What is a Third Party?

What “third party involvement” means under FINTRAC

• Definition: A “third party” is the person or entity who is really directing the transaction, even if someone else appears on the paperwork.
  
  

• FINTRAC requires you to ask clients “Are you acting on behalf of a third party?” and record the answer.
  
  

• Examples of true third parties:
  
  

  • A parent using their child’s name to buy a property.
    
    

  • A company director using a numbered company to conceal the real beneficial owner.
    
    

  • A criminal using a proxy to place funds into real estate.
    
    

It’s about who’s behind the money and decision-making — not just who shows up to sign.