FINTRAC for buyers: what to expect when you put down a deposit

The first time you put down a real-estate deposit in Canada, your realtor will ask for two pieces of government-issued ID, your full name and date of birth, your occupation, and questions about where the money is coming from. If you're new to this, it can feel like overreach.

It's not. It's FINTRAC.

What FINTRAC is

FINTRAC — the Financial Transactions and Reports Analysis Centre of Canada — is the federal anti-money-laundering regulator. Real-estate brokerages, mortgage broker partners, and financial institutions are all "reporting entities" under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). They have specific obligations to:

• Identify clients before transactions
• Verify identity with government documents
• Report certain transactions to FINTRAC
• Keep records for five years

The realtor is the one collecting your information. The brokerage is the one ultimately accountable.

The forms that matter

You won't sign these directly — your realtor and brokerage handle them — but you'll see them referenced in your closing documents. Here's what each does:

• Form 630 — Receipt of Funds Record. Filed when the brokerage receives an amount of $3,000 CAD or more (any source). Captures who paid, the amount, the source, and the destination.
• Form 631 — Large Cash Transaction Record (LCTR). Filed for cash payments of $10,000 CAD or more. Almost nobody pays a real-estate deposit in physical cash, so you'll rarely see this. EstatePulse drafts it automatically when triggered.
• Form 632 — Suspicious Transaction Report (STR). Filed when there are reasonable grounds to suspect a transaction is related to money laundering or terrorist financing. Confidential — you don't see it; the regulator does.
• Form 636 — Information Record. General client identification record kept by the brokerage. Holds your ID details and the agent's verification notes.

EstatePulse generates Forms 630, 631, and 636 automatically based on the deposit data we capture. Your broker reviews and submits them.

What you'll be asked

A typical buyer onboarding looks like this:

1. Government ID. Driver's licence + passport, or driver's licence + Canadian citizenship card. Health cards generally do not qualify under FINTRAC.
2. Date of birth and full legal name.
3. Occupation and employer.
4. Source of funds. Where the deposit money is coming from (savings, investment account, gift from family, sale of a previous property, etc.). For larger deposits, you may be asked for documentation — a bank statement showing the funds, a gift letter, or proof of sale.
5. Beneficial ownership. If you're buying through a corporation or trust, the brokerage must identify the real humans who control it (the "beneficial owners").
6. Politically exposed persons (PEP) check. Are you, or anyone in your immediate family, a current or former senior public official? PEPs trigger enhanced due diligence — not a problem, just more questions.
7. Sanctions screening. Your name is run against OSFI sanctions lists. This is automated and usually instant.

Triggers and timing

Most buyers will trigger at least one FINTRAC form. The most common is:

• You wire your $50,000 deposit to your brokerage's trust account. Form 630 (Receipt of Funds) is generated. That's it.

Less common, but possible:

• You pay $20,000 in physical cash. Form 631 (LCTR) is generated AND Form 630. Brokerages strongly prefer you not do this; it raises questions.
• You pay deposits across multiple transactions that aggregate above $10,000. Same — LCTR triggers on the aggregate. Splitting transactions to avoid the threshold is itself a red flag.
• The source of funds is unusual or hard to document. STR may be considered. The realtor cannot tell you when they file an STR; that information is kept from the client.

Beneficial ownership

If you're buying through a corporation, your brokerage will need to identify every individual who directly or indirectly controls 25% or more of the corporation. This includes shareholders, partners, and trustees of trusts. Names, addresses, dates of birth, and occupations are required for each.

This rule was strengthened in 2024 to close the "shell-company" loophole that had let foreign buyers obscure ownership. If you set up a numbered Ontario corporation to hold property, expect a thorough beneficial-ownership review.

What about non-residents?

Non-residents trigger additional checks: residency declaration (which we cover in our Newcomer guide), Prohibition Act eligibility, and the Non-Resident Speculation Tax (NRST) if applicable. FINTRAC forms still apply — usually with extra source-of-funds documentation.

The bigger picture

FINTRAC isn't about distrust. It's about creating a paper trail that makes laundering money through Canadian real estate hard. The system isn't perfect (academic studies show real-estate ML is still a problem), but the framework is real, the obligations are enforced, and the fines for non-compliance are significant.

When your realtor asks for your driver's licence and where the deposit is coming from, they aren't being nosy. They're doing their job. The good news: with EstatePulse, almost all of this happens once, in your profile, and we re-use the data on every transaction.

This post is general information, not legal or compliance advice. Brokerage-specific FINTRAC obligations are detailed in your brokerage's compliance policies; consult them or a Canadian real-estate lawyer for case-specific questions.