Anti-Money Laundering Compliance and Enhanced FINTRAC Penalty Frameworks

Some of RBC’s policies required “reasonable grounds to believe” before reporting a suspicious transaction, although the legal threshold is “reasonable grounds to suspect.” FINTRAC found 16 of 130 case files without a required report and imposed a $7,475,000 penalty. Its notice does not say how many missed reports resulted from the policy wording. 

Dr. Jason Dean uses that examination, other cases and a fictional life insurance advisor to explain client verification, beneficial ownership, politically exposed persons, reporting decisions and compliance programs. He examines how penalties were calculated before Bill C-12 and the higher maximums for violations committed on or after 26 March 2026. Those maximums are ceilings, not typical penalties. Exercises and seven fill-in tools help viewers apply the material. 

Lawyers who work with clients subject to FINTRAC reporting duties need to understand the requirements and penalties those clients face. Although the course is directed at life insurance advisors, securities dealer representatives, banking and money services staff, compliance officers and covered accountants, its cases and exercises show how FINTRAC requirements affect those clients’ decisions and records.