Glasslake Funding’s Doug Robinson: FINTRAC non-compliance is a risk brokers can no longer ignore
With additional reporting by Fergal McAlinden
Two years after mortgage brokers became reporting entities under Canada’s anti-money laundering framework, a senior industry voice is sounding a warning: the window for wilful inaction has closed.
Doug Robinson of Glasslake Funding, a Toronto-based alternative mortgage lender, drew on a dual background in policing and lending to take stock of where brokerages stand on compliance.
Robinson was speaking at the Mortgage Professionals Canada conference in Calgary, two years on from October 11, 2024, the date on which the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) brought mortgage administrators, brokers and lenders under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).
“I can pretty much guarantee this will not blow over,” Robinson said.
“If you’re a broker or owning a brokerage and you haven’t done any work on FINTRAC stuff, you may want to.”
Robinson described two camps that emerged when the rules were first announced: those who hired compliance staff, documented policies and prepared in earnest, and those who hoped the requirements might quietly disappear.
As the debate over challenging FINTRAC requirements for brokers rumbles into 2026, Robinson argued the regulator’s baseline expectations are more achievable than commonly assumed.
“FINTRAC doesn’t want mortgage brokers to become experts in reporting money launderers,” he said.
“They just wanted to add mortgage brokers because you guys are governed by a regulator and you have an obligation, and it fortifies Canada’s anti-money laundering landscape.”
Know your client — or know the risk
Robinson anchored his anti-money laundering (AML) framework around three questions every broker must be able to answer: who is the applicant, how will they service the mortgage, and where did the down payment come from? The third, he said, is the most exploited vulnerability in the transaction chain.
“In lending and in mortgages, the down payment is usually, in my opinion, the softest spot,” Robinson said.
“If someone’s looking to get a whole bunch of money into the system in one spot, they’ll usually do it through down payment.”
He urged brokers to build what he called “reasonability statements” — documented explanations that account for the origin of funds — warning that gift letters alone carry limited evidentiary weight.
“The reasonability statements go a long way,” he said.
Policies, risk ratings, and a lender blind spot
Robinson outlined five elements every brokerage should have in place:
- a designated compliance officer or administrator
- written policies
- a company-level risk assessment
- AML training — leverageable through MPC for smaller shops
- a completed two-year self-assessment
A smaller brokerage, he noted, can assign compliance responsibilities to an administrative staff member, provided the function is kept separate from the sales side.
His sharpest criticism was aimed at lenders. “In my opinion, lenders are soft on being concerned about where the repayment comes from,” Robinson said.
Accelerated or lump-sum payments made after funding, he argued, too often pass without scrutiny, a gap that sophisticated money laundering schemes are positioned to exploit.
Robinson also flagged British Columbia’s unexplained wealth orders (UWOs), a civil mechanism under the province’s Civil Forfeiture Act that can compel individuals to account for assets exceeding $75,000 that appear disproportionate to their known income, all without requiring a criminal conviction.
Some mortgage professionals argue that regulation is both burdensome and necessary. Robinson, a former police officer, sits firmly in the latter camp. He suggested the UWO model could spread beyond British Columbia as the courts test its constitutional limits.
“There’s no downside to reporting an unusual transaction report to FINTRAC,” he said.
“Sometimes big investigations start from a really small report that someone put in sometime.”
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