The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) has continued its recent run of enforcement actions ending in hefty financial penalties by fining five real estate brokerages a total of over $350,000.
The firms were found to have been in breach of part one of the Proceeds of Crime and Terrorist Financing Act. While other regulators have scaled back the pace of enforcement activity, FINTRAC has underscored its position as Canada’s anti-money laundering and anti-terrorist financing regulator with a regular cadence of enforcement activity throughout 2025.
Five firms and their compliance failings
November 20, 2025 was a busy day for FINTRAC, with the regulator issuing press releases summarizing the compliance failings of five firms alongside the monetary penalties levied. Each firm was found to have been in non-compliance with Part 1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations.
LeHomes Realty Premier earned a more substantial fine of $149,886 for:
- Failure to submit a suspicious transaction report where there were reasonable grounds to suspect that transactions were related to a money laundering offense.
- Failure to ensure that the appointed person was responsible for implementing a compliance program.
- Failure to develop and apply sufficient compliance policies and procedures for its regulatory obligations relating to record keeping, third party determination, business relationship and ongoing monitoring.
- Failure to take into consideration the money laundering or terrorist activity financing risk of its products and delivery channels, its geographic location, and its clients and business relationships.
- Failure to fully document and deliver an ongoing training program for its staff.
- Failure to keep complete client identification records.
Houston & Associates Realty Ltd was fined $117,975 for failing to:
- Develop and apply written compliance policies that are kept up to date and approved by a senior officer.
- Assess and document the risk of a money laundering offence or a terrorist activity financing offense during its activities.
- Develop and maintain a written, ongoing compliance training program.
- Institute and document the prescribed review of its compliance program for the purpose of testing its effectiveness.
- Keep prescribed records.
HomeLife New World Realty was fined $36,135 for failing to:
- Develop and apply written compliance policies and procedures that are kept up to date and, in the case of an entity, are approved by a senior officer.
- Assess and document the risk of a money laundering or terrorist financing offence, taking into consideration prescribed factors.
- Keep prescribed records.
Pacesetter Marketing Ltd fined $41, 085 for failing to:
- Develop and apply written compliance policies and procedures that are kept up to date and, in the case of an entity, are approved by a senior officer.
- Ensure a person or entity to assess and document risks.
- Ensure a person or entity to institute and document the prescribed review.
Quebec Inc was fined £23,100 for failures to:
- Develop and apply written compliance policies and procedures that are kept up to date; and, in the case of an entity, are approved by a senior officer.
- Assess and document the risk of a money laundering or terrorist financing offense, taking into consideration prescribed factors.
While these cases featured a variety of compliance failures, common threads included failures to establish and consistently update written compliance policies, and assess and document AML risks. The larger fine issued to LeHomes Realty for failing to log a suspicious transaction report is representative of the firm not only failing to establish a fully functional compliance program, but of a material risk of harm resulting from that failure.
Given FINTRAC’s mandate to protect Canadian markets and consumers from criminal activity, the larger penalty comes as little surprise. This mission was underscored in summary comments from Sarah Paquet, FINTRAC Director and Chief Executive Officer, across all five cases:
“Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime is in place to protect the safety of Canadians and the security of Canada’s economy. FINTRAC works with businesses to help them understand and comply with their obligations under the Act. We are also firm in ensuring that businesses continue to do their part and we will take appropriate actions when they are needed.”
Watching out for weak links
FINTRAC isn’t the only Canadian regulator working to ensure rigorous standards of compliance and market integrity. The Office of the Superintendent of Financial Institutions (OSFI) recently published its “Supervisory Framework post-implementation review” to encourage better risk conversations and set clearer expectations around the application of its “weakest link principle” across areas like financial risk, operational resilience, and risk governance.
With FINTRAC and other regulators examining the very foundations of compliance and risk reporting policies, including how they are enforced, who oversees them, and whether they exist at all, firms need to be sure that they’re getting the very basics right – because if not, it could cost them.
Getting the compliance basics right means having a firm understanding of the policies and procedures are needed to meet regulatory requirements, and the essential tools that can support compliance efforts. Business communications surveillance can act as a vital early warning system for non-compliance or signs of anti-money laundering or other misconduct or compliance failures.
