Real Cases — Complix

FINTRAC Public Enforcement Notices

Ten questions, and the brokerages that failed them.

Q: Do you have a compliance officer formally designated in writing, with a documented job description covering FINTRAC responsibilities?

FINTRAC requires a written designation naming who is responsible for the brokerage's compliance program. In one enforcement case, 9293-0809 Quebec Inc., operating as Groupe Sam's Globale in Montreal, QC, was fined $101,227 after FINTRAC found the appointed person was not actually responsible for implementing a compliance program, a designation in name only.

Q: Has your compliance officer completed FINTRAC-specific training in the last 24 months, separate from general RECO continuing education?

A compliance officer's own FINTRAC training is not automatically covered by general provincial licensing continuing education. 1135233 B.C. Ltd., operating as LeHomes Realty Premier in Vancouver, BC, was fined $149,886 in a case where the training gap covered the entire brokerage, including its compliance officer.

Q: Are your compliance policies and procedures specific to your brokerage's actual operations, rather than a generic template you downloaded or inherited?

FINTRAC expects written compliance policies that reflect a brokerage's actual clients, transactions, and risk, not a generic downloaded template. Park Georgia Realty Ltd. in Vancouver, BC was fined $33,371 after FINTRAC found its written policies did not sufficiently cover the brokerage's actual regulatory requirements.

Q: Do your written policies reflect the October 2025 amendments and the March 2026 Bill C-12 changes?

No brokerage has yet been publicly fined specifically under the updated Bill C-12 standard, which requires a compliance program to be reasonably designed, risk-based, and effective. Bill C-12 received Royal Assent on March 26, 2026, and the requirement is already active even though enforcement notices typically lag months behind an examination.

Q: Have you completed a documented risk assessment using FINTRAC's required methodology, with a written rationale for each risk score, in the last 12 months?

RE/MAX Twin City Realty Inc. in Kitchener, ON was fined $24,750 for a single violation: failing to assess and document the risk of a money laundering or terrorist financing offence, taking into account FINTRAC's prescribed risk factors.

Q: Does your risk assessment account for your specific client base, transaction types, and geography, rather than treating all clients as equal risk?

In the same case, RE/MAX Twin City Realty Inc. in Kitchener, ON was fined $24,750 because its risk assessment did not weigh the brokerage's actual clients, products, and locations, which FINTRAC's prescribed-factors requirement calls for.

Q: Has every agent at your brokerage completed FINTRAC-specific compliance training in the last 12 months, with attendance documented?

1135233 B.C. Ltd., operating as LeHomes Realty Premier in Vancouver, BC, was fined $149,886 across six violations, one of which was failing to fully document and deliver an ongoing training program for its staff.

Q: Do new agents receive FINTRAC training as part of onboarding, before they handle their first transaction?

In the same LeHomes Realty Premier case in Vancouver, BC ($149,886), the ongoing training program was found not to have been fully documented or delivered, meaning new agents onboarded during that period could not have been properly covered either.

Q: Has your compliance program had an independent effectiveness review in the last two years, as required by FINTRAC?

VIP Realty Inc., operating as Royal LePage Integrity Realty in Ottawa, ON, was fined $33,000 for a single isolated finding: failing to institute and document the required review of its compliance program, which must be carried out at least every two years by an internal or external auditor.

Q: If FINTRAC requested your compliance binder tomorrow, could you produce it, complete and current, within 24 hours?

HomeLife New World Realty Inc., with locations in Toronto and Richmond Hill, ON, was fined $36,135 after FINTRAC reviewed 50 completed transactions and found 14 missing a client's occupation or full address, and 3 of 22 receipt-of-funds records missing an account number, account type, or account holder name.

Every gap in our readiness assessment has already cost a real Canadian brokerage real money in FINTRAC penalties. These aren’t hypotheticals — they’re pulled straight from FINTRAC’s public enforcement notices. Click through and read the actual finding for yourself.

Named cases, all paid & closed

$378K+

Combined FINTRAC penalties shown

2021–2026

Enforcement window

01 / COMPLIANCE OFFICER

Do you have a compliance officer formally designated in writing, with a documented job description covering FINTRAC responsibilities?

9293-0809 Québec Inc. operating as Groupe Sam’s Globale · Montréal, QC $101,227

FINTRAC found the brokerage did not ensure the appointed person was actually responsible for implementing a compliance program — a designation in name only.

Read the FINTRAC notice

02 / COMPLIANCE OFFICER TRAINING

Has your compliance officer completed FINTRAC-specific training in the last 24 months, separate from general RECO continuing education?

1135233 B.C. Ltd. operating as LeHomes Realty Premier · Vancouver, BC $149,886

FINTRAC doesn’t cite compliance officer training as its own violation — it’s folded into the ongoing training program failure below. Same case, same brokerage: the training gap covered everyone, officer included.

Read the FINTRAC notice

03 / POLICIES & PROCEDURES

Are your compliance policies and procedures specific to your brokerage’s actual operations, rather than a generic template you downloaded or inherited?

Park Georgia Realty Ltd. Vancouver, BC $33,371

FINTRAC found the written policies didn’t sufficiently cover the brokerage’s actual regulatory requirements — a common finding when policies are copied rather than built.

Read the FINTRAC notice

04 / RECENT AMENDMENTS

Do your written policies reflect the October 2025 amendments and the March 2026 Bill C-12 changes?

No public case yet Bill C-12 received Royal Assent March 26, 2026

FINTRAC exams typically surface months before a penalty is made public. Bill C-12 raised the legal bar to a “reasonably designed, risk-based and effective” standard — no brokerage has been publicly fined against it yet, but the requirement is already live. Being early here is a real advantage.

Too new for a public case — requirement is already active

05 / RISK ASSESSMENT

Have you completed a documented risk assessment using FINTRAC’s required methodology, with a written rationale for each risk score, in the last 12 months?

RE/MAX Twin City Realty Inc. Kitchener, ON $24,750

One violation, one clean finding: failure to assess and document the risk of a money laundering or terrorist financing offence, taking into account the prescribed factors.

Read the FINTRAC notice

06 / RISK ASSESSMENT DEPTH

Does your risk assessment account for your specific client base, transaction types, and geography, rather than treating all clients as equal risk?

RE/MAX Twin City Realty Inc. Kitchener, ON $24,750

Same case as above — a risk assessment that doesn’t weigh the brokerage’s actual clients, products, and locations doesn’t meet the prescribed-factors requirement.

Read the FINTRAC notice

07 / AGENT TRAINING

Has every agent at your brokerage completed FINTRAC-specific compliance training in the last 12 months, with attendance documented?

1135233 B.C. Ltd. operating as LeHomes Realty Premier · Vancouver, BC $149,886

One of six violations in the same exam: failure to fully document and deliver an ongoing training program for its staff.

Read the FINTRAC notice

08 / NEW AGENT ONBOARDING

Do new agents receive FINTRAC training as part of onboarding, before they handle their first transaction?

1135233 B.C. Ltd. operating as LeHomes Realty Premier · Vancouver, BC $149,886

Same training-program failure — FINTRAC doesn’t split out onboarding timing as its own violation, but an ongoing program that wasn’t fully documented or delivered can’t have covered new agents either.

Read the FINTRAC notice

09 / INDEPENDENT EFFECTIVENESS REVIEW

Has your compliance program had an independent effectiveness review in the last two years, as required by FINTRAC?

VIP Realty Inc. operating as Royal LePage Integrity Realty · Ottawa, ON $33,000

A single, isolated finding: failure to institute and document the prescribed review of its compliance program, to be carried out every two years by an internal or external auditor.

Read the FINTRAC notice

10 / RECORDKEEPING READINESS

If FINTRAC requested your compliance binder tomorrow, could you produce it, complete and current, within 24 hours?

HomeLife New World Realty Inc. Toronto & Richmond Hill, ON $36,135

FINTRAC reviewed 50 completed transactions. In 14 of them, the brokerage hadn’t recorded a client’s occupation or full address. In 3 of 22 receipt-of-funds records checked, the account number, account type, or account holder name was missing.

Read the FINTRAC notice

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These FINTRAC penalties and the violation language describing them are sourced directly from FINTRAC’s public notices of administrative monetary penalties (fintrac-canafe.canada.ca), current as of July 2026. Every case named on this page was paid in full, with the file closed — none are under appeal.