policies and procedures for enhanced identity verification and other enhanced mitigation, including keeping client identification and beneficial-ownership information up to date and conducting ongoing monitoring of business relationships at a frequency appropriate to the risk level. One deadline sits just past the expansion window: from March 26, 2026, new PCMLTFA s. 9.6(1.1) requires the program to be 'reasonably designed, risk-based and effective' — a standard worth building toward from the start rather than retrofitting.

Coverage also brings regime-wide duties that many newly covered businesses overlook. Three ministerial directives are in force under PCMLTFA s. 11.42: North Korea (December 9, 2017), Iran (July 25, 2020, amended February 15, 2024 and November 15, 2025) and Russia (February 24, 2024). As of November 15, 2025, the Iran directive applies to every person or entity referred to in PCMLTFA s. 5 — which now includes every sector in this article. Each directive requires treating every transaction originating from or bound for the named jurisdiction as high risk regardless of amount, verifying the identity of anyone requesting or benefiting from it, applying due diligence attentive to sanctions evasion, and keeping a record; the Iran directive additionally requires reporting all such transactions to FINTRAC. Sanctions-related reporting under PCMLTFA s. 7.1(1) phased in across the same window — United Nations Act disclosures from March 1, 2025, SEMA and JVCFOA disclosures from October 1, 2025 — and s. 7(c) requires a suspicious transaction report on reasonable grounds to suspect a sanctions evasion offence.

A practical sequence for a newly covered business: first, confirm which s. 5 hook applies using the definitions above, because that answer determines whether FINTRAC registration is required (it is for cheque cashing and PABM acquiring; it is not for factors, financing or leasing entities, title insurers or mortgage participants). Second, build and document the compliance program, anchored on the s. 156(1)(c) risk assessment. Third, for sector-specific report types, forms and timelines, check the current FINTRAC guidance for your sector — FINTRAC publishes dedicated requirement pages for each newly covered class.