On February 24, 2024, the Minister of Finance issued a new Ministerial Directive under the Proceeds of Crime (money laundering) and Terrorist Financing Act (“FINTRAC regime”) applicable to the real estate sector. 

The Ministerial Directive requires all reporting entities (including brokers and sales representatives) to treat all transactions originating from, or destined to, Russia as high risk.

Each brokerage has the responsibility to:

• Document in the brokerage’s risk assessment that transactions to and from Russia are high-risk
  
• Update policies and procedures to include information on how the brokerage becomes aware of ministerial directives issued by the Minister of Finance (i.e., FINTRAC RSS feed, join FINTRAC email list, FINTRAC website)
  
• Implement specific measures to mitigate the risk posed by high-risk transactions
  (i.e., take additional steps to identify clients involved in such transactions, keep a record of all actions with the client, and report a suspicious transaction); and
  
• Ensure that all sales representatives understand the measures.

Minor tweaks to the Canadian Real Estate Association's (CREA) FINTRAC Regime resources have been made to remind REALTORS^® of the existence of the new Ministerial Directive.

Note that a separate Ministerial Directive, applicable to North Korea, which has been in force since 2017, continues to apply.

For more information on the Russian Ministerial Directive, please click here.