FINTRAC’s New Obligations for Title Insurers: What You Must Know
Why Title Insurers Are Now in FINTRAC’s Spotlight
The real estate sector has long been identified as a channel vulnerable to money laundering and terrorist financing. With the rise in complex property ownership structures and fraud schemes, the federal government has moved to tighten oversight. Effective October 1, 2025, title insurers will be formally recognized as reporting entities under Canada’s anti-money-laundering regime.
This means title insurers must meet the same compliance expectations as banks, real estate brokerages, and mortgage brokers: designing AML programs, verifying clients, keeping detailed records, and reporting suspicious or high-risk activity directly to FINTRAC.
What FINTRAC Requires of Title Insurers
Title insurers will need to establish a compliance program that meets all the core pillars:
Policies and procedures tailored to their business and risk exposure.
Client identification and verification — ensuring that purchasers, vendors, and mortgage details are verified in line with FINTRAC rules.
Recordkeeping obligations covering policy details, transaction values, land registry information, and related documents.
Reporting requirements including suspicious transaction reports (STRs), large cash transaction reports (LCTRs), and terrorist property reports.
Appointment of a compliance officer and regular training for staff.
Another major element is the ability to work with agents to collect client information or perform verifications. This requires a formal agreement and must respect client confidentiality. Lawyers assisting in this process must secure informed written consent from their clients before sharing details with title insurers, as FINTRAC reporting may involve disclosure to law enforcement.
Where Title Insurers Will Struggle Most
For many title insurers, these requirements represent a steep learning curve. Unlike banks, most insurers haven’t had to design AML compliance frameworks before. Common challenges will include:
Building a client identification process that integrates with existing underwriting workflows.
Training staff who may not be familiar with financial crime red flags.
Ensuring recordkeeping systems are detailed enough to withstand a FINTRAC examination.
Establishing agency agreements with lawyers that comply with both AML laws and legal ethics.
How Platino Consulting Works with Title Insurers
This is where Platino Consulting steps in. Our team specializes in helping new reporting entities translate FINTRAC guidance into practical, defensible compliance frameworks. For title insurers, we provide:
Program development: We draft customized AML policies and procedures that integrate with your insurance and claims processes.
Fractional AML Compliance Officer: We act as your companies AML compliance officer, providing on-going support for your AML compliance needs, meeting FINTRAC requirements.
Client verification frameworks: We build tools and workflows for verifying purchasers, vendors, and mortgage details.
Agent agreements: We design legally sound templates and processes for working with lawyers and other agents while respecting solicitor-client confidentiality.
Reporting and recordkeeping systems: We help implement technology or manual processes that meet FINTRAC’s reporting and audit expectations.
Training and ongoing support: We train staff to recognize suspicious activity and support your compliance officer with ongoing advisory services.
With these measures in place, title insurers not only reduce their regulatory risk but also strengthen the integrity of their business against fraud and misuse.
Getting Ready for October 2025
The countdown to October 1, 2025 has already begun. Title insurers who delay compliance preparation may face significant operational pressure and exposure to penalties. Platino Consulting ensures you have a readiness roadmap tailored to your business, so that when FINTRAC comes calling, you can demonstrate full compliance.
