The Canadian Real Estate Association (CREA) has made important changes to its FINTRAC Regime materials.
The changes reflect changes to the law and guidance since the last update to CREA’s materials in January 2024. As explained in a recent blog post, many of these changes are a consequence of Canada’s broader tariff strategy in response to recent U.S. trade threats.
Key changes include:
Updates throughout CREA’s materials to reflect FINTRAC’s current guidance (e.g. with respect to suspicious transactions).
Updating references throughout CREA’s materials from “terrorist property reporting” to “listed person and entity property reporting”, to reflect new Canadian sanction reporting obligations to FINTRAC.
New sections in CREA’s template office policy with respect to sanctions evasion, listed entity and property reporting, and beneficial ownership discrepancy reporting.
Updates to reflect the fact that, effective October 1, 2025, agents must ID unrepresented parties.
Updated materials to assist members in complying with the new obligations have been posted to CREA’s Member Portal and will be made available on CREA WEBForms® on September 8, 2025. Note that until September 30, 2025, both old and new FINTRAC forms will be available on CREA WEBForms® . However, starting October 1, 2025, only the revised forms will be available.
