New FINTRAC Guidance: Title Insurers and Private ATM Acquirers Now Reporting Entities

For affected businesses, this update represents a fundamental shift in how operations must be structured, documented, and monitored.

Why FINTRAC Issued This Guidance

FINTRAC has long focused on financial institutions, securities dealers, money services businesses (MSBs), and real estate participants as key points of vulnerability for money laundering and terrorist financing. By adding title insurers and private ABM acquirers to the list of reporting entities, FINTRAC is targeting two areas where regulatory gaps have persisted:

Real estate title insurance is widely used to facilitate property transfers and mortgages. Criminals have exploited real estate transactions to launder large sums of illicit funds, often through complex ownership structures or fraudulent conveyances. Title insurers now become a critical checkpoint in this process.

Privately operated ATMs (sometimes called “white-label ATMs”) have also been flagged as high-risk channels for introducing cash into the financial system. Without the same controls as bank-owned machines, these devices can be exploited for layering illicit funds. By bringing acquirer services under the PCMLTFA, FINTRAC intends to tighten oversight on this vulnerable cash entry point.

Who Is Affected

Title Insurers

These are companies that issue insurance policies to protect buyers and lenders against defects in title when purchasing real property. Although their primary role is not financial intermediation, their involvement in transactions makes them a natural touchpoint for AML monitoring.For real-estate-adjacent teams seeking a baseline on Canadian AML expectations, our overview for real estate professionals provides a useful frame: AML Compliance for Real Estate Agents & Brokers

Private ABM Acquirers

These businesses provide network and processing services for ATMs that are not owned by banks. They often work with independent convenience stores, gas stations, or other retail outlets that operate “white-label” machines. Many operators are small or mid-sized; few have had to maintain a full compliance program until now. If you also support financial-institution clients, see AML Compliance Services for Banks & Neobanks for program components that map closely to ABM acquirer obligations.

Core Obligations Under PCMLTFA

Beginning October 1, 2025, both sectors must meet the same types of obligations already familiar to MSBs and financial institutions. Key requirements include:

1. Establishing a compliance program
   

   • Appointment of a Compliance Officer (such as a CAMLO/MLRO).

   • Written policies and procedures tailored to business activities.

   • A documented risk assessment addressing products, services, delivery channels, geography, and clients.

   • Ongoing training for employees and contractors.

   • A mandatory effectiveness review conducted at least every two years.

    

2. Client identification

   • Verification of identity when entering into certain transactions or relationships.

   • Use of prescribed methods such as government-issued ID, credit file checks, or dual-process methods.

   • Application of enhanced due diligence where higher risks are identified, including politically exposed persons (PEPs).

3. Record-keeping

   • Client identification records.

   • Records of large cash transactions (CAD 10,000 or more).

   • Records of suspicious transactions and attempted suspicious transactions.

   • Retention of records for at least five years.

4. Reporting to FINTRAC

   • Suspicious Transaction Reports (STRs).

   • Large Cash Transaction Reports (LCTRs).

   • Large Virtual Currency Transaction Reports (LVCTRs), if applicable.

   • Terrorist Property Reports (TPRs) where necessary.

Failure to meet these obligations can lead to administrative monetary penalties or, in severe cases, criminal charges.

Practical Challenges for Businesses

Title Insurers

Title insurers will need to integrate AML procedures into workflows historically focused on legal and underwriting risks. This means building new client onboarding and due diligence processes, as well as training underwriters and claims staff on red flags for money laundering.

Private ABM Acquirers

For private ABM acquirers, the challenge is often scale. Many operators are small businesses with limited compliance infrastructure. Reporting, record-keeping, and training requirements may feel burdensome without dedicated compliance expertise. Nonetheless, the risks in this sector are well-documented, and FINTRAC’s decision signals an expectation of professionalization across the industry.

What Businesses Should Do Now

With less than a month until the October 1, 2025 deadline, affected businesses must act quickly. Immediate steps include:

• Review FINTRAC’s published sector-specific guidance for both title insurers and private ABM acquirers.

• Appoint a Compliance Officer responsible for designing and overseeing the AML program.

• Conduct a risk assessment tailored to the specific vulnerabilities of the business.

• Draft policies and procedures that reflect FINTRAC’s requirements.

• Develop training materials and ensure all staff understand their obligations.

• Consider outsourcing compliance functions where internal resources are insufficient. External specialists can accelerate program design and reduce the risk of gaps.

How AML Incubator Can Help

At AML Incubator, we specialize in guiding businesses through the complexities of Canadian AML law. For new reporting entities such as title insurers and ATM acquirers, we provide end-to-end support to meet regulatory expectations.

Our services include:

• MSB Registration and Compliance Program Development: Designing compliant frameworks that withstand regulatory scrutiny.

• CAMLO/MLRO Services: Providing outsourced compliance officers with expertise in financial crime prevention.

• Effectiveness Reviews: Independent assessments to confirm your program is functioning as intended.

• Regulatory Remediation: Helping businesses correct deficiencies identified by regulators or during internal reviews.

Whether you are building your compliance program from scratch or adapting existing processes, our team can ensure you are prepared for the October 1, 2025 deadline and beyond.

Key Takeaways

• As of October 1, 2025, title insurers and private ABM acquirers are subject to the PCMLTFA.

• Obligations include compliance programs, client identification, record-keeping, and FINTRAC reporting.

• Both sectors face significant challenges in adapting to these new requirements, particularly smaller operators.

• Acting early to design a program, train staff, and establish reporting mechanisms is critical.

• External compliance expertise can help businesses meet the deadline confidently.

In a Nutshell

This expansion of the PCMLTFA is part of a broader trend: Canada’s AML regime is tightening across all sectors where money laundering risks exist. For title insurers and private ATM acquirers, the coming months represent a pivotal period of transition. Compliance will no longer be optional; it is now a legal requirement backed by regulatory enforcement.

Businesses that treat this as an opportunity to strengthen their operations, rather than a burden, will be best positioned. By embedding robust AML practices into their workflows, these firms not only avoid penalties but also contribute to the integrity of Canada’s financial system.

If your business is unsure how to comply, AMLI’s team is ready to assist with tailored solutions that turn regulatory obligations into sustainable, effective programs.