In October 2026, FC conducted it’s biannual effectiveness audit as a requirement for FINTRAC. The results showed a few areas where agents can focus to ensure they (and the brokerage) are staying compliant:
When do our obligations start: Our AML obligations don’t just kick in when we submit a compliance package; if you pull credit or ID your client, you need to conduct your AML obligations (risk assessment and justification, PEP and sanctions screening, ID verification) regardless if the deal is cancelled, declined, or the client chooses not to proceed.
If you’re early in the file and you don’t have all the info, that’s okay. Document your assessment based on what you have available to you. If a client comes back or the information changes, your assessment can be updated.Entity borrowers: For borrowers who are not individuals, you have additional obligations - documenting not only proof of existence, but beneficial ownership as well (individuals who own more than 25% of the corporation). It’s important that this is included in compliance. As a reminder, there are additional requirements for high-risk corporations.
The Platform Matters: Filogix and Velocity are quite different in how they manage their AML obligations - but an agent/broker’s obligations are the same no matter what platform you use. Regardless of how it’s tracked, you need to make sure you’re fulfilling all of your obligations - making notes about your risk justification, ensuring that you’ve made a third-party determination - and documenting these things.
Right now, Velocity is ahead of Filogix with regards to documentation. Filogix users can expect a solution from the brokerage in the near future to bring the platforms back to a more consistent level.Prove It: As a reminder, it’s not enough to say “I conducted due diligence” or “enhanced due diligence completed” as the entirety of your justification. The steps you took should be spelled out in detail (e.g., adverse media searches, review of income and down payment documents, extra verification of identity, etc.) and any document you look at to verify these things should be included in compliance.
Use the resources available to you: You have resources available - the DLC Interactive Scorecard; the brokerage’s resources available through the portal, a dedicated compliance and AML team … so take advantage of them. If you’re at all unsure about your obligations or have a file-specific question, we encourage you to reach out to the AML Officer (james@fcfunding.ca).
If there’s any questions, don’t hesitate to reach out to the compliance/AML team.