Real estate finance and enforcement agencies address complex fraud and cross-border threats

Executives from Canada’s leading banks and financial firms will join government officials in Toronto next month to address evolving threats in financial crime and the tightening web of anti-money laundering (AML) regulations.
The event will take place at the 24th Annual Canadian Forum on Anti-Money Laundering and Financial Crime, hosted by the Canadian Institute on June 25–26 at the One King West Hotel.
It comes amid growing concern over the rise of complex mortgage fraud schemes used to launder illicit money through Canada’s housing market, as well as new compliance challenges from the US Corporate Transparency Act and cross-border reporting changes.
Complex mortgage fraud
Mortgage-related money laundering, though harder to detect and less frequent than other fraud types, has become a priority for regulators due to its far-reaching effects. Criminals have been known to use property purchases, funded through mortgages with unknowing or complicit lenders, to integrate illegally obtained cash into the financial system. These transactions often rely on straw buyers and intermediaries to obscure their origins.
In a typical scheme, down payments and mortgage instalments move criminal funds into the banking system. Later, the property is sold, the mortgage discharged, and profits redirected into illicit activity. Because these transactions mimic legitimate behaviour, uncovering them remains a major challenge for financial institutions and national security agencies.
To address the threat, the federal government has brought more mortgage and real estate professionals under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). As of 2024, mortgage brokers, administrators, lenders, and real estate agents are considered reporting entities, now required to adhere to compliance regulations and report suspicious transactions to the Financial Transactions and Reports Analysis Centre of Canada (FinTRAC).
FinTRAC, in turn, processes that intelligence for use by law enforcement and national security bodies. However, experts argue that additional reforms and more robust enforcement capacity will be needed to close persistent gaps in oversight.
Cross-border compliance
US financial policy changes are also creating new challenges for Canadian institutions. In March 2025, the US Treasury’s Financial Crimes Enforcement Network (FinCEN) confirmed that foreign entities deemed “reporting companies” must meet Beneficial Ownership Information (BOI) reporting requirements under new deadlines.
This development means Canadian banks must respond quickly to evolving expectations from American regulators, particularly as scrutiny of cross-border flows intensifies.
“There's a lot changing,” said Karen Creen, chief compliance officer and chief AML Officer at First Nations Bank of Canada and conference co-chair. “We’ve moved into Gen 2 reporting with FINTRAC. We have the FATF mutual evaluation coming. There’s the new reporting of sanctioned property. There’s a lot of moving pieces, as always in AML.”
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The two-day forum will feature keynotes from Tina Matos, chief compliance officer and deputy director of supervision at FINTRAC, and Gabriel Ngo, director of the independent review office at the Bank of Canada. Topics include:
- Lessons from recent US enforcement actions targeting Canadian financial institutions
- Economic and compliance risks tied to the US election outcome
- Real estate and crypto sector vulnerabilities
- FATF evaluation preparation and global BOI compliance
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