Free guides and reference materials for Ontario real estate brokerages.

Every statistic on this page, and everywhere else on complix.ca, traces back to a public source. You don’t have to take our word for any of it.

Downloadable guides

Bill C-12 Fact Sheet

A one-page summary of the March 2026 changes to FINTRAC’s penalty framework, including the before and after penalty comparison, key legislative changes, and what they mean for your brokerage.

Get the Guide

The 5 Mandatory Pillars of a FINTRAC Compliance Program

A one-page reference showing what each of the five compliance pillars covers, and what FINTRAC actually looks for during an examination.

Download the 5 Pillars

Key facts

$2.6M+

in FINTRAC administrative monetary penalties issued to 24 real estate brokerages across Canada between 2021 and November 30, 2025.

$110K

average penalty per brokerage. The single largest penalty in that period was approximately $282,000.

92%

of penalized brokerages were cited for policies and procedures that didn’t sufficiently cover their actual obligations, the single most common finding.

88%

failed to conduct a risk assessment that met FINTRAC’s required standards, the second most common finding.

63%

were cited for recordkeeping. The same share were cited for training, and the same share again for their prescribed effectiveness review.

38%

had not appointed a functioning compliance officer, or had appointed one in name only.

Nearly two-thirds were cited on their effectiveness review.

The review is the pillar designed to catch every other gap before FINTRAC does. When it’s skipped, rushed, or done by the person who wrote the program, the other findings tend to follow.

How our effectiveness review works

Full compliance-area breakdown

Percentage of the 24 penalized brokerages cited for issues in each area. A single brokerage is often cited in more than one category.

Compliance area	% of brokerages with issues
Policies and procedures	92%
Risk assessment	88%
Prescribed effectiveness review	63%
Training	63%
Recordkeeping	63%
Governance (compliance officer)	38%
Reporting (STRs / LCTRs)	29%

Regulatory context

Bill C-12 received Royal Assent on March 26, 2026, raising the maximum penalty for a very serious violation from $500,000 to $20 million per entity, a 40-fold increase. Download the one-page fact sheet.
Compliance programs are now legally required to be “reasonably designed, risk-based and effective,” a new statutory standard FINTRAC can assess independently of whether the technical paperwork requirements are met. Having the documents is no longer enough. The program has to work.
As of October 2025, agents must verify the identity of unrepresented parties and report material beneficial ownership discrepancies.
A prescribed effectiveness review of your compliance program, conducted by an independent internal or external party, is required at least every two years.

Useful links

FINTRAC: fintrac-canafe.gc.ca
FINTRAC Mailing List: subscribe for regulatory updates
Public Safety Canada: listed entities
Consolidated Canadian Autonomous Sanctions List: Global Affairs Canada
CREA Member Portal: FINTRAC templates and FAQs for REALTORS® (member login required)

Sources

Compliance-area statistics and penalty totals: MNP LLP, “FINTRAC penalties highlight real estate compliance gaps” (Part 3 of MNP’s FINTRAC enforcement series), published February 5, 2026. Based on FINTRAC’s public notices of administrative monetary penalties issued between 2021 and November 30, 2025.
Read the full MNP report →

Individual case examples (referenced on our Real Cases page): FINTRAC’s public notices of administrative monetary penalties.
Browse FINTRAC’s public notice database →

Bill C-12 penalty changes: confirmed against multiple independent legal analyses published following Royal Assent on March 26, 2026, including coverage from Blakes, McCarthy Tétrault, and Torys LLP.

We update this page as new enforcement data becomes public. Last reviewed: September 2026.

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