Published 7 September 2026 · By Jatin Dua, Broker of Record, RE/MAX Quantum Realty
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Get My Free Estimate →Because federal law requires it. Real estate brokerages are reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. They must verify client identity, determine and record beneficial owners holding 25% or more of a corporate or trust client, make a third-party determination about who is really directing and funding the transaction, keep prescribed records, and maintain a full compliance programme.
Two reporting obligations sit on top of that: a Large Cash Transaction Report where cash of $10,000 or more is received in a single transaction or in aggregated transactions within 24 hours, and a Suspicious Transaction Report, which has no dollar threshold at all.
What a brokerage must actually do
| Obligation | What it means in practice |
|---|---|
| Client identification | Verify identity for prescribed transactions, using acceptable methods and documents |
| Beneficial ownership | For a corporation, partnership or trust: determine and record individuals owning or controlling 25% or more, and take reasonable measures to confirm |
| Third-party determination | Establish whether someone other than the client is directing or funding the transaction |
| Record keeping | Client identification records, receipt of funds records and related documentation, retained for prescribed periods |
| Compliance programme | Written policies and procedures, a risk assessment, staff training and a periodic effectiveness review |
| Large Cash Transaction Report | Cash of $10,000 or more in one transaction, or aggregated within 24 hours |
| Suspicious Transaction Report | No dollar threshold. Filed on reasonable grounds to suspect money laundering or terrorist financing |
Why this shows up most at the top of the market
Not because high-value buyers are suspect, but because high-value transactions have more moving parts: corporate and trust purchasers, funds arriving from more than one source, non-resident participants, private and alternative lending, and larger deposits. Each of those triggers a step in the process.
The practical effect is that a $5 million purchase involves more documentation than a $900,000 one, and the documentation is required earlier than most buyers expect.
What the regime has added recently
- October 2024: mortgage lenders became reporting entities, bringing non-bank and private lending into the regime.
- 1 October 2025: title insurers became reporting entities, with registration, compliance programme, client identification, record-keeping and reporting obligations.
Both changes matter in the luxury market specifically, because private lending and title insurance are common features of high-value transactions.
Corporate ownership does not create privacy
This is worth stating clearly because it is a persistent misconception. Buying through a corporation or a trust does not conceal who is behind the purchase from the transaction chain. The brokerage must determine beneficial ownership at 25% or more and make a third-party determination. Ontario corporations have also been required to maintain a transparency register since 1 January 2023.
What you will be asked for
- Government-issued identification for individual purchasers
- For a corporation: incorporation documents, and the names and addresses of directors and of individuals owning or controlling 25% or more
- For a trust: the trust deed and details of trustees, settlors and beneficiaries
- Information about the source of the deposit and the balance of funds
- Confirmation of whether anyone other than the named purchaser is directing or funding the transaction
The practical takeaway
None of this is personal and none of it is optional. Treat it as a checklist to complete early rather than an obstacle to argue about, and your closing will be smoother than most. The transactions that go badly are the ones where the documentation is left until the end.
Frequently asked questions
Why does my real estate agent need identification?
Because a brokerage is a reporting entity under federal anti-money-laundering law and must verify the identity of clients for prescribed transactions. It is not discretionary and it is not a comment on the client.
What is beneficial ownership and why 25%?
Where a client is a corporation, partnership or trust, the brokerage must determine and record the individuals who own or control 25% or more, and take reasonable measures to confirm that information. The 25% threshold is set in the regulations.
What is a large cash transaction report?
A report filed with FINTRAC when cash of $10,000 CAD or more is received in a single transaction, or in two or more transactions within 24 hours that total $10,000 or more.
Is there a threshold for suspicious transaction reports?
No. A suspicious transaction report must be filed whenever there are reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing, regardless of the amount involved.
Has the regime changed recently?
Yes, it has widened. Mortgage lenders became reporting entities in October 2024, and title insurers on 1 October 2025. Both changes close gaps in the chain around real estate transactions.
Do lawyers have the same obligations?
Lawyers are regulated separately for anti-money-laundering purposes by their law society rather than directly by FINTRAC, and operate under law society client identification and verification rules, including limits on receiving cash. Your lawyer will explain their own requirements.
Thinking about buying or selling at the top end?
Send me the address, or the shortlist you are considering. I will tell you what the property is actually worth today, what the land is worth without the house, what the transfer tax and carrying costs will be, and whether the deal makes sense. Confidential, always.
connect@jatindua.com · 437-987-1925 · Book a free consultation
Confidential. Read personally and answered within 24 hours. I never share, sell or distribute your information.
Related reading
- Should you buy a luxury home in a corporation or trust in Ontario?
- Can a foreign buyer purchase a luxury home in Toronto in 2026?
- Deposits in Ontario: how much, who holds it, and what happens if you walk
- Buying a Toronto luxury home from out of country: how to do it safely
Sources
Everything above that is a rule, a rate or a published number comes from these. Verify anything that matters to your own deal.
- FINTRAC — Guidance for real estate brokers, sales representatives and developers
- FINTRAC — Reporting suspicious transactions
- McCarthy Tétrault — New FINTRAC requirements for title insurers, effective 1 October 2025
About the author — Jatin Dua, Broker of Record
I’m the Broker of Record at RE/MAX Quantum Realty, 799 The Queensway in Etobicoke, and I work with buyers, sellers and investors across Toronto and the west GTA. A large part of my work sits in the upper end of the market, where the comparables are thin, the rules are heavier and the cost of a wrong number is measured in hundreds of thousands of dollars.
The free estimators on this site are mine. I built them because the first question every owner asks is “what is it worth?” and the honest answer starts with a number you can check yourself. connect@jatindua.com or 437-987-1925.