Anti-money laundering and counter-terrorist financing updates:

Stay informed on high-risk jurisdictions, jurisdictions under increased monitoring, and terrorist and proliferation financing trends and take appropriate measures when providing legal services. Be aware that criminals try to obtain funds, resources and information that can be used to finance terrorism, crimes and/or build weapons of mass destruction.

Grey-listed countries
On June 13, 2025, the FATF updated its list of jurisdictions under increased monitoring. It works with these grey-listed countries to address their strategic deficiencies. Read about the countries under increased monitoring.

Black-listed countries
On June 13, 2025, the FATF released a statement about high-risk jurisdictions. These black-listed jurisdictions are Iran, the Democratic People’s Republic of Korea (North Korea) and Myanmar. These jurisdictions have significant strategic anti-money laundering and counter-terrorist financing deficiencies and have heightened proliferation risks. The Russian Federation’s FATF membership has been suspended since February 24, 2023. Sanctions related to Russia are in effect.

Comprehensive update on terrorist financing risks
On July 8, 2025, the FATF published an important report titled Comprehensive Update on Terrorist Financing Risks. This report highlights serious and evolving terrorist financing risks and warns of gaps in countries’ abilities to fully understand terrorism financing trends and thus respond effectively. It outlines current and evolving methods employed by terrorist organizations and individuals to raise, move, store, and use funds and assets, including cash transportation, hawala and other similar service providers, money value transfer services, online payment services, formal financial services, digital platforms (including social media and crowdfunding sites), virtual assets, and the abuse of legal entities, such as shell companies, trusts and non-profit organizations. Review this report to help you understand and mitigate risks with respect to your practice.

On November 28, 2025 FINTRAC publish a comprehensive guidance document that directly applies to BC Notaries. 

The guidance includes mandatory reporting for every person and entity including BC Notaries.

By way of example:

1) Every person or entity referred to in section 5 of the Act must:

• treat every financial transaction originating from or bound for a black listed country, regardless of its amount, as a high-risk transaction;
• verify the identity of any person or entity requesting or benefiting from such a transaction, regardless of its amount, in accordance with Part 3 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (the Regulations);
• exercise customer due diligence in relation to such a transaction, with particular attention to the risk of sanctions evasion offence, including by ascertaining the source of funds or virtual currency, the purpose of the transaction and the beneficial ownership or control of any entity or requesting or benefiting from the transaction;
• keep and retain a record of such a transaction, regardless of its amount, in accordance with the regulations;
• and, before undertaking any financial transaction originating from or bound for any foreign state or foreign entity, or an entity referred to in paragraph 5(e.1) of the Act, ensure that the compliance program referred to in section 9.6 of the Act includes the development and application of policies and procedures for the person or entity to assess, in the course of the person’s or entity’s activities, with the risk of a sanctions evasion offence associated with a black listed country.

2) Before undertaking any transaction with a foreign financial institution under a correspondent banking relationship, entities referred to in subsection 9.4(1) of the Act must:

• ensure that the risk of a sanctions evasion offence associated with a black listed country is taken into consideration when taking the measures referred to in paragraphs 16(2)(h) to (j) and subsection 16(3) of the Regulations and when conducting ongoing monitoring under subsection 16(3.1) of the Regulations;
• and evaluate the measures taken to implement the United Nations Security Council sanctions against the a black listed country by the jurisdiction in which the foreign financial institution was incorporated and the jurisdiction in which it conducts transactions in the context of the correspondent banking relationship.

Read the entire advisory here
https://fintrac-canafe.canada.ca/notices-avis/avs/2025-11-28-eng