As new regulations in relation to client identification come into force on October 1, 2025, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) updated its guidance on the use of an agent or mandatary and its guidance on unrepresented parties in real estate transactions.

Use of an agent or mandatary

Starting October 1, 2025, businesses subject to the Act can use an agent or a mandatary to verify the identity of a corporation or an entity on their behalf. Prior to October 1, 2025, using an agent or a mandatary could only be relied on when verifying the identity of a person.

For more information, refer to FINTRAC’s guidance: Methods to verify the identity of persons and entities.

Real estate sector – Unrepresented parties

Starting October 1, 2025, real estate sales representatives and brokers must verify the identity of unrepresented parties, i.e., any party who takes part in a purchase or sale of real estate and is not represented by a real estate broker or sales representative. Real estate brokers and sales representatives must keep an information record on unrepresented parties and make the associated third party determination for these parties in real estate transactions.

For more information, refer to FINTRAC’s guidance: