Real estate agents and brokersCA

FINTRAC Client Record

The record a real estate brokerage keeps for each client in a purchase or sale: who the client is and how their identity was verified, the funds received, the third-party and politically exposed person checks, the purpose of the business relationship, and the deadlines and keeping periods that follow.

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Deadlines and records

WhatWhenRule
Identity of the client verifiedAt the time of the transaction (November 3, 2026)PCMLTFR s. 101 (1) (a), 105 (7) (a)
Whether the client is a politically exposed person, a head of an international organization, or a family member or close associate of oneWhen the business relationship begins (the first identity verification)PCMLTFR s. 4.1 (c), 120.1 (1)
Purpose and intended nature of the business relationship recorded; ongoing monitoringFrom the first identity verification, then periodicallyPCMLTFR s. 123.1, 145, 146
Receipt of funds record keptUntil at least November 3, 2031PCMLTFR s. 148 (1) (c)
Information record and identity records keptAt least 5 years after the last business transaction with this clientPCMLTFR s. 148 (1) (b)

Dates count from the transaction date entered. Working days skip weekends but not public holidays. Cash amounts from the same person within 24 consecutive hours count as one. A suspicious transaction is reported to FINTRAC as soon as practicable, whatever the amount.

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What goes in it

Every FINTRAC client record from ReportDraft follows the same professional structure, so clients and reviewers find things where they expect them.

  • Directors, owners and controllers (corporations and other entities)Name, Address, Role, Share held
  • Ownership, control and structureHow the entity is owned and controlled, and the measures taken to confirm it.
  • Third partyName, Address, Date of birth, or incorporation number and where issued, Occupation or principal business, Relationship to the client
  • Other people or entities involved in the transactionName, Address, Occupation or principal business, Date of birth (a person)
  • Ongoing monitoringWhat was checked during the business relationship, what was found, and any change to the client's risk.
  • NotesReasons a third party could not be determined, measures that did not work, or anything else for the file.

How it works

1. Enter the details. Names, dates and amounts, once. The next one starts from these entries.

2. Worked out for you. The verification deadline, any report due to FINTRAC and how long to keep each record are worked out from the transaction, and the standard wording is filled in.

3. Check, sign, keep. A completeness list shows anything missing. Sign to lock the PDF and download Word too.

Why it pays for itself

Without ReportDraftWith ReportDraft
Retyping the same names, dates and amounts on every formEnter them once; the standard wording fills itself in
Working out deadlines and keep-until dates by handDates and figures worked out from your entries, every time they change
Looking up the rules and hoping you caught them allEach rule on your checklist, linked to the official text
Paying for a whole software suite for one formA plan for your line of work, from one a month
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What Canadian federal rules require

  • A real estate broker or sales representative has these duties when acting as an agent for a purchaser or vendor in a purchase or sale of real property. Property management alone (leases, rental management) is not covered, and a sales representative's duties rest with their broker, except reporting suspicious transactionsProceeds of Crime (Money Laundering) and Terrorist Financing Regulations s. 53 · FINTRAC: Real estate brokers or sales representatives, and real estate developers
  • The broker keeps a receipt of funds record for every amount received (unless it comes from a financial entity or public body), an information record for every client and every unrepresented party to the purchase or sale, and, for a corporation, a copy of the part of its records about who can bind itPCMLTFR s. 58 (1)
  • The receipt of funds record sets out the date, the payer's name, address, date of birth and occupation (an entity's name, address and principal business), the amount and any part in cash, how it was received, the currency and any exchange rate, every account affected with its type and holders, every other person or entity involved, reference numbers and the purpose of the transactionPCMLTFR s. 1 (2), "receipt of funds record"
  • The identity of each person who conducts the transaction is verified at the time of the transaction: by a valid government-issued photo identification document, information from a government body, a Canadian credit file at least 3 years old, two different reliable sources, or a previous verification by an affiliate or memberPCMLTFR s. 101 (1) · PCMLTFR s. 105 (1) and (7) (a)
  • The identity record sets out the person's name, the date it was verified and how, and for an identification document its type, its number, the jurisdiction and country of issue and its expiry datePCMLTFR s. 108
  • A corporation's identity is verified from its certificate of incorporation or another current record confirming its existence, name, address and directors; another entity's from a partnership agreement, articles of association or a similar record; in both cases within 30 days after the transactionPCMLTFR s. 109 (1) and (4) (i) · PCMLTFR s. 112
  • For a corporation or other entity, the broker obtains the directors' names, the names and addresses of everyone who owns or controls 25% or more, and the ownership, control and structure (for a trust: trustees, beneficiaries and settlors), takes reasonable measures to confirm it, and records bothPCMLTFR s. 138
  • On receiving 10,000 dollars or more in cash or virtual currency, the broker takes reasonable measures to find out whether the payer is acting for a third party, and records the third party's details and relationship, or the grounds for suspicion when it cannot be determinedPCMLTFR s. 134
  • The broker determines whether the client is a politically exposed foreign or domestic person, a head of an international organization, or a family member or close associate of one: when the business relationship begins (in real estate, at the first identity verification), periodically after that, and for anyone paying 100,000 dollars or more in cash or virtual currencyPCMLTFR s. 4.1 (c) · PCMLTFR s. 120.1
  • The broker records the purpose and intended nature of the business relationship, monitors it periodically based on its risk assessment, and keeps a record of the monitoring and what it foundPCMLTFR s. 145 and 146 (1) · PCMLTFR s. 123.1
  • A receipt of 10,000 dollars or more in cash is reported to FINTRAC within 15 days, and in virtual currency within 5 working days, with a large cash or large virtual currency transaction record; amounts from the same person or for the same beneficiary within 24 consecutive hours count as onePCMLTFR s. 54 to 57 · PCMLTFR s. 126 and 132 (2), (3)
  • Records are kept for at least 5 years: information records from the last business transaction with the client, and receipt of funds records from the day they were createdPCMLTFR s. 148 (1)

Every real estate brokerage in Canada keeps the same federal records for the people it acts for in a purchase or sale, whatever the province: who the client is and how their identity was checked, the funds received, whether anyone else is behind the money, whether the client is politically exposed, and why the relationship exists. Here is each rule with a link to the official text.

Two records for every client

For each client, and for any party to the deal who has no agent of their own, the brokerage keeps an information record: name, address, date of birth and occupation for a person, or name, address and principal business for an entity. For every amount it receives, such as a deposit, it keeps a receipt of funds record: the date, who paid, how much and how, the currency, the accounts affected, everyone else involved, reference numbers and the purpose.

When the client is a corporation, the file also holds a copy of the part of its records that says who can bind it.

Checking identity

A person's identity is checked at the time of the transaction. The usual way is a valid government-issued photo identification document, compared with the person in front of you; information from a government body, a Canadian credit file, or two different reliable sources also work. The record notes the date, the method, and for a document its type, number, issuing jurisdiction and country, and expiry date.

A corporation is checked from its certificate of incorporation or another current record that shows its name, address and directors, and another kind of entity from its partnership agreement or articles, within 30 days after the transaction. For both, the brokerage also gathers who owns or controls 25% or more, and how the entity is structured, and records how it confirmed that.

The business relationship

In real estate the business relationship begins the first time a client's identity has to be checked. From then on, the brokerage records the purpose and intended nature of the relationship, checks whether the client is a politically exposed person, a head of an international organization, or a family member or close associate of one, and monitors the relationship periodically based on its own risk assessment.

Cash and virtual currency

A deposit of 10,000 dollars or more in cash, or several smaller ones from the same person within 24 hours, is reported to FINTRAC within 15 days. The same amount in virtual currency is reported within 5 working days. Either way, the brokerage keeps a large transaction record and takes reasonable measures to find out whether the payer is acting for someone else.

A suspicious transaction is reported as soon as practicable, whatever the amount.

Who does it, and for how long

The duties apply when the brokerage acts for a purchaser or vendor in a purchase or sale; leases and rental management alone are not covered. A sales representative's records are the broker's responsibility. Records are kept for at least 5 years: the information record from the last transaction with the client, and the receipt of funds record from the day it was made.

Common mistakes

  • Writing the identification document's type but not its number, issuing jurisdiction and country, and expiry date.
  • Leaving out the client's occupation, or writing "self-employed" without the nature of the business.
  • Skipping the receipt of funds record when the deposit goes to the other side's brokerage: the agent of the party who paid keeps it.
  • Recording a corporation's name but not its directors and its owners of 25% or more.
  • Treating the politically exposed person check as optional for an ordinary home purchase.

Sources

Last reviewed October 24, 2026. Next review due January 24, 2027. This page explains published rules to help you write your report. It is not legal advice; the official text linked above governs. Provincial and territorial rules can add to these.

Template preview

REPORTDRAFT.CA
FINTRAC Client Record Template
Brokerage
Agent (broker or sales representative)
Property
Client is the
Client
Name
Download in Word or PDFIncluded with FINTRAC Records and its free trial.

Questions

What goes in an FINTRAC client record?

The record a real estate brokerage keeps for each client in a purchase or sale: who the client is and how their identity was verified, the funds received, the third-party and politically exposed person checks, the purpose of the business relationship, and the deadlines and keeping periods that follow. ReportDraft lays it out in 6 sections: directors, owners and controllers (corporations and other entities), ownership, control and structure, third party, other people or entities involved in the transaction, ongoing monitoring, notes.

Do my province or territory's rules change the document?

Pick your province or territory when you start. Where we have checked a local requirement against official sources, it is added to your completeness list with a link to the source.

Can I change the wording?

Yes. The standard wording is a starting point: edit any sentence before you sign. The figures and dates are worked out again from your entries every time.

What do I get at the end?

A signed, locked PDF for your client and an editable Word file, both with your company details. Signed reports keep a fingerprint so later changes are visible.

Do I need a FINTRAC record for a lease?

No. The real estate obligations apply when you act for a purchaser or vendor in a purchase or sale. Property management alone, such as leases or rental management, is not covered.

When do I verify my client's identity?

A person's identity at the time of the transaction. A corporation's or another entity's within 30 days after the transaction.

How long do I keep FINTRAC records?

At least 5 years: the information record from the last business transaction with the client, and the receipt of funds record from the day it was created.

What if a client pays the deposit in cash?

Ten thousand dollars or more in cash in one transaction, or in several within 24 hours from the same person, is reported to FINTRAC within 15 days, with a large cash transaction record and a third-party determination.

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