When Bill C-12 came into force on March 26, every summary led with the number: penalty ceilings up roughly 40 times, to $20 million for a very serious violation. That's real, and our penalties guide walks through it. But FINTRAC's own implementation page lists two other changes from the same Act that most dealerships haven't registered at all. Neither is about the size of the fine. Both are about what happens before and after an examination.

1. Universal enrolment: FINTRAC will know you exist

Until now, only money services businesses had to register with FINTRAC. Everyone else, including the financing and leasing entities brought in on April 1, 2025, was simply obligated, and FINTRAC found you when it found you. That's why so many dealerships assumed, reasonably, that they were invisible.

Bill C-12 ends that. Every reporting entity except an already-registered MSB will have to enrol with FINTRAC, tell it about any change within 30 days, and renew. FINTRAC will keep a roll of enrolled entities and make identifying information from it public. There's a full application, renewal, change-of-information and revocation process behind it, with appeal rights to the Federal Court.

None of it is switched on yet. The provisions are law, but they come into force on a date set by order in council, once the regulations land. Nobody outside Ottawa knows the date, and we won't guess at one.

Three things follow anyway. Enrolment turns "FINTRAC might not know about us" into a filing you sign. The roll is a list of who's obligated, which is also a list of who can be examined. And because it's public, a lender, an auction house or a floor-plan provider will be able to look you up. Being absent from a public register of obligated businesses isn't the quiet position it sounds like.

The practical read: the day enrolment opens, you'll describe your business to FINTRAC in its own categories. If you already know you're a financing or leasing entity, have a named compliance officer and can point to a program, it's a form. If you're still working out whether you're covered, you'll be doing that analysis on a clock. The scope test is the place to settle it now.

2. Compliance agreements and orders: what a failed exam leads to

The second change adds two rungs to the enforcement ladder, and they're the ones a small business should worry about.

Before C-12, examination findings led to a penalty, and the penalty was more or less the end of it. Now, under the new section 73.16, FINTRAC must require a compliance agreement from anyone found to have committed a prescribed violation: a written undertaking naming what went wrong, the steps to fix it, and a deadline. It used to be optional. It isn't anymore.

Refuse one, or miss the deadline, and you're into compliance orders. Contravening an order is its own new violation, carrying the greater of $30 million or 3 percent of gross global revenue for an entity. Orders get published as soon as feasible, and FINTRAC's Director can publish reasons alongside them.

Read that sequence from a dealer principal's chair. The exposure isn't the first penalty. It's what the first penalty commits you to: a promise, on paper, that your program will be built and working by a date FINTRAC accepts. Miss that date and you don't get a second letter. You get a public order with your name on it and a much bigger number behind it.

Two smaller changes point the same way. Your compliance program now has to be reasonably designed, risk-based and effective, where the old standard was a program intended to ensure compliance. That lets an examiner ask whether your policies work, not just whether they exist. And FINTRAC now weighs ability to pay when it sets a penalty. That sounds like relief for a small business, and it also means the framework was built to reach businesses your size, not just the banks the old ceilings were written for.

Is any of this theory yet?

Fair question. FINTRAC's public notice of penalties shows seven published so far in 2026, most recently on July 9: two real estate brokerages, two casino-sector entities, a money services business, a jeweller and a bank, from $24,750 to $693,742.50. None against a financing or leasing entity, and none under the new ceilings, which only bite on violations after March 26.

So the honest picture: the tools exist, the first sectors examined under them are the older ones, and financing and leasing is about a year into the examinations FINTRAC said would follow its outreach year. The detailed penalty policy is still being rewritten, and FINTRAC says guidance on compliance agreements and orders arrives with it.

The test to run on yourself this week

Pretend enrolment opened this morning and the form asks three questions: are you a financing or leasing entity under the Act, who is your compliance officer, and when was your risk assessment last dated? Write the answers down. If any one of them takes more than a minute, or comes out as a hunch rather than a document, that's your gap.

Then do the harder version, because the enforcement ladder starts where the examination ends. Open the five program elements and check that each exists as a record, not an intention: a compliance officer named in writing, dated policies, a dated risk assessment, training with attendance, and a plan for the first effectiveness review. Then read the examination guide with the new ladder in mind. The document request is the moment that decides whether you ever see a compliance agreement at all.

Our free 12-item readiness checklist will tell you in two minutes which of those you'd struggle to produce today.

Sources: FINTRAC, Implementation of legislative amendments; FINTRAC, Changes to the administrative monetary penalties framework; FINTRAC, Public notice of administrative monetary penalties, figures checked August 15, 2026. Bill C-12, Strengthening Canada's Immigration System and Borders Act, received Royal Assent March 26, 2026 (Royal Assent text, PCMLTFA amendments including new sections 11.4014, 11.4015 and 73.16); enrolment and penalty specifics cross-checked against published analyses by DLA Piper, BLG and McCarthy Tétrault. Universal enrolment is not in force and its regulations are pending; verify the current status against FINTRAC's site or counsel before relying on this summary. General information, not legal advice.