Strengthening the Shield: Developments in the Fight Against Financial Crime

With financial crime continuing to increase in sophistication, the role of CPAs in combatting money laundering and terrorist financing is more critical than ever. Given their training and experience, CPAs are uniquely positioned to detect and deter money laundering activities.

At the time of this writing in late September, the Canadian government is preparing for an evaluation by the Financial Action Task Force. Scheduled to begin in late 2025, this fifth-round mutual evaluation will assess Canada’s technical compliance and—for the first time—the effectiveness of its Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) Regime.

In anticipation, the federal government has released a comprehensive report highlighting key vulnerabilities and threats.¹ It has also introduced significant reforms that expand the powers and mandates of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).²

This article explores these and other developments in the AML landscape and provides some practical steps to help CPAs not only stay onside of the rules but also contribute to the fight against financial crime.

FINTRAC’s expanding oversight and new tools

In early 2025, the Government of Canada directed FINTRAC to mobilize resources to address the urgent threats posed by organized criminal activities such as fentanyl trafficking.³ This directive was issued shortly after the launch of the Integrated Money Laundering Intelligence Partnership, a new intelligence-sharing collaboration between law enforcement and Canada’s major banks.⁴

In addition, FINTRAC has expanded its supervisory framework and enforcement capabilities. Key highlights of this expanded framework include:

• A risk-based approach that prioritizes early intervention, transparency, and forward-looking strategies;⁵
• Three pillars of supervision—engaging, monitoring, and enforcing—each representing “a continuum of tools, activities, and interventions”;⁶ and
• Administrative monetary penalty categories whereby violations are classified as minor, serious, or very serious, with penalties ranging from $1 to $500,000 per violation.⁷

Additionally, FINTRAC has issued new compliance guidance for reporting entities regarding requirements for:

• The use of an agent or mandatary;⁸
• Ministerial directives;⁹ and
• New reporting entities.¹⁰

Federal acceleration of AML reforms

In March 2025, the Department of Finance fast-tracked several AML amendments originally anticipated for October, bringing them into force by April 1, 2025. These changes include the introduction of:

• Mandatory compliance programs for new reporting entities;¹¹
• Information sharing between private institutions to detect money laundering and sanctions evasion;¹² and
• The requirement for entities to flag inconsistencies between their records and federal registries when reporting discrepancies in beneficial ownership information.¹³

These reforms are part of a broader strategy that includes the Canada-U.S. Joint Strike Force and the aforementioned Integrated Money Laundering Intelligence Partnership, both of which are aimed at dismantling organized crime networks and drug trafficking operations.¹⁴

Money laundering risks for CPAs

CPAs may encounter money laundering risks in a variety of professional contexts, particularly when providing services that involve financial transactions, asset management, or corporate structuring. The threat is greatest when working with clients in high-risk industries or jurisdictions, and/or with clients who exhibit unusual financial behaviour—such as making large cash payments, creating complex ownership structures, or being reluctant to provide complete documentation.

In addition, CPAs engaged in tax planning, bookkeeping, or trust services may unwittingly facilitate the movement or concealment of illicit funds if they fail to conduct proper due diligence.

What CPAs need to know and do

Given the increasing complexity of both financial crime and the regulatory landscape designed to combat it, CPAs need to be aware and vigilant—particularly as money laundering is often carefully designed to exploit professional services.

CPAs can better protect themselves, their clients, and the integrity of the financial system by taking the following steps:

• Staying informed about evolving ethical standards and regulations¹⁵ and ensuring adherence to CPABC and FINTRAC rules;
• Adopting a risk-based compliance program that includes:
  • Robust client identification procedures,
  • Enhanced due diligence for high-risk clients and transactions,
  • Careful review of cash-handling policies, and
  • Thorough documentation of all transactions; and
• Completing AML CPD requirements of 1.5 hours.

CPABC offers a range of resources, including free AML courses and access to CPA Canada’s Guide to Comply with Canada’s Anti Money Laundering and Anti Terrorist Financing (AML/ATF) Legislation. Visit our AML website for details. Members are also encouraged to consult CPABC’s member advisory services team for confidential guidance.

Keeping up the good fight

As financial crime evolves, so must the regime designed to defend Canadians against it. With new rules, enhanced oversight, and global momentum, the fight against money laundering continues, and CPAs in British Columbia have a continuing role to play in this effort.

Jessica McKeachie is the director of public interest and corporate secretary at CPABC.

This article was originally published in the November/December 2025 issue of CPABC in Focus.

Footnotes