Canadian Mortgage, Financing & Leasing AML Starter Kit — FINTRAC New Sectors (Word + Excel)
Mortgage brokers, lenders, and administrators became FINTRAC reporting entities on October 11, 2024 — and financing and leasing businesses (including car dealers that offer financing) on April 1, 2025. There's no registration to apply for: the PCMLTFA obligations simply apply, and most businesses in these sectors are building an AML program for the first time. This kit is that program, written for your sector — 18 branded, fully editable templates, from the compliance program manual through source-of-funds verification and the scored risk assessment workbook.
What's included (18 items):
- AML/ATF Compliance Program Manual — written for the mortgage and financing/leasing sectors
- Compliance Officer Appointment Pack — appointment record, role charter, annual attestation
- Effectiveness Review Guide — the required two-year review, structured end to end
- KYC/CDD Procedures — borrower/lessee identification, beneficial ownership, risk ratings
- PEP/HIO & Sanctions Screening Procedure
- Transaction Monitoring Procedure — origination and servicing-stage monitoring
- STR Reporting Procedure — escalation to filing
- Large Cash & EFT Reporting Procedure — LCTR/EFTR and the 24-hour rule for funds you receive
- Source of Funds & Down Payment Verification Procedure — evidence standards by risk level, gift letters, third-party funds
- Record-Keeping Procedure — the five-year retention standard
- Mortgage Client KYC & Source of Funds Form (Word)
- Financing & Leasing Client KYC Form (Word)
- Staff AML Training Program — including broker and dealer partners
- ML/TF Red Flags Quick Reference — sector typologies (straw buyers, third-party down payments, buyout patterns)
- AML Risk Assessment Workbook (Excel) — 17 sector risk factors, automatic inherent/residual scoring
- Reporting & Compliance Registers (Excel) — STR, LCTR/EFTR, ID verification, and training logs with due-date helpers
- Copyright & Licence Terms
- Start Here Implementation Guide — including what "new to FINTRAC" actually requires
Who it's for: Canadian mortgage brokers, mortgage lenders, mortgage administrators, financing companies, leasing companies, and dealers that arrange financing — any business brought under the PCMLTFA in the 2024–2025 sector expansion that needs a complete, practical AML program without paying consulting rates to draft one from a blank page.
How it works: Download the ZIP, replace the [BRACKETED] placeholders with your organization's details, have senior management approve the manual, and follow the Start Here guide's implementation order. Every document carries professional formatting: document control, approval blocks, and review cycles built in.
Please note: Templates and general information, not legal advice. FINTRAC's guidance for these sectors is recent and evolving; confirm your category, thresholds, and deadlines against current FINTRAC guidance and have your program reviewed by qualified Canadian counsel before relying on it.
Copyright & licence: © 2026 Zee Consulting. All rights reserved. This product and everything in it is the intellectual property of Zee Consulting. Your purchase gives one named organization a licence to use and customize the documents for its own internal business — nothing more. The files must not be resold, shared, redistributed, sublicensed, or given to clients or any other organization, in original or modified form. Anyone who uses these materials without a licence is infringing copyright, and Zee Consulting reserves the right to pursue litigation and claim damages and legal costs to the fullest extent permitted by law. The full Copyright & Licence Terms are included in the download (Copyright_and_Licence_Terms.docx) and inside the Start Here guide.
Requirements: Microsoft Word and Excel (or compatible: Google Docs/Sheets, LibreOffice). Instant download after purchase — no shipping, no waiting.