FINTRAC Beneficial Ownership & Third Parties

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About Course

This course focuses on beneficial ownership and third-party involvement in real estate transactions, which are key risk areas under Canada’s anti-money laundering requirements.

Participants will learn how to recognize situations where the individual listed on a contract may not be the person who ultimately owns or controls the transaction. The course explains how corporations, nominees, family members, or other third parties may be involved in providing funds or directing a transaction.

Topics covered include:

• What beneficial ownership means in FINTRAC compliance
• The 25% ownership or control threshold
• Common ownership structures such as corporations, trusts, and holding companies
• Identifying third-party involvement and nominee arrangements
Risk indicators and red flags in residential and commercial transactions
• The proper internal escalation process when ownership or funding is unclear
• A reminder of tipping-off rules and appropriate client communication

Agents and staff are not expected to investigate ownership structures, but they must be able to recognize potential risks and escalate concerns internally.

This training forms part of Renanza Realty Inc.’s ongoing FINTRAC compliance program. Completion helps ensure agents and staff understand their obligations when ownership, control, or funding sources are unclear in a transaction.

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What Will You Learn?

  • Understand what beneficial ownership means in real estate transactions
  • Recognize when the person on the contract may not be the true owner
  • Identify common ownership structures such as corporations and trusts
  • Recognize third-party involvement in residential and commercial transactions
  • Identify risk indicators and red flags related to ownership and funding
  • Understand when and how to escalate concerns through the brokerage compliance process
  • Understand tipping-off rules when communicating with clients

Course Content

Why Beneficial Ownership Matters
Beneficial ownership refers to the individual who ultimately owns or controls a transaction, even if their name does not appear on the contract or title. Criminals often use corporations, nominees, or third parties to hide their involvement in real estate transactions. Understanding beneficial ownership helps agents recognize potential risks and escalate concerns appropriately.

  • What is Beneficial Ownership
  • Why Criminals Use Beneficial Ownership Structures
  • FINTRAC Expectations for Real Estate Professionals

Understanding Ownership Structures
Many real estate transactions involve corporations or other legal entities. These structures are common and legitimate but may also be used to conceal the identity of the true owner.

Third Parties in Real Estate Transactions
A third party is someone who participates in a transaction by providing funds, instructions, or influence but is not named as a party in the agreement.

Risk Indicators and Red Flags
Certain behaviors or transaction patterns may indicate attempts to conceal beneficial ownership or use third parties to move funds.

Escalation and Compliance Process
Real estate professionals are responsible for recognizing risk indicators but not for conducting investigations.