Does This Apply to Your Dealership?

Yes, if your dealership:

• Provides in-house financing or leasing
• Facilitates loans through third-party lenders or brokers
• Offers buy-here-pay-here or similar programs

Key Compliance Requirements for Dealerships

To meet FINTRAC’s AML standards, your dealership must implement a five-part compliance program:

1. Appoint a Compliance Officer

Designate someone within your organization to oversee AML efforts. This individual will:

• Lead your dealership’s AML strategy
• Monitor changes in regulations
• Coordinate employee training
• Act as your contact for FINTRAC inquiries or audits
  
  

If you’re unsure who should take on this role, we can help you assess your options.

2. Conduct a Risk Assessment
   
   

Dealerships must assess and document potential risks associated with money laundering. This includes:

• Identifying services or customer types that pose higher risk (e.g., large cash transactions, third-party payments)
• Evaluating vulnerabilities in your current processes
• Using the results to guide your compliance strategy
  
  

A thorough risk assessment helps prioritize resources and protect your dealership.

3. Develop Written Policies and Procedures
   
   

Your policies must clearly explain how your dealership will:

• Identify and verify the identity of customers, including beneficial ownership
• Monitor transactions for suspicious activity
• Report required information to FINTRAC
• Maintain proper records for audits
  
  

These should be integrated into your financial policies and shared with all relevant team members.

4. Train Your Staff
   
   

All employees involved in financing or leasing must be trained to:

• Understand AML regulations and their reporting duties
• Identify red flags or suspicious behaviors
• Know when and how to escalate concerns
  
  

Training must be completed:

• Annually for all staff
• Within 30 days for all new hires
  
  

If you need training added to your dealership’s learning platform, we can help with that.

5. Monitor, Maintain, and Review
   
   

Your AML program is not a one-time setup. You must:

• Review and update it every two years
• Monitor for effectiveness and adjust as needed
• Conduct internal or third-party audits
  
  

This helps demonstrate that your dealership is taking compliance seriously and can adapt to changes in the law.

What You’ll Need to Report

Your dealership is now required to report the following to FINTRAC:

• Large Cash Transaction Reports (LCTRs): For cash payments over $10,000
• Suspicious Transaction Reports (STRs): Even if the transaction doesn’t proceed
• Terrorist Property Reports: If applicable
  
  

You must also keep detailed records on:

• Identity verification
• Business relationships and beneficial ownership
• All relevant transactions and financial activity
  
  

Want Help with Training?

We’re currently preparing a FINTRAC-compliant training module designed specifically for dealerships. It will cover everything your team needs to know, with the flexibility to add it to your existing learning environment.

To be notified when the training is ready or to request it for your team, join the waitlist or send your questions to:

📧 hr@drivehris.com

We’ll make sure you’re the first to know once the course is live.