How Canadian Financial Advisors Can Meet FINTRAC Record-Keeping Requirements

FINTRAC — the Financial Transactions and Reports Analysis Centre of Canada — imposes detailed record-keeping obligations on financial advisors, mutual fund dealers, securities dealers, and other reporting entities. These requirements exist to support Canada's anti-money laundering and anti-terrorist financing regime, and FINTRAC has broad authority to examine your records and impose significant penalties for non-compliance.

Who Must Comply with FINTRAC?

FINTRAC's requirements apply to a wide range of financial sector participants including financial advisors and planners, securities dealers, mutual fund dealers, portfolio managers, exempt market dealers, insurance companies and brokers, and real estate brokers handling financial transactions.

Core Record-Keeping Requirements

FINTRAC requires reporting entities to keep records of large cash transactions over $10,000, suspicious transactions (regardless of amount), client identification records (Know Your Client documentation), business relationships and beneficial ownership information, and correspondent banking records. Most records must be retained for a minimum of five years following the date the record was created.

Client Identification and KYC Records

For each client, you must maintain records confirming identity verification, the nature of the business relationship, the purpose of the account or arrangement, and beneficial ownership information for entities. These records must be kept in a form that allows FINTRAC to examine them, which means they must be organized, accessible, and legible.

Electronic Record-Keeping

FINTRAC permits electronic record-keeping but requires that electronic records be maintained in a form that can be readily produced and that preserves the integrity of the original information. This means records cannot be altered after the fact, and the system must provide audit trails showing who accessed or modified records.

FINTRAC Examination Authority

FINTRAC compliance officers can examine your records at any time during normal business hours. They will review your record-keeping policies and procedures, sample client files, and assess whether your systems are adequate. Inadequate record-keeping is one of the most common findings in FINTRAC examinations.

Penalties for Non-Compliance

Administrative monetary penalties for FINTRAC violations can reach into the hundreds of thousands of dollars. Serious violations can be referred to law enforcement for criminal prosecution, with fines up to $2 million and imprisonment up to five years.

SecureVault provides the secure, auditable document storage that Canadian financial advisors need to meet FINTRAC requirements — with immutable audit logs, access controls, and retention management built in.