How to Complete and Upload FINTRAC Compliance Records

Summary

This playbook provides standard procedures for identifying clients, checking for international political exposure, and documenting the receipt of funds in compliance with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) regulations. Adhering to these steps ensures our file compliance with Royal LePage Performance Realty and federal anti-money laundering laws.

Required Client Information & Verification Videos

Data Gathering Requirements

Before beginning any paperwork in NexOne, the Realtor must collect the following foundational components from the client:

Valid Photo ID: A clear photo of a Driver's License or Passport. The ID must be current and cannot expire within a few months of the transaction closing date.
Current Residential Address: Must be the client's actual current living address. If using a Passport for identification, this information must be verified separately since passports do not list residential addresses.
Employment Details: Current employer name and the full title of their position.
Note on Employment: If a client is retired or unemployed, enter "retired from" or "last employer" followed by their historic industry data. "Stay-at-home parent" is considered a valid career option and should be written exactly as such.

Video Walkthroughs

Review these step-by-step video tutorials created by the team before filling out your first electronic package:

Step-by-Step Form Instructions

Form 1 — Individual Identification Information Record

The Realtor must meticulously fill out this record for every individual buyer or seller appearing on title.

Section A (Verification of Individual): Fill in full legal names exactly matching the photo ID.
Section A.1: Input the details of the federal, provincial, or territorial government-issued photo ID (ID type, unique number, province/country of issue, and expiry date).
Section B.1 & B.2 (Third-Party Determination): Complete these fields if you check "Yes" indicating a third party is steering or funding the transaction.
Sections C & D.1: Complete the Client Risk Core Calculation and establish the Business Relationship parameters.
Additional Sections: Assess the specific client circumstances to determine if remaining sections are required. If uncertain, escalate to the Sales Lead or Integrator in your daily check-in[cite: 1, 3].

Form 2 — Politically Exposed Persons (PEP) & Head of International Organizations (HIO) Checklist

This document tracks high-risk corporate and political affiliations.

Verification Screening: Confirm if the client is or is not a Politically Exposed Person or a Head of an International Organization. Use the free verification tool provided by the brokerage or ask the client directly during their consultation.
Employment Tracking: Input the client's current or historical corporate title using the exact guidelines defined in the Data Gathering Requirements section above.

Form 3 — Receipt of Funds Record

The Realtor handles the data entry for this form, while the Operations seat ensures compliance tracking during conditional periods. This form is mandatory for Buyer Clients.

Required Element	Source of Information	Action Needed
Official Deposit Receipt	Listing Brokerage	Request from the listing agent. Upload directly to NexOne.
Account Holder Name	Deposit Receipt	The name of the individual who submitted the deposit will appear on the receipt.
Account Number	Cheque / Client	Capture at least the last 6 digits (full account number preferred). This information is at the bottom of a cheque, if that was the method of submission. If the deposit was submitted via another method, you will have to ask the client directly.
Account Type	Client	Specify if funds originate from a Chequing, Savings, or Trust account.

Critical Compliance Note: If the deposit funds are provided by someone other than the individuals listed on the property title, you must complete a separate Individual Identification Record and PEP Checklist for that specific entity.

File Naming & Upload Standards

Standard Nomenclature Style

To maintain consistency for our Operations transaction audits, all compliance documents uploaded to NexOne must match our team file naming conventions exactly.

Use the property address, document abbreviation, and the human client's name:

Individual Identification: [Property Address] - FINTRAC [Client First and Last Name]
- Example: 123 Banana Street 305 - FINTRAC Marty McFly
PEP Checklist: [Property Address] - FINTRAC PEP_HIO [Client First and Last Name]
- Example: 123 Banana Street 305 - FINTRAC PEP_HIO Marty McFly
Receipt of Funds: [Property Address] - FINTRAC ROF
- Example: 123 Banana Street 305 - FINTRAC ROF
Brokerage Escrow Receipt: [Property Address] - Deposit in Trust
- Example: 123 Banana Street 305 - Deposit in Trust

Submission Timelines & Handoffs

Timeline: All completed compliance records must follow the Faltour - Transaction Data Entry Standards and be fully submitted in NexOne within 5 days of an offer going firm.
System Review: Operations performs regular file updates and cleanups every Wednesday to ensure no documents or signature certificates are missing from active transaction loops.