New AML Compliance Requirements for Canadian Financing & Leasing Companies — What You Must Know Before April 1, 2026

Canada’s financial crime regime continues to expand, and one of the most impactful recent developments for the financing and leasing industry is the inclusion of financing and leasing companies as reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). This shift signals that businesses previously outside the scope of FINTRAC’s supervision must now build and maintain robust anti-money laundering (AML) compliance programs.

While the new regulations came into effect on April 1 2025, impacted companies have until April 1, 2026 to fully implement their compliance frameworks, though earlier action is strongly advised. This blog explains what these new obligations are, why they matter, and how your financing or leasing business can prepare comprehensively before the compliance deadline.

What Changed for Financing and Leasing Companies?

Under the amended PCMLTFA regulations, a “financing or leasing entity” is broadly defined as any person or organization that:

• Provides financing or leasing for property (other than real property/immovables) for business purposes,

• Engages in financing or leasing passenger vehicles in Canada, or

• Finances or leases property valued at $100,000 or more (excluding immovables).

This inclusion captures companies that deal with mid- to high-value property and commercial assets, a segment historically exempt from FINTRAC oversight but now recognised as having money laundering and terrorist financing risk.

Core AML Obligations Financing & Leasing Companies Must Prepare For

Once a business meets the definition above, it must comply with key AML reporting entity obligations already applicable to banks, MSBs and other regulated sectors. These include:

1. Establishing a Compliance Program

You must design and implement a written AML compliance program that is tailored to the risks your business faces. This includes assigning a compliance officer, documenting risk assessments, and putting policies and controls in place.

2. Enhanced Client Due Diligence

This means verifying the identity of each party to a transaction, including beneficial ownership, and monitoring that information over time. Verification isn’t just a one-off task; it must be systematic, documented, and defensible.

3. Transaction Reporting and Record Keeping

Like other reporting entities, you must keep appropriate records of transactions and report certain transactions (including suspicious transactions) to FINTRAC in accordance with the PCMLTFA and Regulations.

These requirements mark a considerable shift in the regulatory landscape for this industry, and the documentation, controls, and governance required to comply are substantial.

Why Early Preparation Is Essential

Although you are not expected to be fully compliant until April 1, 2026, FINTRAC and industry groups have indicated that they will emphasize education, outreach and engagement during the transitional period, and only later move to formal supervisory activities.

However, delay can be risky. Companies that wait until the last minute often find themselves unable to build robust risk assessments, tailor their AML programs to business models, or integrate compliance into existing operational processes. Non-compliance can result in administrative monetary penalties and increased regulatory scrutiny, issues that can affect your business well beyond the initial deadline.

AML compliance is not simply about having documents on a shelf. It’s about building a defensible, risk-based program that aligns with FINTRAC’s expectations and can withstand supervisory assessment.

Platino Consulting can help your financing and leasing business by:

• Conducting a thorough risk assessment tailored to your financing activities and asset classes,

• Designing and documenting an AML compliance program that adheres to FINTRAC’s compliance regime,

• Assisting with customer due diligence frameworks, including beneficial ownership and third-party checks,

• Implementing monitoring and reporting processes, including suspicious transaction workflows, and

• Advising on discrepancy reporting and ongoing governance practices.

Early engagement with AML experts will reduce cost, operational disruption, and regulatory risk as the April 1, 2026 compliance date approaches.

What Next?

If your firm is involved in financing and leasing activities as defined by the PCMLTFA, now is the time to take meaningful steps toward compliance. Waiting until requirements are in force may leave your team scrambling, increase the risk of non-compliance, and weaken your ability to demonstrate a defensible program to regulators.

For tailored advice and practical implementation support, contact Platino Consulting today. We understand both the regulatory requirements and the operational realities of your industry.