FINTRAC updates Iran transaction directive guidance for Canadian reporting entities

OTTAWA, June 23, 2026 — Canada’s financial intelligence unit updated guidance tied to the ministerial directive on financial transactions associated with the Islamic Republic of Iran, setting out compliance steps for persons and entities covered by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

The guidance says the directive, first effective July 25, 2020, was amended Feb. 15, 2024, and Nov. 15, 2025. As of Nov. 15, 2025, it applies to every person or entity referred to in Section 5 of the act.

Covered firms must treat every financial transaction originating from or bound for Iran as high risk, regardless of amount. They must verify the identity of any client requesting or benefiting from such a transaction, carry out customer due diligence with particular attention to sanctions evasion risk, obtain information on the source of funds or virtual currency and the purpose of the transaction, determine beneficial ownership or control for relevant entities, keep records and report the transactions to FINTRAC.

The guidance also addresses transactions routed through intermediary jurisdictions, saying the directive applies when available information indicates a connection to Iran. It gives examples including origin or destination addresses in Iran, transactions involving Iranian rial, funds linked to assets sold in Iran, online transactions traced to an Internet Protocol address geolocated in Iran, and casino disbursements bound for Iran.

For correspondent banking, entities covered by subsection 9.4(1) of the act must factor Iran sanctions evasion risk into required measures for foreign financial institutions and evaluate how the relevant jurisdictions implement U.N. Security Council sanctions against Iran.

FINTRAC said the directive expands reporting in some cases by removing or lowering thresholds for electronic funds transfers, cash, virtual currency, casino disbursements and certain negotiable instrument transactions tied to Iran. The guidance says completed transactions must be reported when the sole reason for reporting is that they originate from or are bound for Iran, while attempted transactions remain reportable where there are reasonable grounds to suspect a money laundering, terrorist financing or sanctions evasion offense.

The update also provides a six-month transition for casinos. Until Dec. 23, 2026, casinos may continue reporting under-threshold casino disbursements using a suspicious transaction report; after that date, they must use the casino disbursement report.