Ontario Real Estate Glossary
FINTRAC (Real Estate)
Canada's federal financial intelligence unit, the Financial Transactions and Reports Analysis Centre. Real estate brokerages and registrants must verify client identity, keep prescribed records, and report large cash transactions and suspicious transactions to FINTRAC under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.
What is FINTRAC in real estate?
FINTRAC is Canada's Financial Transactions and Reports Analysis Centre, the federal financial intelligence unit responsible for detecting, preventing, and deterring money laundering and terrorist financing. Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, every Ontario real estate brokerage and individual registrant must verify client identity, keep prescribed records, and submit reports to FINTRAC for large cash transactions, suspicious transactions, and certain other activities. Compliance is mandatory and audited.
What registrants must do for FINTRAC compliance
Every Ontario brokerage must implement a documented compliance program with five mandatory elements:
- A compliance officer appointed at the brokerage level
- Written policies and procedures covering identification, record-keeping, and reporting
- Risk assessment and mitigation for the brokerage's clients and transactions
- Ongoing training for every registrant and staff member
- A biennial review of the compliance program by an independent or internal reviewer
Individual registrants are responsible for executing client identification, completing the OREA Form 630 (Individual Identification Information Record) for every client, and flagging suspicious activity to the brokerage's compliance officer.
The reports registrants must file
Three FINTRAC reports come up most often in real estate:
| Report | Trigger | Deadline |
|---|---|---|
| Large Cash Transaction Report (LCTR) | $10,000 or more in cash in a single transaction or 24-hour aggregated period | 15 days |
| Suspicious Transaction Report (STR) | Reasonable grounds to suspect a transaction relates to money laundering or terrorist financing | 30 days |
| Receipt of Funds Record | Every receipt of funds in a transaction | Maintained for 5 years |
The $10,000 cash threshold is exam-tested. Cash means physical currency or coin — bank drafts, certified cheques, and electronic transfers do not trigger LCTRs even at high amounts.
Where this appears in your Humber program
FINTRAC compliance is core content in Course 1: Real Estate Essentials under regulatory framework and reappears in Course 5: Getting Started for new-registrant business setup. Continuing-education advertising-compliance and AML modules revisit FINTRAC obligations annually.
Frequently asked questions
Why is my realtor asking for FINTRAC identification?
Your realtor is required by federal law to verify the identity of every client and keep prescribed records. The Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires registrants to obtain government-issued ID, complete an Individual Identification Information Record, and retain it for at least five years. Refusing to provide ID prevents the brokerage from acting on your behalf — it is not optional.
What is the $10,000 rule for FINTRAC?
The $10,000 rule requires real estate brokerages to file a Large Cash Transaction Report (LCTR) with FINTRAC within 15 days when they receive $10,000 or more in cash in a single transaction or in two or more cash amounts aggregating to $10,000+ within 24 hours. Cash means physical currency only — certified cheques, bank drafts, and wire transfers do not trigger an LCTR regardless of amount.
What three reports must be submitted to FINTRAC?
The three core FINTRAC reports for real estate are: (1) Suspicious Transaction Reports (STRs) filed within 30 days when there are reasonable grounds to suspect money laundering or terrorist financing, (2) Large Cash Transaction Reports (LCTRs) filed within 15 days for $10,000+ cash receipts, and (3) Terrorist Property Reports filed without delay when a registrant has property they know or suspect is owned by a designated terrorist entity.
What happens if a brokerage fails to comply with FINTRAC?
FINTRAC can impose administrative monetary penalties ranging from $1 to $500,000 per violation, depending on severity and the size of the brokerage. Repeat or wilful non-compliance can lead to criminal charges. RECO can also discipline registrants for FINTRAC failures because compliance is an obligation under TRESA's Code of Ethics. Penalties from FINTRAC and RECO can be imposed in parallel.
Practice this topic
ExamAce covers FINTRAC obligations, the five-element compliance program, and report-trigger thresholds in the Course 1 question bank.
See it in practice
Walk through a realistic Ontario scenario where FINTRAC (Real Estate) matters — with the decision point, the correct move, and the pitfall.
Authoritative sources
Related terms
RECO
The Real Estate Council of Ontario — the provincial regulator that administers the Trust in Real Estate Services Act, registers brokerages and registrants, runs the discipline process, and operates the mandatory insurance program.
Errors and Omissions Insurance
Mandatory professional liability insurance carried by every Ontario real estate brokerage and registrant under TRESA, covering claims arising from negligent acts, errors, or omissions in the course of practice. Provided through RECO's insurance program.
Agreement of Purchase and Sale
The legally binding contract under which a buyer and seller agree to a real estate transaction in Ontario, capturing price, deposit, conditions, irrevocability, and closing terms. The standard residential APS is OREA Form 100.