banner banner

Cash Transactions and Recordkeeping Requirements and Client Identification and Verification Rules Amendments – Administrative Penalties

Benchers have approved amendments to Rules 15 and 16 to provide for administrative monetary penalties to address breaches of Anti-Money Laundering and Terrorist Financing (AMLTF) Rules. The revisions are designed to emphasize lawyers’ obligations with regard to AMLTF and provide appropriate and proportionate sanctions for violations. Administrative penalties of up to $2,500 in the first instance of non-compliance and up to $5,000 for subsequent instances may be assessed. The Law Society is consistently seeing client files where members have not fully satisfied their regulatory requirements under the AMLTF Rules. These Rules underpin our efforts to combat money laundering and terrorist financing activities in the legal profession as lawyers’ trust accounts may be targeted and utilized as a vehicle to commit criminal activities.

These amendments will be effective June 30, 2024. The amended Rules can be viewed here.

Members can find helpful practice resources to assist in understanding their responsibilities, on our website and on the Federation of Law Societies of Canada website.

The Federation of Law Societies of Canada has also developed a five-module program “Anti-Money Laundering and Terrorist Financing in the Canadian Legal Profession” which can be found here. It is a complimentary course and is eligible for CPD credits once completed.

If you have any questions related to these amendments, please contact Brenda B. Grimes, KC, Executive Director, at, or Nicole Miller, Trust Compliance Auditor, at


Posted: May 1, 2024