GEARING UP FOR FINTRAC

With enforcement expected to ramp up on April 1, 2026, the time was right to introduce the resources we have created for UCDA members.

Here you will find guidance and links to useful information and templates.

Webinar

The UCDA and KPMG partnered to create a unique FINTRAC webinar designed just for dealers.

Just log in to your member account and we have a recorded version there:

https://ucdasearches.com/fintrac/

One on One Training

If you are interested in more one-on-one training for your dealership, which does cost some money, we have that option ready for you with KPMG as well. Just call us and ask about it.

As a member of the UCDA you are well positioned to be ready for FINTRAC, take advantage of another benefit of UCDA membership and don’t be caught unaware and unprepared.

Templates and Guides

FINTRAC & AML Compliance

UCDA Member Resources for Dealers Who Finance or Lease Vehicles

Ontario motor vehicle dealers who provide financing or leasing in their own name have obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC guidance.

To support members, UCDA has developed two core AML compliance resources. 

You can request copies of the documents at the bottom of the page.

1. AML Compliance Policy & Procedure Guide (Template)

This document is a customizable policy template for dealerships that offer financing and/or leasing.

It provides structured policy language covering:

• Governance and oversight

• Risk assessment methodology

• Client identification (KYC)

• Client risk rating

• Enhanced due diligence

• Watch list and PEP screening

• Ongoing monitoring

• FINTRAC reporting (STR, LCTR, EFTR)

• Record keeping

• Training

• Independent testing

This template must be customized to your dealership’s size, structure, and operations. Yellow-highlighted sections indicate where dealership-specific information must be inserted.

Important:
This document is not legal advice. It must be tailored to your business model and approved by senior management.

2. AML Compliance Program Guidance Document

This document explains how to build and operationalize your AML Compliance Program.

It breaks down the 12 required components of an AML program into practical steps, including:

• Appointing a Compliance Officer

• Drafting policies and procedures

• Conducting a risk assessment

• Implementing KYC and due diligence

• Establishing reporting protocols

• Training staff

• Monitoring transactions

• Performing a two-year effectiveness review

• Maintaining required records

This guidance document is designed to help dealerships:

• Identify gaps in current practices

• Develop an implementation plan

• Understand size and complexity considerations

• Prepare for a FINTRAC examination

How to Use These Documents

UCDA recommends the following approach:

1. Read the Guidance Document first
   Understand the structure and regulatory expectations.

2. Conduct your internal risk assessment
   Identify your dealership’s specific risk exposure.

3. Customize the Policy & Procedure Template
   Insert your dealership’s:

   • Legal name

   • Governance structure

   • Risk appetite

   • Monitoring approach

   • Reporting process

   • Record keeping method

4. Train staff and document completion
   All relevant staff must understand their responsibilities.

5. Review your program regularly
   At minimum, every two years.

Important Reminder

If your dealership:

• Only arranges third-party financing, and

• Does not finance or lease vehicles in its own name

FINTRAC obligations may not apply in the same way.

If your dealership:

• Provides in-house financing, or

• Leases vehicles directly

You are likely considered a reporting entity and must have a compliant AML program in place.

Member Responsibility

Each dealership is responsible for:

• Determining whether FINTRAC applies to its operations

• Ensuring its AML program meets regulatory requirements

• Maintaining documentation to support compliance

• Filing required reports within prescribed timelines

Failure to comply may result in:

• Administrative monetary penalties

• Public naming

• Regulatory action

Need Assistance?

Members who require support implementing or customizing these documents should seek:

• Qualified legal advice

• Independent compliance review

• AML specialist consultation (if appropriate)