Many Alberta homebuilders are reporting entities under Canada's anti-money laundering law and have obligations to FINTRAC, the federal financial intelligence agency. A builder that has sold five or more new houses or condominium units to the public in any calendar year since 2007 is generally a "real estate developer" for FINTRAC purposes, and must identify its buyers, keep specific records, determine third-party involvement, and maintain a compliance program. These steps belong in the buyer file from the first deposit, not at possession.
This article is an operational summary, not legal advice. Confirm your obligations with your compliance officer, your lawyer, and FINTRAC guidance.
Key takeaways
- FINTRAC treats a business as a real estate developer if, in any calendar year since 2007, it sold to the public five or more new houses or condo units, or certain new multi-unit or commercial buildings.
- Once the threshold is met, the compliance program obligation continues as long as the business develops real estate, even in years with lower volume.
- Core obligations include client identification, a client information record, third-party determination, politically exposed person checks, and reporting of large cash transactions of $10,000 or more.
- FINTRAC updated guidance on beneficial ownership in October 2025, which matters when the buyer is a corporation or trust.
- The practical risk for builders is not intent; it is incomplete records scattered across sales, admin, and lawyers.
Who counts as a real estate developer under FINTRAC?
FINTRAC defines a real estate developer as anyone who, in any calendar year after 2007, has sold to the public, other than in the capacity of a real estate agent or broker:
- five or more new houses or condominium units,
- one or more new commercial or industrial buildings,
- one or more new multi-unit residential buildings each containing five or more units, or
- two or more new multi-unit residential buildings that together contain five or more units.
For most production builders and condo developers in Calgary and Edmonton, that threshold has long been met (CHBA overview).
What must a builder do on each sale?
When a developer sells a new home to the public, the obligations generally include:
- Identify the client using a method FINTRAC accepts, and record how it was done.
- Keep a client information record with the details FINTRAC requires.
- Determine whether a third party is involved, meaning someone directing the purchase, and record that determination.
- Determine whether the buyer is a politically exposed person, a head of an international organization, or a family member or close associate of one.
- For corporations and trusts, collect beneficial ownership information and take reasonable measures to confirm it.
- If $10,000 or more in cash is received in one transaction or within 24 hours, keep a large cash transaction record, identify the person handing over the cash, and report it to FINTRAC.
Separately, every reporting entity must have a compliance program: a named compliance officer, written policies and procedures, a risk assessment, ongoing training, and a periodic effectiveness review.
Why do these records go missing?
In a builder, the information for one buyer is often split between:
- the sales team, who met the buyer and saw identification,
- sales administration, who prepared the agreement,
- finance, who received the deposit, and
- the lawyers, who handle the transfer.
Nobody is wrong; the record is just incomplete in every single place. Corporate buyers, co-buyers added later, and international buyers who sign remotely make gaps more likely. See managing international preconstruction buyers.
How to build FINTRAC records into the buyer file
Treat the FINTRAC record as part of document readiness, with the same discipline as the purchase agreement:
| Item | When | Owner | Evidence |
|---|---|---|---|
| Client identification | At or before the first deposit | Sales or sales administration | Method used, document details, date |
| Client information record | At agreement | Sales administration | Completed record |
| Third-party determination | At agreement | Sales administration | Recorded determination |
| PEP and HIO determination | At agreement | Sales administration | Recorded determination |
| Beneficial ownership (entities) | At agreement | Sales administration with legal | Ownership information and confirmation steps |
| Large cash transaction | When cash of $10,000 or more is received | Finance | Record and report |
Then check completeness on a cadence: every firm buyer should have a complete FINTRAC record before the file moves to possession readiness. For the broader document set, see the document collection readiness matrix.
Which cases need human review and escalation?
Route these to your compliance officer rather than resolving them in the workflow:
- The buyer cannot or will not provide identification in an accepted form
- A third party appears to be directing or funding the purchase
- The buyer, or someone connected to them, may be a politically exposed person
- Beneficial ownership of a corporate or trust buyer is unclear
- Unusual payment patterns, such as several deposits from unrelated sources
- Anything that may require a suspicious transaction report
Software can make sure the questions are asked and the evidence is attached. Whether a transaction is suspicious, and what to report, is a decision for the compliance officer.
Where Asterisko fits
Asterisko keeps a document-readiness record for each buyer and home, built from the CRM and ERP a builder already uses. It can request missing identification and record fields through approved messages, show which files are incomplete, and escalate exceptions to the compliance officer. It is not a FINTRAC reporting tool and does not decide whether a transaction is suspicious; those obligations stay with your compliance program.
Explore the document-readiness workflow.
Sources
- FINTRAC, Notices and advisories for reporting entities
- Canadian Home Builders' Association, Anti-money laundering compliance (FINTRAC)
- Osler, Real estate brokers, sales representatives and developers
