OTTAWA — Canada’s September 2026 evaluation by the Financial Action Task Force (FATF) should serve as a defining moment for the country’s financial sector.
The report recognizes substantial improvements in Canada’s anti-money laundering and anti-terrorist financing framework. Financial intelligence has become more sophisticated, inter-agency cooperation has improved, and important advances have been made in beneficial ownership transparency.
But are we becoming better at regulating financial institutions than we are at prosecuting the criminals exploiting them?
As I will unpack throughout this piece, the central test is whether Canada can translate its growing financial intelligence capabilities into meaningful enforcement—dismantling professional money laundering networks, prosecuting their facilitators and stripping criminal enterprises of the wealth that sustains their operations.
The answer may depend, in part, on resolving thorny questions surrounding Canada’s legal framework and the role of legal professionals in financial transactions.
After more than five decades investigating organized crime and financial wrongdoing, including serving as the RCMP’s National Director of Proceeds of Crime and subsequently working in senior banking compliance roles, I believe this question goes to the heart of Canada’s financial crime problem.
The FATF findings reveal a system making measurable progress while continuing to struggle with professional money laundering, beneficial ownership transparency, complex prosecutions and recovering criminal proceeds.
For Canada’s banks, credit unions, money services businesses, virtual asset service providers and other reporting entities, compliance expectations are rising. Regulatory supervision is becoming more targeted. Technology and data analytics are increasingly important. And boards of directors will face growing pressure to demonstrate that their financial crime programs are effective in practice, not simply documented on paper.
On October 9, 2026, FINTRAC’s Deputy Director of Supervision and Chief Compliance Officer, Tina Matos, delivered a significant address to the Canadian ACAMS community. She made clear that FINTRAC intends to become a more sophisticated, technologically capable and risk-focused supervisor.
According to the address, the Centre’s funded supervisory envelope is increasing from approximately $60 million in 2025–26 to $85 million in the current fiscal year.
FINTRAC intends to use its expanded resources to deepen supervision across financial institutions, virtual currencies and online gaming while supporting oversight of newer sectors, including mortgage lending, leasing, financing and factoring. Its transformation also includes modernized technology, a proposed universal enrolment program and an expanded administrative monetary penalty framework.
It will no longer be sufficient to produce a risk assessment, maintain an extensive compliance manual and demonstrate that transactions have been screened. Regulators increasingly expect a clear and defensible connection between an institution’s risk exposure, the controls it has implemented, how those controls operate and the results they achieve.
Financial institutions should anticipate deeper, more focused examinations where identified risks justify greater scrutiny. Significant or repeated non-compliance may attract stronger enforcement responses as FINTRAC’s enhanced framework is implemented.
Yet FINTRAC has also emphasized that supervision should be fair and proportionate. Institutions with lower risk profiles should not automatically face the same supervisory intensity as organizations operating in materially higher-risk environments.
That distinction is especially important to smaller banks, credit unions and specialized financial institutions, many of which already bear substantial compliance costs. Risk-based supervision cannot simply mean more regulation. It must mean better-targeted regulation.
The FATF evaluation also provides a practical roadmap for financial institutions.
First, institutions must revisit how they assess risk.
