No. Basically, when financial institutions or any of the reporting entities identified in section 6 as having a duty to determine if they're in the possession or control of any of the property of a listed person, they have a corresponding obligation as part of their ongoing reporting to the regulator to comply with those provisions. The criminal penalties that exist under the act are with respect to the freezing of the funds.
The financial institutions have a duty under the law. They have an obligation to freeze those funds, and a failure to comply with those orders could result in a criminal penalty, depending on the circumstances of that behaviour.
The requirement to report is part of the regulatory oversight set out as the obligation, the ongoing duty, to determine whether they have this property. It's part of the determination of whether they're freezing the property.
There is a connection between the different actions, in the sense that the financial institutions must be freezing these funds if they have any in their possession or control. It's part of that obligation, but the duty to report does not come with criminal penalties if there's a failure to do that.