Canada’s new beneficial ownership registry is slated to arrive in 2023 but the details remain uncertain. One way for corporations to prepare for these changes is by looking at how similar registries operate in other jurisdictions.
Canada has been criticized for having a relatively weak AML regime. Experts indicate that casinos, real estate, and shell companies in particular increase the risk of money laundering in Canada, with limited oversight of beneficial ownership being a major contributor.
Globally, Canada’s beneficial ownership standards have been described as comparable with those of nations on AML and tax blacklists maintained by the OECD and G20. It is no surprise that addressing this AML vulnerability is of paramount importance for the federal government.
The 2022 federal budget clearly states an intention to model Canada’s beneficial ownership registry of real property along the lines of those implemented in other countries, specifically citing the U.K.’s practices.
Canada’s public and searchable beneficial ownership registry may function similar to that of the U.K., and perhaps require additional reporting requirements. This would no doubt be an improvement, but may not solve Canada’s widespread financial crime problem. Existing public registries have been criticized for containing vast amounts of unreliable data, difficulty or inability to enforce false declarations, and for not being as effective in reducing overall financial crime.
Yet knowing the shortcomings of such programs, corporations in Canada would do well to pay attention to how corporations in jurisdictions with more advanced beneficial ownership registries adapt to similar weaknesses in their registry system. As Canada plays “follow the leader” in AML regulation, corporations in Canada may benefit by considering how their policies may align with other existing regimes, such as the U.K.
 See https://cullencommission.ca/. See also https://globalnews.ca/news/8277350/bc-casinos-money-laundering-cullen-commission-closing-arguments/.
 Jason Sharman, Report to the Cullen Commission “Money Laundering and Foreign Corruption Proceeds in British Columbia: A Comparative International Policy Assessment” at p.3, online: < https://ag-pssg-sharedservices-ex.objectstore.gov.bc.ca/ag-pssg-cc-exh-prod-bkt-ex/959%20-%20Money%20Laundering%20and%20Foreign%20Corruption%20Proceeds%20in%20British%20Columbia%20A%20Comparative%20International%20Policy%20Assessment%20by%20Jason%20Sharman.pdf> [Sharman].
 Sharman at p 7.
 Sharman at p 142.
 Sharman, at p 10.