1. Boiling down the investment management division’s annual report

The Ontario Securities Commission’s investment management division is responsible for the regulatory framework for investment funds, investment fund managers and portfolio manager services. In OSC Staff Notice 81-739 Investment Management Division Annual Summary Report (the Report), the division describes its key operational and policy initiatives that impacted investment fund issuers and advisers over the last fiscal year, summarizes public fund filings made over the past year, exemptive relief granted to public funds and provides a general description of the division’s responsibilities.

There is helpful information in the Report relevant to registrants involved in the management and distribution of investment funds in the exempt market. For example, the Report discusses exemptive relief that is frequently sought for fund of funds from the financial statement filing and delivery deadlines. This relief is sought when a fund invests a significant portion of its assets in foreign funds with different reporting deadlines, to give the auditors of the top fund an opportunity to consider those statements in the top fund audit. It is noted that staff will not likely grant relief on a future oriented basis. The Report reminds filers that the application for relief must include certain information, including:

  • A description of the fund’s investment objectives and strategies, and how they are met by investing in underlying funds;
  • The % of the pooled fund’s net assets in the underlying funds;
  • The domicile of the underlying funds;
  • Why the relief is required (i.e. confirmation from the auditor that the underlying fund information is necessary);
  • The specific amount of additional time requested and an explanation for the amount of time;
  • The alternatives that were considered (i.e. changing year end) and why the alternatives are not feasible; and
  • The method by which the filer will let the security holders of the pooled fund know about the exemptive relief AND give them the opportunity to exit the fund on reasonable terms after being told of the relief.

With respect to registrant regulation, the Report also references bulk transfer applications, where a large number of registered individuals move from one firm to another as the result of a business transaction. In these kinds of applications, the acquiring firm typically files an application for exemptive relief from the individual form filing requirements, so that the transfer of registered or permitted individuals and business locations can be done on a ‘bulk transfer’ basis. The Report reminds registrants that Appendix D of Companion Policy 33-109CP Registration Information lists the circumstances in which regulators will consider granting this relief and the information that should be included in the application. For staff to consider granting the relief, at least 25 people must be part of the transfer and relief should be sought at least 30 days prior to the effective date of the transfer.

In addition, staff continue to find issues in s. 11.9 and 11.10 notices for the acquisition of a registrant’s securities and remind registrants to use the voluntary notice form, provide the notice as soon as the firm knows, or has reason to believe, that 10% or more of its voting securities or securities convertible into voting securities are going to be acquired, and to file the notice a minimum of 30 days before the closing of the proposed transaction.

Finally, the Report recaps information from Staff Notice and Consultation 11-348 Applicability of Canadian Securities Laws and the Use of Artificial Intelligence Systems in Capital Markets and reminds registrants to include their use of AI systems (and related risks) in their policies and procedures.

For more information on the Report and its impact on managers of public funds, please see BLG’s Insight below.

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2. Finding the right flow: Proposed new self-certified investor prospectus exemption

Fall is always a busy time for regulatory consultations and Fall 2025 was no different as the regulators in a number of jurisdictions other than British Columbia and Québec released CSA Notice and Request for Comment Proposed Multilateral Instrument 45-111 Self-Certified Investor Prospectus Exemption (together with its proposed companion policy, the Proposed Exemption) relating to a new harmonized prospectus exemption for eligible investors.

The Proposed Exemption is intended to work similar to the existing accredited investor prospectus exemption, where an individual would be permitted to purchase securities if they can certify that they meet the qualifying criteria based on their education or experience, sign Form 45-111F2 Acknowledgement of Risks and are provided with Form 45-111F3 Information to Understand before Making an Investment. Such investors would be permitted to invest up to $50,000 per year across a number of non-investment fund issuers that have their head office in Canada.

In order to be eligible to purchase securities under the Proposed Exemption, investors would need to complete Form 45-111F1 Confirmation of Qualifying Criteria and certify that they meet at least one of the following criteria:

  1. Qualifying Employment History. A number of eligible alternatives are presented under this qualifying criteria, including that the investor has a minimum of five years of management, engineering, product development, or other relevant operational experience at a business that operates in the same industry or sector as the issuer in which the investor wishes to invest.
  2. Qualifying Degree. There are a number of different potential degrees listed in the Proposed Exemption, including an accredited Master of Business Administration (MBA), Doctor of Business Administration, PhD or master’s degree from a university, where the degree specializes in finance or economics or an accredited undergraduate degree in finance, business, or commerce from a university if the investor has a minimum of three years of relevant employment experience.
  3. Qualifying Designation. No less than eight potential designations are listed, including the Chartered Financial Analyst (CFA) designation, the Chartered Investment Manager (CIM) designation, the Certified Financial Planner (CFP) designation or a Financial Planner or Financial Advisor credential, in good standing, from a credentialling body approved by the Financial Services Regulatory Authority of Ontario under the Financial Professionals Title Protection Act, 2019, or from a credentialing body comparable to FSRA under corresponding legislation in other participating jurisdictions, that permits the individual to use the Financial Planner or Financial Advisor title.
  4. Qualifying Examination. Examples of qualifying exams include passing the Canadian Securities Course Exam administered by the Canadian Securities Institute and the Exempt Market Products Exam administered by the IFSE Institute Canada.

Especially interesting (as it is not currently permitted in all jurisdictions) is the proposal to allow a distribution of securities to a special purpose vehicle if all of the owners of interests (except the voting securities required by law to be owned by directors), are accredited investors or self-certified investors. Each self-certified investor investing in the special purpose vehicle would be subject to the aggregate individual investment limit described above, but not the vehicle itself.

Consequential amendments would be made to other prospectus exemptions, including a clarification that includes self-certified investors in the list of purchasers that can purchase under the private issuer prospectus exemption.

Issuers that distribute securities on the basis of the Proposed Exemption would need to file a report of exempt distribution on Form 45-106F1 Report of Exempt Distribution no later than the 30th day after the distribution. In certain jurisdictions, including Ontario, the seller must also deliver to the securities regulatory authority a copy of any offering memorandum used with the Proposed Exemption no later than the 30th day after the distribution.

If adopted, the Proposed Exemption would replace a number of existing blanket orders and exemptions. A number of questions are posed with respect to the qualifying criteria and risk disclosure forms. Comments will be accepted until January 5, 2026, and we would be pleased to assist you with a letter, should you wish to participate.

3. There’s a new syrup in town: Update on CIRO’s incorporated advisor compensation option

The industry has been carefully watching the Canadian Investment Regulatory Organization (CIRO) publications on advisor compensation options. Recently, the Canadian Securities Administrators (CSA) published a recognition of CIRO Bulletin #25-0297 Update on the project to develop rule amendments relating to the proposed adoption of an incorporated advisor compensation option.

Currently, if an individual advisor is sponsored by an investment dealer, the applicable rules require them to be compensated directly as either an employee or individual agent of their sponsoring dealer. If an individual advisor is sponsored by a mutual fund dealer, the applicable rules require them to be compensated directly as either an employee or individual agent of their sponsoring dealer, or under specified conditions, a part of their compensation can be paid to the advisor’s personal corporation for activities carried out by the corporation on the sponsoring dealer’s behalf.

In the CIRO bulletin #25-0297, it is noted that CIRO will propose amendments to harmonize the allowable compensation options for individual advisors sponsored by investment dealers or mutual fund dealers while ensuring that investor protection regulatory obligations to clients remain obligations of the sponsoring dealer, the relevant individual sponsored advisors and of the sponsored advisor’s personal corporation (and potentially the personal corporation’s employees and shareholders). Dealers must supervise activities conducted by the advisor and the advisor’s corporation on their behalf.

The proposal is expected to include, amongst other things, that the use of personal corporations would be limited to client-facing Approved Persons and that the corporation would need to be approved by CIRO under a new non-individual category of Approved Person, “Incorporated Approved Person”, to ensure that CIRO has jurisdiction over its registerable activities. In addition, the shareholders of the advisor corporation would be limited to an enumerated list of people, while voting ownership must be controlled by the individual advisors that provide qualifying regulated financial services to clients through the corporation.

In its press release, the CSA noted that CIRO is continuing to pursue this policy work and that the CSA will continue to monitor CIRO in this regard in the ordinary course as CIRO drafts rules subject to approval by the CSA.

4. Sweetening compliance - Updated CIRO proficiency and other guidance

In advance of the new proficiency model set to come into effect on January 1, the Canadian Investment Regulatory Organization (CIRO) has been busy this last quarter releasing guidance aimed at helping dealers and their approved individuals understand the new regime.

As examples, on September 26, 2025, CIRO released Guidance on Relevant Education and Experience Requirements (Education Guidance) which relates to compliance with the proficiency principles for minimum education and experience requirements, dealer considerations regarding relevant education and experience requirements, and reporting on the National Registration Database (NRD).

The Education Guidance describes factors for dealers to help assess the relevancy of an individual’s education or experience before submitting an application to CIRO for approval. Considerations include the applicable CIRO approval category, including client and product types, the dealer’s business model as it applies to the approved role, and the activities and responsibilities of the Approved Person.

That same day, CIRO also released guidance concerning CIRO Proficiency Exemption Requests (Exemption Guidance) providing a general overview of the CIRO proficiency exemption request process for investment dealers and Approved Persons, as well the information required when requesting an exemption from CIRO exams. The Exemption Guidance notes that the onus is on the dealer and the applicant to provide the information for CIRO to determine if the alternative proficiency (such as an alternative educational course, training or experience) is acceptable and (at a minimum) equivalent to the applicable prescribed proficiency requirement.

The Exemption Guidance specifies that staff will not support an exemption based on a course or materials intended as preparatory for passing a CIRO exam. It also notes that staff would not support an exemption application from the relevance requirement with respect to an applicant’s education or experience. If a request is made on the basis of equivalent education or experience, a comparative analysis must be provided in order to support the request, and such information can be presented in the form of tables, charts or descriptive paragraphs that clearly demonstrate equivalency.

5. Grade A obligations: New Ontario AFS non-delivery list

On October 8, the Ontario Securities Commission (OSC) announced measures relating to the use of the Offering Memorandum Prospectus Exemption in section 2.9 of National Instrument 45-106 Prospectus Exemptions. As signaled in other publications, the OSC will be enhancing its monitoring of the use of the exemption. As a result, both issuers relying on the offering memorandum exemption and exempt market dealers distributing these products should ensure the issuers comply with all requirements of the exemption.

Under the Offering Memorandum Prospectus Exemption, an issuer must, within 120 days of its financial year end, deliver annual audited financial statements to the OSC, prepared in accordance with IFRS, among other delivery requirements. In order to provide retail investors with additional information on non-reporting issuers raising capital in the exempt market, it has introduced an AFS non-delivery list (the List).

The List consists of names of non-reporting issuers that have used that exemption to distribute securities in Ontario but have not delivered their annual financial statements to the OSC as required in one or both of the issuer’s two most recently completed financial years. Issuers will be placed on the List no earlier than 30 days after the deadline for filing the statements, and staff will notify the issuer in advance to provide an opportunity to remedy the default or explain why the issuer is not in default. The List should be consulted frequently by issuers and dealers, as it is updated monthly as required.

In addition, the OSC’s Registration, Inspections and Examinations division has indicated that they will review exempt market dealers that distribute securities of certain non-reporting issuers that are not in compliance with the exemption in the context of the registrants’ know-your-product policies and procedures.

6. The maple standard: New proposed liquidity risk framework

Significant changes have been proposed to National Instrument 81-102 Investment Funds and its companion policy that would impact liquidity risk management (LRM) policies and procedures for all investment funds, regardless of their reporting issuer status. The proposed amendments would build on previously published CSA guidance and require funds to create a LRM framework, govern LRM operational matters, and require specific oversight of the LRM framework.

In the view of the CSA, non-reporting issuer investment funds are similarly susceptible to liquidity risk and should have a robust framework to manage this risk and thus will be subject to a number of the requirements set out in the amendments.

The proposed amendments would require investment funds to establish and maintain an LRM framework, including policies that address the matters set out in the consultation. The proposed operational requirements address LRM in various stages of the life of a fund, including its establishment and when considering potential portfolio transactions. Managers of new funds would need to ensure its objectives and strategies and redemption frequency align with the nature of the fund’s expected portfolio assets and expected redemption activity. A fund would also need to assess the impact of a portfolio transaction on its liquidity profile before entering into a transaction, as well as monitor the liquidity profile of the fund and relevant markets conditions on an ongoing basis to determine if adjustments to the portfolio assets are necessary. For this purpose, liquidity profile references the ability of the portfolio of the investment fund to be disposed of and settled quicky and easily without a significant loss in value.

Ongoing monitoring would include requirements for liquidity thresholds and targets to monitor, review and assess the fund’s liquidity profile. The proposals include specifically mandated stress testing, as well as contingency planning that would include the use of liquidity risk management tools, such as the suspension of redemptions, redemptions in kind, and the use of redemption fees. A fund would have to appoint an LRM supervisor or LRM committee to oversee the framework. If an individual, an LRM supervisor would have to be the CCO of the investment fund manager, or an individual who reports directly to the CCO (or a person who reports directly in respect of LRM matters). A LRM committee must include the CCO or a person who reports directly to the CCO. In any case, the individuals must have sufficient knowledge of the management of liquidity risk. The manager of an investment fund would need to refer matters that “would reasonably be expected to significantly impact the liquidity profile of the investment fund” to the LRM supervisor or LRM committee. Any such committee need to meet at least quarterly.

The companion policy expands on several details of the proposed LRM framework. In addition to the specific items in the Proposed Amendments, there are other matters relating to LRM that may need to be addressed in policies and procedures, including circumstances where independent valuations for portfolio assets are not available, and conflicts of interest between the fund and manager.

The CSA is also seeking feedback in a consultation paper on further changes to the LRM framework, including the use of specific LRM tools, liquidity classification of underlying assets, and regulatory disclosure related to LRM matters (including certain confidential reporting requirements).

Among other things, the consultation paper asks for feedback on whether there is a need to permit or require the use of liquidity management tools that are not currently permitted in Canada. The potential liquidity classification framework would require the classification of the liquidity of each of the fund’s investments when the fund is designed, as well as for each new investment, and a review of the liquidity classification of each of the fund’s investments on an ongoing basis (at least monthly). The liquidity classification would be based on the number of business days within which a fund’s portfolio asset would be readily disposed of and its disposition would be settled at an amount that approximates the amount at which the asset is valued for NAV calculation purposes. All investment funds, including private funds, would need to report on a confidential basis to the regulators the liquidity classification of each investment held by the fund on a quarterly basis. All investment funds, including private funds, would also need to report to the regulators when certain liquidity events occur, including if the fund suspends redemptions or borrows cash to accommodate redemption requests.

Comments are open until March 27, 2026. For more information on how these proposals could impact your business, please see BLG’s Insight.

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7. OSC report on digital engagement practices: Crossing the line from sweet to sour

Staff of the Ontario Securities Commission conducted a targeted sweep focused on the use of digital engagement practices (DEPs) by certain registered dealers and advisers, as well as certain crypto asset trading platforms. The sweep was designed to gain a greater understanding of the types of DEPs being used by registrants and to examine registrants’ compliance with securities law requirements. The results of the sweep were discussed in OSC Staff Notice 33-760 – Digital Engagement Practices: Focused Compliance Examination of Online Retail Platforms (Staff Notice).

As described in the Staff Notice, DEPs are tools that include behavioural techniques, differential marketing, gamification, design elements, or design features that intentionally or unintentionally engage with retail investors on digital platforms. Staff saw a range of both positive and potentially concerning uses of DEPs in the sweep. Some positive examples include:

  • helping clients track savings goals and monitor investment contributions; and
  • delivering educational nudges and alerts to promote account security and encourage long-term investing behaviour.

However, staff also found promotional or unsubstantiated language in push notifications, rewards programs, contests, and other features that prompt clients to trade more frequently, which would result in additional risks and fees for trades they would not have engaged in without the DEPs.

Other issues identified include the omission or concealment of material information about pricing and applicable charges, exaggerated or unsubstantiated claims about the registrant or an asset that is traded on the registrant’s platform; deficient policies and procedures related to the use of DEPs, and insufficient controls and supervision. Regulatory concerns identified include the potential provision of advice through the use of DEPs when they were linked to specific products or used to influence investment decisions, as well as potential conflicts of interest where the registrant would benefit from increased client activity.

The Staff Notice suggests that registrants develop policies and procedures relating to DEPs, which should include – at a minimum, the following: an assessment at the design stage to asses whether the interactions or marketing content could be inconsistent with the firm’s regulatory obligations; ongoing monitoring; considering whether any advice is being provided and if so, ensure that a suitability determination is conducted; and implementing a supervisory process for review of DEP content. Clients should also be able to easily control and manage their notifications and be provided with all transaction charges before and after each trade. Please contact us if you have any questions about the use of DEPs and the implementation of policies and procedures with respect to these tools.

8. From tree to table: OSC’s draft statement of priorities

The Ontario Securities Commission (OSC) has published its latest draft Statement of Priorities for 2026-2027, which highlights the areas it will focus on in its upcoming fiscal year – each of which are tied to six goals in the OSC’s previously published strategic plan.

As examples of proposed action items, under the goal related to quickly delivering effective regulatory actions, the OSC will look at modernizing regulation in the face of increased use of artificial intelligence, and work to align regulation in areas like disclosure of the use of AI systems and governance practices. The OSC will also study the impact of quantum computing on capital markets.

Under the goal of dynamically right-sizing regulation, the OSC will continue to develop a proof of concept for a machine-readable data set of its regulatory framework. Other related priorities include delegating additional registration responsibilities to CIRO, conducting direct examinations of CIRO member firms and republishing amendments to an access model specific to investment fund issuers for comment.

Related to the goal of fostering conditions for capital formation and innovation, the OSC intends to report on priority growth sectors and make recommendations about addressing financing gaps, as well as to conduct a consultation on modernizing regulation of non-investment fund issuers, including shortening the length of certain hold periods.

The OSC is continuing a number of projects, including evaluating the client-focused reforms to see if the current know-your-product requirements are contributing to limited product shelves.

The comment period ends on January 12, 2026.

In Brief

Tapping into trouble: CSA Phase 2 CFR Sweep Results

The Canadian Securities Administrators (CSA) and the Canadian Investment Regulatory Organization (CIRO) have released their much-anticipated Client Focused Reforms (CFR) Phase 2 Sweep Report, which provides additional and, in some cases, expanded, guidance with respect to KYC, KYP and suitability obligations. This joint report summarizes the CSA and CIRO findings on their sweep and provides actionable recommendations on core registrant obligations, including product due diligence, assessing risk and the process for recommending alternative investment products.

As this guidance will impact all registered firms, BLG has released a separate Insight summarizing the material features of the guidance and referencing the webinar BLG will be hosting to provide additional insights and views on the report, entitled “Under the bright lights: CSA & CIRO illuminate enhanced expectations in phase 2 client-focused reform sweep”

We can assist with updating your policies and procedures, reviewing client facing documentation and providing training to your employees. Please contact us with any questions on this report.

Maple mixology: CSA report on hybrid investors

The Canadian Securities Administrators (CSA) have been releasing a number of research reports providing background information on the nature of advice in Canada. On October 2, the CSA released a report on hybrid investing, the findings of which may be of interest to registered advisers. The two research projects described in the report include results from an online survey of approximately 600 hybrid self-directed investors, and four focus groups among hybrid self-directed investors who identify themselves as having high-risk investing attitude/behaviours.

The study defines “hybrid investors” as those who invest on their own, but who also have a separate portfolio managed by a financial advisor. One in eight Canadians are hybrid investors, and, as compared to the general population they are younger, male, and hold a university degree. Of note, 68% of hybrid investors intend to maintain this approach to investing going forward. Hybrids investors tend to use their DIY accounts for more speculative investing, such as trading frequently (40% traded at least once a week), checking frequently (74% checked at least once a week), and owning speculative investment products. The goals of additional income or “having fun” was more likely for holders of these DIY accounts.

Hybrid investors, according to the study, are willing to take on moderate or significant levels of risk within their investments (84% of investors), but those who work with an advisor on their financial plan generally engage in less speculative investment behaviour in their own DIY accounts. Somewhat concerning was the finding that hybrid investors with a higher risk tolerance had limited awareness of investment fraud.

Studies such as these can help the CSA better understand the way Canadians invest today and whether any regulatory or other outreach actions are warranted.

The sap’s running dry: CSA reconsiders role of EMDs in selling groups

In late November, seven Canadian securities regulators published CSA Multilateral Staff Notice 31-367 Notice and Consultation Regarding CSA Coordinated Blanket Order 31-930 Exemption to Allow Exempt Market Dealer Participation in Selling Groups in Offerings of Securities Under a Prospectus (Staff Notice) that was put into place for a time-limited period in late June 2024. The exemption had – on a very limited use basis - allowed EMDs to assist start-ups and small to medium sized businesses to raise capital. Only three EMDs reported a change in business activity indicating that they intended to rely on the Blanket Order, and of those, only two participated in selling groups in prospectus offerings. As a result, the exemption will not be extended past December 20, 2025, when it expires. In the Staff Notice, numerous questions about the conditions of the exemption are posed, and additional feedback is sought to help inform whether a revised exemption should be published in future. Comments will be accepted until January 26, 2026.

Maple rule reduction: CIRO rule consolidation project update

The Canadian Investment Regulatory Organization (CIRO) announced earlier in December that the Investment Dealer and Partially Consolidated (IDPC) Rules and Mutual Fund Dealer (MFD) Rules, which are being consolidated into a harmonized rulebook (the CIRO Rules) will be republished for comment in their entirety in February 2026. One of the primary objectives of the consolidation project is to minimize regulatory arbitrage between investment dealers and mutual fund dealers, and to ensure that similar dealer activities are regulated in a like manner. A number of amendments will be included in the CIRO Rules, including the investment dealer proficiency model and enhanced cost reporting, while other policy projects, such as the modernization of requirements for account transfers and bulk account movements, will continue separately as they await approval.

The consolidated CIRO Rules will be open for comment for a period of 120 days, to allow dealers time to consider the material in its entirety. A detailed implementation guide will be included in the request for comments. Any guidance notes needing material changes to align with the new rules will be published for comment once the CIRO Rules are finalized.

OSC drips update on OLTF proposals

Late in November, the Ontario Securities Commission (OSC) released OSC Staff Notice 81-740 Update on Long-Term Asset Fund Project which discussed key themes and questions from industry stakeholders on OSC Staff Notice 81-738 Next Steps Following OSC Consultation Paper 81-737 Opportunity to Improve Retail Investor Access to Long-Term Assets through Investment Fund Product Structures. Staff at the OSC is continuing to speak to stakeholders on topics such as:

  • higher illiquid asset limits under National Instrument 81-102 Investment Funds;
  • adapting the interval fund structure;
  • adapting the Ontario Long Term Fund (OLTF) structure; and
  • allowing non-accredited investors to hold qualified private funds in an RRSP.

Staff also confirmed that not every element that was in the original proposal in the OLTF consultation paper will be required for any exemptive relief decision that could be granted under the long-term asset fund project. An example provided was that redemption limits might not be appropriate for conventional mutual funds seeking to increase their percentage of illiquid assets, and that the cornerstone investor requirement may not be required for every OLTF structure.

Staff also used the notice to request more information from private fund managers with funds that hold illiquid assets so the regulator can better understand if there may be a retail market for those funds. Staff will work with parties interested in seeking relief to permit product launches as part of the long-term asset fund project.

Two taps, one pour - CSA tool updates

The Canadian Securities Administrators (CSA) have made it easier to provide comments on regulatory proposals through a new online tool on a dedicated portion of the CSA’s website. Through this site, stakeholders can provide feedback once through the tool instead of having to send responses to more than one jurisdiction. In addition, the tool incorporates an online Q&A format, although submissions can still be made via letter by uploading the documentation to the tool.

FINTRAC refinements for resilience

As always, registrants subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Act) should review the federal Minister of Finance’s updated directives, including the recent Ministerial Directive on the Islamic Republic of Iran, effective as of November 15, 2025. The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) has issued guidance related to this directive, which includes the following:

  • Affected registrants must report every financial transaction to or from Iran, regardless of amount and those transactions must be treated as high-risk transactions;
  • The identity of every client must be identified if they request or benefit from such a transaction;
  • Registrants must exercise customer due diligence with respect to such transactions, and look for risks of a sanction’s evasion offence (e.g. the source of the funds, purpose of the transaction and ascertaining the beneficial ownership/control of any entity requesting or benefiting from the transaction); and
  • Keep records of any such transaction, regardless of amount.

It is important that your firm’s policies and procedures:

  • Include information on how the firm becomes aware of ministerial directives and how it will respond;
  • Describe how the firm will determine that a transaction originates from or is bound for Iran (or any other country that is the subject of a similar Ministerial Directive); and
  • The specific mitigation measures the firm will take upon making this determination.

FINTRAC considers that failure to comply with measures outlined in a ministerial directive is a very serious offence and failure to comply may result in a penalty in accordance with the penalty regulations related to the Act.