Canada: banks and other reporting entities must flag beneficial ownership discrepancies to Corporations Canada
From 1 October 2025, FINTRAC-regulated reporting entities must check Corporations Canada's register of individuals with significant control for CBCA corporations they rate high risk, and report material discrepancies within 30 days. Typos and address differences do not count. CBCA corporations can expect their ISC filings to be compared with what they give their banks and advisers.
Amendments to Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations took effect on 1 October 2025. They add a beneficial ownership discrepancy reporting duty linked to Corporations Canada's register of individuals with significant control (ISCs).
What changed
- Reporting entities regulated by FINTRAC, such as banks, accountants and others with anti-money laundering duties, must consult Corporations Canada's database for Canada Business Corporations Act (CBCA) corporations they assess as high risk.
- If the beneficial ownership information they hold differs materially from the ISC information on the register, they must report it to Corporations Canada within 30 days, unless it is resolved within that time.
- Material means substantive, such as a missing beneficial owner. A spelling mistake, a minor name or address variation, or a service address against a residential address does not count.
- Reporting for lower-risk corporations is voluntary. Reports are made through Corporations Canada's online application.
Who is affected
CBCA corporations, whose ISC filings will be checked against what they tell their banks and advisers, and FINTRAC reporting entities.
What to do
Make sure the ISC register, the ISC filing with Corporations Canada and the ownership information given to banks all match.