What REALTORS® Should Know About the Iran Ministerial Directive
Stay current with your FINTRAC obligations.
On November 17, 2025, the Minister of Finance issued a new Ministerial Directive under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“FINTRAC Regime”) applicable to the real estate sector. The Ministerial Directive requires all reporting entities (including brokers and sales representatives) to treat all transactions originating from, or destined to, Iran as high risk.
It's the responsibility of each brokerage to:
- treat every purchase or sale transaction originating from or bound for Iran, regardless of its amount, as a high-risk transaction;
- verify the identity of any person or entity requesting or benefiting from such a transaction, regardless of its amount;
- exercise customer due diligence in relation to such a transaction, with particular attention to the risk of a sanctions evasion offence, including by ascertaining the source of funds or virtual currency, the purpose of the transaction and the beneficial ownership or control of any entity requesting or benefiting from the transaction;
- keep and retain a record of such a transaction, regardless of its amount; and
- report all such transactions to FINTRAC.
Note that separate Ministerial Directives, applicable to North Korea and Russia, and which has been in force for several years, continue to apply.
For more information on the Ministerial Directive see: https://fintrac-canafe.canada.ca/obligations/dir-iri-eng.
If you have questions about FINTRAC, please refer to the resources available on member.CREA.ca.
The article above is for information purposes and is not legal advice or a substitute for legal counsel.
