Draft guidance: Reporting suspicious transactions to FINTRAC

Please note this a draft document and, as such, may be subject to minor changes.

Overview

This guidance comes into effect on September **, 2023.

Suspicious transaction reporting requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations apply to all reporting entity sectors.

Specifically, all reporting entities and their employees must report suspicious transactions. If you are an employee who works for a reporting entity and your employer is actively reporting suspicious transactions, we do not require duplicate reporting. An employee is only expected to report suspicious transactions to FINTRAC in the rare instances where they believe that their employer has not submitted a suspicious transaction report (STR) as required by the PCMLTFA and associated Regulations. To submit an STR in this scenario, the employee may use the paper report form as explained in section 4 below.

A service provider can submit and correct an STR on your behalf. However, as the reporting entity, you are ultimately responsible for meeting the requirements under the PCMLTFA and associated Regulations, even if a service provider is reporting on your behalf. This legal responsibility cannot be delegated.

No person or entity will be prosecuted for sending an STR in good faith or for providing FINTRAC with information about suspicions of money laundering or terrorist financing.^{Footnote 1}

You are not allowed to inform anyone, including the client, of the contents of an STR, or that you have made or will make such a report, if the intent is to prejudice a criminal investigation. This applies whether such an investigation has begun or not.^{Footnote 2} It is important to not tip off your client about the fact that you are making an STR—therefore, you should not be requesting information that you would not normally request during a transaction.

It is recommended that this guidance be read in conjunction with the Money laundering and terrorist financing indicators (ML/TF indicators) guidance.

FINTRAC uses a variety of assessment methods to ensure that you are detecting suspicious transactions and submitting complete reports in a timely manner. For more information on how FINTRAC assesses STRs, see FINTRAC's assessment manual.

Who is this guidance for

All reporting entity sectors

In this guidance

What is an STR?
What are reasonable grounds to suspect (RGS)?
When must I submit an STR?
How do I submit STRs?
What are the main considerations when submitting an STR?
Do I have other requirements associated with suspicious transactions?
Are there any exclusions to reporting suspicious transactions?
Do I need to continue reporting suspicious transactions after I submit an STR?
What are FINTRAC's expectations for completing an STR?
What are common STR deficiencies to avoid?

You will also find field instructions to complete an STR in Annex 1 and scenario examples in Annex 2.

Please note: The examples and scenarios used in this guidance are intended to help explain your reporting requirements. All details described in these examples and scenarios such as names of persons, names of entities, addresses, phone numbers and email addresses are solely fictitious.

If you have questions on your suspicious transaction reporting requirements, please contact FINTRAC by email at guidelines-lignesdirectrices@fintrac-canafe.gc.ca.

**Note: Throughout this guidance, references to dollar amounts (such as $10,000) are in Canadian dollars (CAD) unless otherwise specified.

**Note: All references to transactions should be read to include both attempted transactions and completed transactions. All references to the commission of an ML/TF offence also include the attempted commission of an ML/TF offence.

1. What is an STR?

A suspicious transaction report is a type of report that you must submit to FINTRAC when a financial transaction occurs, or is attempted, in the course of your activities and there are reasonable grounds to suspect that the transaction is related to the commission or the attempted commission of a money laundering offence or a terrorist activity financing offence (ML/TF offence).^{Footnote 3}

The STR is one of the most valuable and unique report types submitted to FINTRAC. In addition to the prescribed information, STRs allow for an expansion on the descriptive details surrounding a transaction that is derived from your assessment of what you are seeing through your business interactions and activities. Information, such as nicknames, secondary names, beneficial ownership information, IP addresses, account numbers, email addresses, virtual currency transaction addresses and their details, details of purchases or e-transfers, locations, relationships, and background information are all details that FINTRAC uses in its analysis and production of financial intelligence disclosures.

Because of the importance of FINTRAC's financial intelligence to the overall safety and security of Canadians and Canada's financial system, FINTRAC reviews and assesses every STR it receives. When warranted, such as in the case of STRs related to threats to the security of Canada, FINTRAC expedites its analysis in order to disclose financial intelligence to law enforcement and other intelligence partners within 24 hours.

2. What are reasonable grounds to suspect (RGS)?

Reasonable grounds to suspect (RGS) is the required threshold to submit an STR to FINTRAC and is a step above simple suspicion, meaning that there is a possibility that an ML/TF offence has occurred. You do not have to verify the facts, context or ML/TF indicators that led to your suspicion, nor do you have to prove that an ML/TF offence has occurred in order to reach RGS. Your suspicion must be reasonable and therefore, not biased or prejudiced.

Reaching RGS means that you considered the facts, context and ML/TF indicators related to a financial transaction and, after having reviewed this information, you concluded that there are RGS that this particular financial transaction is related to the commission of an ML/TF offence. It also means that you are able to demonstrate and articulate your suspicion of ML/TF in such a way that another individual with similar knowledge, experience, or training would likely reach the same conclusion based on a review of the same information.

Many factors will support your assessment and conclusion that an ML/TF offence has possibly occurred. These factors, along with an explanation of your assessment should be included in the narrative section of the STR—specifically, the Details of suspicion section.

The RGS threshold may be better understood when you have an understanding of other thresholds such as simple suspicion and reasonable grounds to believe.

Simple suspicion is a lower threshold than RGS and is synonymous with a "gut feeling" or "hunch". In other words, simple suspicion means that you have a feeling that something is unusual or suspicious, but do not have any facts, context or ML/TF indicators to support that feeling or to reasonably conclude that an ML/TF offence has occurred. Simple suspicion could prompt you to assess related transactions to see if there is any additional information that would support or confirm your suspicion.

Reasonable grounds to believe is a higher threshold than RGS and is beyond what is required to submit an STR. Reasonable grounds to believe means that there are verified facts that support the probability that an ML/TF offence has occurred. In other words, there is enough evidence to support a reasonable and trained person to believe, not just suspect, that an ML/TF offence has occurred. For example, law enforcement must reach reasonable grounds to believe that criminal activity has occurred before they can obtain judicial authorizations, such as a production order.

If you are in receipt of a production order from law enforcement, you must perform an assessment of the facts, context, and ML/TF indicators to determine whether you have RGS that a particular transaction is related to the commission of an ML/TF offence.

If you identify a transaction whereby you reach reasonable grounds to believe that an ML/TF offence has occurred, you must begin an assessment of the related transactions immediately as you have surpassed the RGS threshold.

If assessed by FINTRAC and there are reasonable grounds to believe that a transaction is related to the commission of an ML/TF offence, and you have not begun an assessment of the facts, context or ML/TF indicators, you may be cited for not reporting an STR.

In situations involving time-sensitive information, such as suspected terrorist financing and threats to national security, you are encouraged, as a best practice, to expedite the submission of your STRs. We recommend that this be included in your compliance policies and procedures.

See diagram 1: Threshold for suspicion for an overview of the different thresholds.

Diagram 1: Threshold for suspicion

3. When must I submit an STR?

You must submit the STR to FINTRAC as soon as practicable after you have taken measures that enable you to establish that there are reasonable grounds to suspect that the transaction or attempted transaction is related to the commission of a ML/TF offence.^{Footnote 4}

What measures can I take to establish RGS?

The measures you can take to establish that there are RGS that the transaction or attempted transaction is related to the commission of a ML/TF offence include the following:

screening for and identifying suspicious transactions;
assessing the facts and context surrounding the suspicious transaction;
linking ML/TF indicators to your assessment of the facts and context; and
explaining your grounds for suspicion in an STR, where you articulate how the facts, context and ML/TF indicators allowed you to reach your grounds for suspicion.

Your measures must be described in your compliance policies and procedures.

What is a fact?

A fact, for the purpose of completing an STR, is defined as an event, action, occurrence or element that exists or is known to have happened or existed — it cannot be an opinion. For example, facts about a transaction could include the date, time, location, amount or type. Facts known to a reporting entity could include account details, particular business lines, a client's financial history or information about a person or entity (for example, that the person has been convicted of a designated offence or is the subject of a production order, or that an entity is being investigated for fraud or any other indictable offence).

What is context?

Context, for the purpose of completing an STR, is defined as information that clarifies the circumstances or explains a situation or transaction. This type of information is essential to differentiate between what may be suspicious and what may be reasonable in a given scenario.

You may observe or understand the context of a transaction through:

a general awareness of the events occurring in a person or entity's business environment or community;
your knowledge of the typical financial activities found within your business;
regular know your client (KYC) activities (for example, verifying the identity of persons and entities, their occupation or business, how they generate their wealth, their typical or expected transactional behaviours);
the information obtained through the application of your risk assessment; and
illustrative client details (for example, the background, behaviour and actions of your client).

A transaction may not appear suspicious in and of itself. However, a review of additional contextual elements surrounding the transaction may create suspicion. Conversely, the context of a particular transaction, which may have seemed unusual or suspicious from the onset, could lead you to reassess your client's current and past transactions and conclude that they are reasonable in that circumstance.

Your suspicion of ML/TF will likely materialize from your assessment of multiple elements (transactions, facts, context, and any other related information that may or may not be an indicator of ML/TF). When these elements are viewed together, they create a picture that will either support or negate your suspicion of the commission of an ML/TF offence. Below are some examples of how suspicion may arise:

A person:
- asks several questions about your reporting obligations to FINTRAC (context)
- wants to know how they can avoid their transaction being reported to FINTRAC (context)
- structures their amounts to avoid client identification or reporting thresholds (fact)
- keeps changing their explanation for conducting a transaction or knows few details about its purpose (context)
Transactions constantly being made on behalf of another person or entity:
- a client conducts a transaction while accompanied, overseen or directed by another party (fact)
- payments to or from unrelated parties (foreign or domestic) (fact)
- client appears to be or states that they are acting on behalf of another party (context)
For reporting entity sectors that deal with accounts:
A person making a deposit to a personal account, where the person:
- has an income or job that is not consistent with the deposit amounts (fact)
- keeps changing their reason for the deposit, and cannot or will not provide a reason (context)
- exhibits nervous behaviour (context)
Transactions to a business account with the following additional elements:
- deposits to the account are made by numerous parties that are not signing authorities or employees (fact)
- the account activity involves wire transfers in and out of the country (fact), which do not fit the expected pattern for that business (context)
Transactions frequently being made on behalf of another person or entity:
- multiple payments made to an account by non-account holders (fact)
- account is linked to seemingly unconnected parties (context)

What is an ML/TF indicator?

ML/TF indicators are potential red flags that can initiate suspicion and indicate that something may be unusual without a reasonable explanation. Red flags typically stem from one or more facts, behaviours, patterns or other contextual factors that identify irregularities related to a client's transactions. These often present inconsistencies with what is expected or considered normal based on the facts and context you know about your client and their transactional activities.

For more information and examples of ML/TF indicators, refer to the guidance on ML/TF indicators. FINTRAC also publishes strategic intelligence products (for example, operational alerts and briefs) that focus on the identification of ML/TF related methods, techniques, and vulnerabilities.

What is as soon as practicable?

As soon as practicable is interpreted to mean that you have completed the measures that have allowed you to determine that you reached the RGS threshold and as such the development and submission of that STR must be treated as a priority. FINTRAC expects that you are not giving unreasonable priority to other transaction monitoring tasks and may question delayed reports. The greater the delay, the greater the need for a suitable explanation. STRs can be complex, yet you must treat them as a priority and ensure they are timely; you must also complete the measures that enabled you to conclude that you have RGS the transaction is related to the commission of an ML/TF offence before you submit the report to FINTRAC.

Failing to submit an STR, or not submitting an STR in a timely manner, may directly affect FINTRAC's ability to carry out its mandate. Therefore, FINTRAC expects that when you have completed your measures and determined that you have reached RGS to suspect that a transaction is related to the commission of an ML/TF offence, you will prioritize the submission of that STR.

Criminal organizations often try to avoid the detection of ML/TF by using multiple concealment methods. Indicators of ML/TF can bring to light suspicious transactional activity, but it is your holistic assessment of facts, context and ML/TF indicators that will enable you to determine whether you have reached RGS that a transaction is related to the commission of an ML/TF offence. Indicators are also helpful to articulate your rationale for RGS in an STR. The explanation of how you reached your grounds for suspicion is extremely important for FINTRAC's development and disclosure of financial intelligence.

There is no monetary threshold associated with the reporting of a suspicious transaction and under the Canadian anti-money laundering and anti-terrorist financing (AML/ATF) regime, STRs may contain transactions that must be submitted to FINTRAC in other types of reports. For example, if a completed transaction reported in an STR involved the receipt of cash from a client of 10,000 Canadian Dollars (CAD) or more, you would also be required to report this transaction to FINTRAC in a large cash transaction report (LCTR).

4. How do I submit STRs?

You must submit STRs to FINTRAC electronically if you have the technical capabilities to do so. If you do not have the technical capabilities to report electronically, you must submit paper reports.^{Footnote 5}

Electronic reporting

You must submit STRs to FINTRAC using the following options:

FINTRAC web reporting system (FWR)

FWR (formerly F2R) allows you to submit reports electronically to FINTRAC and is geared towards reporting entities with lower reporting volumes. To access FWR, you must be enrolled for electronic reporting with FINTRAC.

Once enrolled, you can submit new reports and modify previously submitted reports. When you submit your reports, you will receive a message acknowledging receipt of your report. The message will include the date and time your report was received and the report's identification number (FINTRAC report number).

The FWR user guide, which provides detailed reporting instructions, is available to reporting entities who have enrolled in FWR. If you would like to receive the FWR user guide, please send a request to f2r@fintrac-canafe.gc.ca.

Application Programming Interfaces (API)

Paper reporting

If you do not have the technical capability to submit reports electronically, you must submit reports in paper form to FINTRAC. You can access and print the STR paper form on the reporting forms webpage, or request to have one faxed or mailed to you by calling 1-866-346-8722.

You can submit a paper STR form to FINTRAC either by

fax to 1-866-226-2346, or
mail to

Financial Transactions and Reports Analysis Centre of Canada
Section A
234 Laurier Avenue West, 24th floor
Ottawa, ON K1P 1H7
Canada

**Note: There is no official acknowledgement of receipt when you submit a paper form to FINTRAC.

Changes to a report

Once you have submitted a report, it is possible to modify the report — for instance to add missing information or make corrections — but you must provide an explanation for the change.

FINTRAC may also notify you by email of reports that are missing information or contain incorrect information. These notices are labelled as "Reports returned for further action (RRFA)." For more information on how to respond to RRFAs, please refer to the FWR user guide that is available to reporting entities who have enrolled in FWR.

To modify a report that was submitted by:

FWR, refer to the FWR user guide
API, refer to ***
Batch, refer to the batch documentation for instructions, or use FWR to modify a report submitted by batch.
**Note: As of September ** 2023, new reports cannot be submitted by batch. Batch will only be available for reporting entities to modify or delete reports that were previously submitted in batch files before September **, 2023.

If you submitted an STR to FINTRAC and need to make a subsequent change to the report, or if FINTRAC notified you of an RRFA, you must make the change and submit the revised report to FINTRAC as soon as practicable.

5. What are the main considerations when submitting an STR?

This section contains important considerations when submitting STRs to FINTRAC. Some of these considerations only apply to reports submitted electronically and will be indicated accordingly.

STR form

The STR form has six sections — General information, Transaction information, Starting action, Completing action, Details of suspicion, and Action taken — and the table below shows the type of information for each section.

General information

Contact details and information about your business
Ministerial Directives
Reporting entity report reference number

Transaction information

Transaction status (completed or attempted) and reason if transaction was not completed
Date and time of transaction
Method of transaction
Reporting entity transaction reference number
Purpose of the transaction
Location where the completed or attempted transaction took place

Starting action

Direction of starting action (In / Out)
Type of funds, assets or virtual currency coming in or going out
Amount and currency or virtual currency type
Exchange rate
Virtual currency, reference and/or account information
Information about the source of funds, assets or virtual currency
Conductor (person or entity that conducted or attempted the transaction and their associated information)
Third party (person or entity on whose behalf the transaction is conducted or attempted and their associated information)

Completing action

Details of disposition
Amount and currency or virtual currency type
Exchange rate
Virtual currency, reference and/or account information
Any other person or entity involved in the completing action and their associated information
Beneficiary (any person or entity that was the beneficiary of the transaction and their associated information)

Details of suspicion

This is a free form text section where you can provide a description of the facts, context and indicators that allowed you to reach the reasonable grounds for suspicion of a money laundering or terrorist activity financing offence.

In this section, you can indicate:

whether the suspicious activity is related to ML/TF or both
the public-private partnership project name(s)
previously submitted reports and transactions that are related to the suspicious activity in this report

Action taken

This is a free form text section where you can provide a description of the action that will be or has been taken.

See Annex 1 and/or the STR form for the full list of fields in each section.

You can enter one or more transactions in a report. When entering multiple transactions into a report, you can enter transactions that have:

the same or different transaction status (for example, a report can include completed transactions and/or attempted transactions) and
taken place at the same or different locations.

For each completed or attempted transaction, you must provide information obtained about that transaction, the details of suspicion and the action you have taken in the fields provided in the STR. For example, if you know or obtained the following information, you must provide it in the STR:

Name of the person or entity who completed or attempted to complete the transaction.
Type and amount of funds, assets or virtual currency involved in the completed transaction or attempted transaction.
How the funds, assets or virtual currency were used (details of disposition) for a completed transaction or going to be used in an attempted transaction.
Whether the person or entity who conducted or attempted the transaction did so on anyone else's behalf.
Account details of an account involved in a completed transaction or was going to be involved in an attempted transaction.

Further, for a completed transaction, there should be at least one starting action and one completing action. If the transaction (for example, cash transaction, international electronic funds transfer, receipt of virtual currency or casino disbursement) involves a threshold amount of $10,000 or more, then the transaction must include the name of a beneficiary.

A transaction can have multiple starting actions and/or completing actions—depending on the client's instructions. Within each starting action, you can include multiple conductors, account holders, sources of funds or virtual currency, and third parties. If the conductor or third party is an entity, you can also include information about the entity's director(s), beneficial owner(s), trustee(s), settlor(s), and beneficiary(s) as applicable. Within each completing action, you can include multiple account holders, beneficiaries and other persons or entities involved in the completing action.

For each starting action, you will need to indicate the direction of the funds, asset or virtual currency used to start the transaction as either in or out. The direction of the starting action is in when a client physically brings in or electronically transfers in funds, assets or virtual currency to your business to start a transaction. The direction of the starting action is out when your client requests to start a transaction with client funds, assets or virtual currency already held by or deposited at your business. For example, when a client brings cash to your business to purchase a bank draft, the direction of the starting action is in. If the client does not bring in any funds but requests to purchase a bank draft with the client's funds already held by or deposited at your business, then the direction of the funds is out for the starting action.

STR example

On July 10, 2023, Ms. Green walks into branch 1 of Maple Credit Union and deposits $9,900 cash into her savings account. On July 11, 2023, Ms. Green walks into branch 2 of Maple Credit Union with a cheque for $20,000 and deposits $12,000 into her savings account and $8,000 into her chequing account. On July 12, 2023, Ms. Green walks into branch 1 of Maple Credit Union and instructs that $20,000 be withdrawn from her savings account and transferred to ABC Automotive Company's account at Hemlock Bank.

Based on a review of facts, context and indicators, as well as their procedures to assess suspicious transactions, Maple Credit Union establishes that there are reasonable grounds to suspect that the transactions are related to the commission of a ML/TF offence. Therefore, Maple Credit Union submits an STR—see Diagram 2.

Diagram 2 — STR example

The STR provides general information about Maple Credit Union and indicates that Ms. Green conducted three transactions:

The first transaction was conducted at branch 1 on July 10, 2023. There is one starting action involving $9,900 cash coming in and one completing action where $9,900 is deposited into a savings account. As Ms. Green is the sole account holder, she is the beneficiary of this transaction.
The second transaction was conducted at branch 2 on July 11, 2023. There is one starting action involving a $20,000 cheque coming in and two completing actions where $12,000 is deposited into a savings account and $8,000 is deposited into a chequing account. Ms. Green is the sole account holder for both accounts and therefore the beneficiary of this transaction.
The third transaction was conducted at branch 1 on July 12, 2023. There is one starting action involving $20,000 funds withdrawal out and one completing action—an outgoing domestic funds transfer for $20,000 where ABC Automotive Company is the beneficiary.

In the Details of suspicion section of the STR, Maple Credit Union provides the facts, context and indicators that allowed it to conclude that there are reasonable grounds to suspect that the transactions are related to the commission or attempted commission of a money laundering or terrorist activity financing offence. In the Action taken section, Maple Credit Union describes the action it has taken.

STR submission limitations (applicable to reports submitted electronically)

A report must include at least one transaction (completed or attempted) and may include up to *** transactions. If there are more than *** transactions, you will have to use more than one report for your transactions. You must include the reporting entity report reference number so that FINTRAC is aware of linked reports. The reporting entity report reference number is the unique number you assign each report. If *** transactions are exceeded in a report, you may include a suffix (for example, -001, -002, etc.) to indicate that the report is linked to another report. See below for more information on linking reports.

A transaction should include one starting and one completing action and may include up to 50 starting and 50 completing actions per transaction. If a transaction has more than 50 starting or completing actions, you must start a new report to continue the reporting of the starting or completing actions. You will use the original reporting entity transaction reference number from the transaction in the report with the first 50 starting or completing actions. You must repeat this transaction reference number to allow FINTRAC to identify and link the starting or completing actions across reports for a given transaction.

If you need to link transactions in multiple reports, you can continue counting transactions incrementally with each report. For example, 250 transactions detailed over three (3) reports could be submitted as:

Report 1 (STR999-01): Transactions 1 to 99;
Report 2 (STR999-02): Transactions 100 to 198; and
Report 3 (STR999-03): Transactions 199 to 250.

Validation of reports by FINTRAC

FINTRAC validates reports by applying the following rules to report fields to ensure the suitability and quality of information.

Presence – is there information in the field?
Format – is the information in the expected format according to the field type?
Content – is the information consistent with the field label?

Using the occupation field as an example:

If teacher is entered into the occupation field, then all of the validation rules are met because:
- the field contains information (presence);
- the information is in a text format (expected format); and
- teacher is an occupation—that is, the information is consistent with the field label (content).
If ABC High School is entered into the occupation field, then only the presence and format validation rules are met because:
- the field contains information; and
- the information is in a text format.
The content rule is not met because ABC High School is not an occupation—that is, the information is not consistent with the field label.
If a telephone number (for example, 604-515-4321) is entered into the occupation field, then only the presence validation rule is met because the field contains information. The format and content rules are not met because:
- the information is numeric rather than text; and
- 604-515-4321 is not an occupation—that is, the information is not consistent with the field label.
If no information is entered in the occupation field, then the presence validation rule is not met and the format and content rules cannot be applied.

Summary of validation results for occupation field:
Occupation field:	Presence	Format	Content
teacher	yes	yes	yes
ABC High School	yes	yes	no
604-515-4321	yes	no	no
(blank – no information provided)	no	Not applicable	Not applicable

FWR report validation (applicable to reports submitted electronically)

Reports submitted through FWR are immediately validated by the application. FWR will indicate where information is missing, incorrect or improperly formatted and you will need to correct this before you can submit a report in FWR.

API report validation (applicable to reports submitted electronically)

TBD

You should familiarize yourself with the STR validation rules. These rules identify possible reporting problems or information gaps but do not cover all scenarios. While FINTRAC conducts a validation of report submissions to assess the quality of reports, you should have your own proactive quality assurance practices in place.

Creating subject profiles (applicable to reports submitted electronically)

A subject is a person or entity involved in a transaction and must be included in the report. Subjects can be conductors, third parties, beneficiaries, all sources of funds or virtual currency, others involved in the transaction, as well as account holders.

FWR and API allow you to create different subject profiles to help streamline the entry of their information in report fields.

"Create person name" or "Create entity name" allows you to create a subject profile that is a source of funds or virtual currency, is involved in the completing action or is an account holder.
"Create person details" or "Create entity details" allows you to create a subject profile for a conductor, third party or beneficiary.

Once you have created a subject profile, you can select it as you navigate through each section of the report and the subject's information will auto populate the fields accordingly. If a person or entity has more than one role in a report (for example, a person is both the conductor and beneficiary in the transaction), the subject profile can be selected to populate fields for all roles. Although a subject profile can be selected to populate fields for all transactions in the same report where it was created, it will not be available for selection in other reports due to privacy considerations.

6. Do I have other requirements associated with suspicious transactions?

Compliance program

Your compliance policies and procedures must include details on the process for how you identify, assess and submit STRs to FINTRAC. It is possible that your organization has an automated or triggering system that detects unusual or suspicious transactions that would require assessment by a person to determine if you must submit an STR. A person with the appropriate knowledge and training is expected to be able to determine whether a transaction is related to the commission of an ML/TF offence. It is also important to note that the value of the transaction is not always the most important aspect of an STR. Training employees to perform this function is considered to be part of your compliance program obligations.

You are also required to assess the effectiveness of your compliance program as a part of your two-year effectiveness review. This includes assessing how effective you are in detecting, assessing and submitting STRs. The following are examples of how this can be done:

You can review previously submitted STRs to ensure that you are consistent in the detection, assessment and submission of STRs. For instance, if certain ML/TF indicators have supported your suspicions of ML/TF, you can assess whether these indicators apply to other situations to ensure that you are not missing suspicious transactions that should be or should have been reported to FINTRAC. This approach can help you build consistency within your organization
You can work with others in your business sector to learn how others are detecting, assessing and reaching the RGS threshold and to establish common ideas of what could be considered unusual or suspicious. Please consult FINTRAC's strategic intelligence products (for example, operational briefs and alerts) for more information on ML/TF risks and vulnerabilities that have been observed within certain reporting entity sectors or that relate to specific forms of criminality (for example, human trafficking, romance fraud, fentanyl and other synthetic drug trafficking).
You can review a sample of your STRs to assess the timeliness of your reporting of suspicious transactions. Specifically, you can review the measures you took to identify the relevant information in the STRs (facts, context and ML/TF indicators) and when this information became known to ensure that you are reporting as soon as practicable from the date you reached the RGS threshold.
You can review a sample of your STRs to assess the quality of information reported. This can include reviewing the integrity and consistency of know your client (KYC) information held by your business and ensuring that all relevant KYC information was included in the STR.

Large cash transactions

In addition to reporting suspicious transactions, you may also be required to submit Large Cash Transaction Reports (LCTR) to FINTRAC when you receive $10,000 or more in cash in a single transaction from a person or entity. Therefore, you may be required to submit an STR and an LCTR for the same transaction. For more information see Reporting large cash transactions to FINTRAC.

Electronic funds transfers

In addition to reporting suspicious transactions, you may also be required to submit an Electronic Funds Transfer Report (EFTR) to FINTRAC if the transaction involves a reportable electronic funds transfer. Therefore, you may be required to submit an STR and an EFTR for the same transaction. For more information see Guideline 8A: Submitting Non-SWIFT Electronic Funds Transfer Reports to FINTRAC Electronically or Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC.

Record keeping requirements

You must keep a copy of all STRs submitted to FINTRAC for a period of at least five years after the day the report is sent.^{Footnote 6} For more information on your record keeping requirements related to STRs, see your sector's record keeping guidance.

Verifying the identity of persons and entities

You are required to take reasonable measures to verify the identity of every person or entity that conducts or attempts to conduct a suspicious transaction.^{Footnote 7} This means that you are expected to ask the client for this information unless you think doing so will tip them off to your suspicion.^{Footnote 8} For specific information on when and how to verify the identity of a person or an entity, see your sector's guidance on When to verify the identity of persons and entities and the guidance on Methods to verify the identity of persons and entities.

Third party determination

For more information on your requirements to determine whether a person or entity is acting on behalf of another person or entity for a financial activity or transaction, see the guidance on Third party determination requirements.

Ministerial Directives

You must consider all requirements issued under a Ministerial Directive along with your suspicious transaction reporting requirements. For more information, see FINTRAC's guidance on Ministerial Directives and transaction restrictions.

Voluntary self-declaration of non-compliance

If you discover instances of non-compliance related to your suspicious transaction reporting requirements, FINTRAC strongly encourages you to report a voluntary self-declaration of non-compliance. For more information, see Voluntary self-declaration of non-compliance.

7. Are there any exclusions to reporting suspicious transactions?

If you are a financial entity, life insurance company or securities dealer, and you have foreign subsidiaries or foreign branches, the suspicious transaction reporting requirement does not apply to their operations outside Canada.

8. Do I need to continue reporting suspicious transactions after I submit an STR?

Once you have reached RGS, you must submit an STR. Further, if there are subsequent transactions, you must keep reporting as long as the suspicion remains. You are expected to periodically re-assess the client to verify that the level of suspicion has not changed. This process may be part of your documented risk assessment or ongoing monitoring. If you continue to report STRs on the same person or entity, you can reference a previous STR in the Related Report(s) section by:

entering the reporting entity report reference number and the reporting entity transaction reference number;
providing the reasonable grounds to suspect (facts, context and ML/TF indicators) that were included in the first STR submission; and
by providing any new additional information.

If you are reporting STRs because the assessment has changed due to new facts, context and/or ML/TF indicators, you are expected to provide them. For example, through the course of your assessment, you may have identified new ML/TF indicators or new parties transacting with your client. You may choose to include that information under a separate heading in the narrative section of the report (Details of suspicion) so that it is properly labeled as new information.

9. What are FINTRAC's expectations for completing an STR?

It is your responsibility to ensure that the information provided in an STR is complete and accurate. It is also important that you submit comprehensive and high quality STRs to facilitate FINTRAC's analysis process and disclosure to recipients. In the narrative sections of the STR—Details of suspicion and Action taken—it is important to avoid jargon or non-public references, such as terms and acronyms that are specific to your organization. Please use clear, simple and concise language so that an outsider can easily understand the information that you provide.

A variety of information is often collected as part of an assessment to determine if you are required to submit an STR and this information is valuable to include in your report to FINTRAC. A well-completed STR should consider the following questions:

Who are the parties to the transaction?
- Provide information on conductor(s), third party(s), beneficiary(s), account holder(s), source(s) of funds or virtual currency and any other person or entity involved in the transaction(s).
- Provide identifying information on the parties involved in the transaction. This could include the information you recorded to identify the conductor, as well as any information you have on the other parties to the transaction or its recipients.
- Provide information on the owner(s), director(s), officer(s), trustee(s), settlor(s) and those with signing authority, when possible. If the transaction involves an entity, you can include information on the ownership, control and structure of the business in the STR.
- Provide clear information about each person or entity's role in each of the financial transactions described. For example, it is important to know who is sending and receiving the funds and this can be elaborated in the Details of suspicion section of the STR.
- Provide the relationships between the parties (if known). This is very helpful to FINTRAC when trying to establish networks of persons or entities suspected of being involved in the commission or attempted commission of an ML/TF offence.
When was the transaction completed/attempted? If it was not completed, why not?
- Provide the facts, context and ML/TF indicators regarding the transaction.
What are the financial instruments or mechanisms used to conduct the transaction?
Where did this transaction take place?
Why are the transaction(s) or attempted transaction(s) related to the commission or attempted commission of an ML/TF offence?
- State the ML/TF indicators used to support your suspicion.
- State the suspected criminal offence related to ML/TF, if known.
How did the transaction take place?

Lists of transactions and the transaction details should not be reported in the narrative section of the STR (Details of suspicion). Transactions may be referenced in the narrative section if there are additional facts or context. However, the transaction details themselves must be entered in the appropriate structured fields of the form. For example, there are fields where you can enter information about:

a person's alias or nickname
electronic transfers (such as email money transfers or wire transfers) including IP addresses and sender/recipient email addresses
location of ATM withdrawals
the ownership, control and structure of an entity
the source of funds or virtual currency
any related and previously submitted STR report reference numbers and transaction reference numbers
credit card activity including details of purchases (dates, amounts, retailer (online or in-store) and details of payments (dates, amounts, conductor and source of payment)

If there are transaction details for which there is no specific field for this information, you can include this information in the narrative section of the STR. Information provided in the narrative section of the STR can contribute greatly to FINTRAC's analysis—this includes the following types of information:

the history the client has with you
links made to other people, businesses and accounts
information on the ownership, control and structure of an entity that is not already captured in the fields provided in the STR form, particularly for any business entities that have a complex structure
the intended or expected use of an account versus the activity you may have observed
any other information about your interactions with the client
relationships between parties to the transaction
the ML/TF indicators or factors that assisted in forming the basis of your suspicion
any information, including publicly available information and/or information from law enforcement, that made you suspect distinctly that the transaction might be related to terrorist financing, money laundering, or both
the location where a transaction was conducted, when this location does not belong to your business—for example, the location of a white label ATM that you do not own
information on any politically exposed persons, including their names, role and involvement in the transactions being reported
any details surrounding why an attempted transaction was not completed
any context or clarification about the information that was reported in the structured sections

If there are multiple details for a field, provide the detail that is specific to the transaction. This may occur for some fields such as the following:

email address
telephone number
URL
Username
Device identifier number
Internet protocol address

For example, your client Billy Bird has three email addresses (Sky@example.ca, Sky22@example.ca and BlueSky@example.ca.) and sends email money transfers to:

Oscar Ocean who is also your client. Oscar has two email addresses (Starfish@example.ca and Whaleshark@example.ca).
A recipient who is not your client but has the following email address and alias (contact name): FastCar@example.ca and Driver.

The email addresses that you report in an STR will depend on the transaction details. The table below provides some transaction details and the expected email address that should be reported.

Transaction details	Email address to be reported in the STR report
Billy Bird sends an outgoing email money transfer for $500 using Sky@example.ca to Oscar Ocean at Starfish@example.ca	Sky@example.ca (conductor email address field) Starfish@example.ca (beneficiary email address field).
Billy Bird sends an outgoing email money transfer for $900 using Sky22@example.ca to Oscar Ocean at Whaleshark@example.ca.	Sky22@example.ca (conductor email address field) Whaleshark@example.ca (beneficiary email address field).
Billy Bird sends an outgoing email money transfer for $1,000 using Sky22@example.ca to Driver at FastCar@example.ca	Sky22@example.ca (conductor email address field) FastCar@example.ca (beneficiary email address field).

Any additional email addresses that you have on your client (and were not related to a specific transaction) can be reported in the narrative section of the report (Details of suspicion). In the example above, you can explain in the narrative section that your client, Billy Bird, also has a third email address (BlueSky@example.ca) that was not used in these transactions.

**Note: If your client (conductor) is not sending an email money transfer, you should still report the client's email address that you have on file in the conductor email address field. If your client has more than one email address, the additional email addresses can be provided in the narrative section of the STR (Details of suspicion).

FINTRAC has been able to identify networks of suspected money launderers and terrorist financiers through pieces of information such as email addresses and secondary identifiers (nicknames) or phone numbers. This type of information may seem insignificant but can be very important to FINTRAC, as it may identify connections among persons, entities or crimes when compared against other FINTRAC intelligence.

The STR structure is intended to encourage reporting even in situations where you may not have information because the client did not provide any or asking for details might "tip off" the client to your suspicions. Double-checking the quality of the STRs before submitting them is important and it is FINTRAC's expectation that if you have the information within your institution, that it be reported.

10. What are common STR deficiencies to avoid?

The following are examples of deficiencies that FINTRAC has identified through its assessments and other compliance activities. FINTRAC is sharing these examples to illustrate common errors that you can avoid.

Using a higher threshold as your basis for reporting: You are required to submit an STR when you have completed the measures that enable you to establish that there are reasonable grounds to suspect that a transaction is related to the commission of an ML/TF offence as explained in section 2 above. Reasonable grounds to believe is a higher threshold than reasonable grounds to suspect and is beyond what is required to submit an STR.
Failing to list all the transactions and accounts relevant to your suspicion in the specified fields: You are required to report all the transactions and accounts that led to your determination that there are reasonable grounds to suspect that the transaction is related to the commission or attempted commission of an ML/TF offence in the specified fields of the report. Providing a summary of the transactions in the narrative section (Details of suspicion) is not enough.
Not providing or naming all parties to the transactions when the information is available: All parties to the transaction, including their associated information, must be provided in their corresponding structured fields if this information is available. This includes conductor(s), third party(s), beneficiary(s), account holder(s), source(s) of funds or virtual currency, and any other person(s) or entity(s) involved in the transaction. If an entity is involved, then the owner(s), director(s), officer(s), trustee(s), settlor(s) and those with signing authority should be provided as applicable. You should also specify whether the parties are known or unknown. This has been observed in transactions such as wire transfers that involve multiple parties. For example, if you are reporting a wire transfer, you should include any information you have on both the ordering client and beneficiary. This could include, but is not limited to, their names, their account number and institution, their relationship, and any known identifiers. FINTRAC acknowledges that this information may not always be at your disposal, but when you know it, it should be provided.
The information provided in the narrative section of the STR (Details of suspicion) does not elaborate on your grounds for suspicion or link to the transaction(s) in the report: You are required to articulate the reasons for your determination that there are reasonable grounds to suspect that the transaction(s) is related to the commission or attempted commission of an ML/TF offence. This includes providing—in the narrative section of the STR—all of the relevant facts, context and ML/TF indicators that are related to the transaction(s) in the report and support your suspicion. This deficiency has been observed when a reporting entity does not articulate the reasons for their suspicion or does not explain how or why certain information is relevant to their suspicion.

Annex 1: Field instructions to complete an STR

This annex contains instructions on how to complete the fields in an STR form. These instructions are organized into two sections, standardized field instructions and specific field instructions.

**Note: Some fields only become applicable on the completion of other fields.

**Note: Some field instructions may only apply to the electronic report submissions and not paper submissions.

Failure to provide applicable reporting information will result in non-compliance and may lead to criminal or administrative penalties. To learn more about potential enforcement actions, please see Penalties for non-compliance.

Standardized field instructions

This section contains:

standardized instructions for the level of effort that is expected in order to obtain the prescribed information for the reporting fields (mandatory, mandatory for processing, mandatory if applicable and reasonable efforts.)
instructions for completing the following fields that appear in multiple sections of the form—name, address, occupation/business, identification, and telephone number.

In this guidance, fields are categorized as either mandatory, mandatory for processing, mandatory if applicable, or reasonable measures. You must complete theses fields as described below:
1. Mandatory:
  Mandatory fields are indicated with an asterisk symbol (*) and these fields must be completed. However, in the case of an attempted transaction, these fields become "reasonable measures" fields and you must take reasonable measures, as indicated in the instructions below, to obtain the information for any mandatory field,^{Footnote 9}
2. Mandatory for processing:
  Mandatory for processing fields must be completed. These fields are indicated with a double dagger symbol (‡).
3. Mandatory if applicable:
  Mandatory if applicable fields must be completed if they are applicable to you or the transaction being reported. These fields are indicated with a dagger symbol (†).
4. Reasonable measures:^{Footnote 10}
  You must take reasonable measures to obtain the information for all non-mandatory fields in the report, if they are applicable. Reasonable measures are the steps that you must take, as outlined in your policies and procedures, to obtain the information that can include asking the person or entity involved in the transaction for the information—as long as you don't think it will tip off the person that you are submitting an STR. If the information is obtained, it must be reported. It also means that you must provide the information if it is contained within your systems or records.
**Note: Fields that are not applicable are to be left blank. When a field is not applicable, do not enter "Not applicable", "N/A" or "n/a" or substitute any other abbreviations, special characters ("x", "-" or "*") or words ("unknown") in these fields.
Name fields
Surname

Provide the last name of the person.

Given name

Provide the first name of the person.

Other/Initial

Provide the middle or other name(s) of the person, or their initial(s) if no other names apply.

Alias

Provide the name a person uses, or by which they are known, other than the name provided under surname, given name, or other/initial.

Name of entity

Provide the full name of the entity.
Address fields
Provide the address details in the structured or unstructured fields (as applicable) as explained below:

Structured address fields

Structured address fields include:
- Apt/Room/Suite/Unit number
- House/Building number
- Street address
- City
- District
- Country
- Province or state
- Sub-province and /or sub-locality
- Postal or zip code
If you have the ability to separate the information, you must report it in the structured address fields. For example, if a person lives at #10-123 Main Street, Richmond, BC, Canada A1B 2C3, complete the address fields as follows:
- Apt number is 10
- Building number is 123
- Street address is Main Street
- City is Richmond
- Province is BC
- Country is Canada
- Postal code is A1B 2C3
If you are unable to separate the address information into the structured address fields (for example, your system groups the Apt/Room/Suite/Unit number with the House/Building number and Street address), then provide all the address information in the Street address field and the city, province, country and postal code in their respective fields.

Similarly, if a person or entity's address is in an area where there is no civic address, provide a description of the physical location. For example, if a person lives in the third house to the right after the community center in Tinytown, SK, Canada X1Y 2Z2, complete the address fields as follows:
- Street address is third house to the right after the community center
- City is Tinytown
- Province is SK
- Country is Canada
- Postal code is X1Y 2Z2
If you use the structured address fields, you cannot use the unstructured address fields to provide additional information.

Unstructured address field

You should only use the unstructured address field when it is not possible to separate the address information—this typically occurs when you are uploading a large volume of reports. If possible, enter information about the country in the Country field and provide the unstructured address information in the following format:
- street address/city/province or state/postal code or zip code
**Note: The following are not valid addresses, and should not be provided in either the structured or unstructured address fields:
- A post office box without a complete physical address (for example, PO Box 333)
- General delivery address
- Only a suite number (for example, Suite 256) without additional address information
However, it is possible that some of the examples above may be included in the narrative section of the STR (Details of suspicion) because they are relevant but they are not considered a valid address in terms of the client identification.

A legal land description can be acceptable as long as the land description is specific enough to pinpoint the physical location of the client's address. If the legal land description refers to an area or a parcel of land on which multiple properties are located, the legal land description would not be sufficient.

For persons who are transient (for example, travelling in a recreational vehicle or temporarily working in a camp) and have no fixed address, you are required to provide the following:
- For Canadian residents, their permanent address is required, even if that is not where they are currently residing.
- For non-Canadian residents travelling in Canada for a short period of time, their foreign residential address is required.
- For non-Canadian residents living in Canada for a longer period of time (for example, a student), then the person's temporary Canadian address should be provided.
Occupation/business fields
Occupation

When entering occupation information, you should be as descriptive as possible. If the person is a manager, provide the area of management, such as "hotel reservations manager" or "retail clothing store manager." If the person is a consultant, provide the type of consulting, such as "IT consultant" or "forestry consultant." If the person is a professional, provide the type of profession, such as "petroleum engineer" or "family physician." If the person is a labourer, provide the type of labour performed, such as "road construction worker" or "landscape labourer." If the person is not working, you should still be as descriptive as possible, and indicate "student," "unemployed," "retired," etc.

You can enter a full numeric classification code and the code title (for example NAICS - North American Industry Classification System or NOC - National Occupational Classification), followed by a text description of the occupation. A numeric code on its own is not sufficient. For example, if the occupation is secondary school teacher, you can enter "NAICS 611110 – Elementary and secondary schools, secondary school teacher" or "NOC 4031 – Secondary school teacher".

Name of employer

Enter the name of the person's employer. Do not provide the name of a supervisor or manager. This field is meant to capture the name of the business that employs the person. If the person has multiple employers, you only need to provide one but it should be the person's primary employer. Providing the name of employer can augment the description of a person's occupation. For example, "retail clothing store manager for ABC high-end clothing store" and "retail clothing store manager for XYZ discount clothing store" are more descriptive than "retail clothing store manager" on its own.

Nature of entity's principal business

You should be as descriptive as possible when entering the entity's principal business. If the entity's principal business is "sales," provide the type of sales, such as "pharmaceutical sales" or "retail clothing sales."

You can enter a full numeric classification code and the code title (for example NAICS - North American Industry Classification System), followed by a text description of the entity's principal business. A numeric code on its own is not sufficient. For example, if the entity is a golf equipment store, you can enter "NAICS 451111 – Golf equipment and supplies specialty stores."
Identification fields
Identifier type

Select the identifier type for the person or entity as applicable. If the identifier type is not listed, select "Other" and provide details. If you use the dual process method to identify a person, you must provide details of both sources of information in the identifier type fields.

Please note that a Social Insurance Number (SIN) must not be reported to FINTRAC. In addition, you cannot use documentation for identification purposes where it is prohibited by provincial legislation.

For more information on how to identify persons and entities, refer to FINTRAC's guidance on Methods to verify the identity of persons and entities.

Number associated with identifier type

This is the number indicated on the identifier type that was used to verify the identity of the person or entity. For example, on a driver's licence, the licence number is the identification number and on a Certificate of Incorporation, the incorporation number is the identification number.

Jurisdiction of issue (country, province or state)

Provide the country, province, or state that issued the documentation used to identify the person or entity. If the documentation is issued by a country, enter that country as the jurisdiction of issue. If the documentation is issued by a province or state, enter that province or state as the jurisdiction of issue, and provide the corresponding country information.
Telephone number fields
If the telephone number is from Canada or the United States, enter the area code and local number (for example, 999-999-9999).

If the telephone number is from outside Canada or the United States, enter the country code, city code and local number using a dash (-) to separate each one. For example,'99-999-9999-9999' would indicate a two-digit country code, a three-digit city code and an eight digit local number.

Specific field instructions

This section contains instructions for specific fields that are laid out in the same order as they appear on the STR form. If a field does not have instructions, it may be that the instructions:

have not been provided for that field,
can be found elsewhere in the form where the same field type exists, or
are in the standardized field instructions section.

General Information

*Reporting entity number

You must enroll in FWR to submit reports electronically. Provide the seven-digit identifier number assigned to you by FINTRAC at enrolment.

‡Reporting entity report reference number

A unique report reference number assigned by you, your organization or your service provider who submits reports on your behalf, as applicable.

Which one of the following types of reporting entities best describes you?

*Activity sector

Enter your business activity sector. If you are involved in more than one type of business activity, indicate the one applicable to the transaction being reported. If there is more than one business activity for one or more transactions on the report, select only one to indicate your principal type of business activity.

Whom can FINTRAC contact about this report?

Enter the contact information of the person you would like FINTRAC to liaise with in the event that a follow up is required. You must ensure that all of your contacts' information is up to date in FWR prior to submitting your report(s).

Report information

Ministerial Directive

If a transaction is being reported to FINTRAC under a Ministerial Directive, then indicate this by selecting the Ministerial Directive in the STR.

Leave this field blank if the transaction(s) are not part of a Ministerial Directive.

**Note: Only one Ministerial Directive (IR2020) is available for an STR report. If you select Ministerial Directive, then the report can only contain one transaction and you must not complete the "Details of suspicion" and "Action taken" sections of the STR form.

**Note: If a transaction is being reported to FINTRAC under a Ministerial Directive and the transaction also meets the RGS threshold, then you must submit two reports to FINTRAC. In the first report, select Ministerial Directive and do not complete the "Details of suspicion" and "Action taken" sections of the STR form. In the second report, do not select Ministerial Directive but complete all applicable fields of the form, including the "Details of suspicion" and "Action taken" sections.

Transaction information

Information about the transaction

*Transaction status

Indicate if the transaction was completed or attempted.

†Reason transaction was not completed

If the transaction was not completed, provide the reason.

†Date of transaction

Enter the date of the transaction or attempted transaction. The date must be no earlier than November 8, 2001. It cannot be a future date and must be the same as or earlier than the posting date.

This field is mandatory, unless you are a financial entity and indicate that the transaction was a night deposit. In this case, if you do not provide the date of transaction in this field, you must provide the date of posting.

Time of transaction

Enter the time of the transaction or attempted transaction and provide the time zone (that is, UTC offset) based on the location where the transaction or attempted transaction took place (for example, the location of where the cash was received). The time must be entered in the following format: HH:MM:SS±ZZ:ZZ. For example, 1:25:06 pm in Ottawa, ON would be reported as 13:25:06-05:00.

A report can contain multiple transactions that took place in different time zones.

If you do not know the time of an attempted transaction, but you are aware of the approximate time frame of when the attempted transaction occurred, you can indicate this in the narrative section of the report (Details of suspicion)—for example, afternoon, morning, between 3 to 4 pm.

*Method of transaction

Select the method that describes how the transaction was conducted. If the method is not listed, select "Other."

**Note: "Night deposit" and "quick drop" are only applicable to financial entities and if you select either of these methods of transaction, you will not be required to complete the conductor information fields.

†If "Other," please specify

Date of posting (if different from date of transaction)

Enter the date the transaction cleared, if this differs from the date of the transaction. The date must be no earlier than November 8, 2001. It cannot be a future date and must be later than the transaction date. This field is mandatory if the transaction was a night deposit and the date of transaction was not provided or differs from the posting date. In all other cases, this is a reasonable efforts field.

‡Reporting entity transaction reference number

This is a unique reference number assigned to the transaction by you, your organization or your service provider who submits reports on your behalf as applicable.

Purpose of transaction

This is the reason for the transaction and it may not be the same as the information provided in the details of disposition field. However, your narrative on the purpose of transaction should expand on the disposition. The bolded text below are examples of purpose of transaction:

A client brings cash tips from his job as a server for deposit into his bank account to save for the purchase of a home.
A client pays cash to purchase jewellery that will be a gift for a friend.
A client brings in cash to exchange CAD to GBP for vacation purposes.
A client purchases a bank draft in order to buy a house.
A client sends an email money transfer to purchase a boat.

You may be able to determine the purpose of a transaction by asking the client.

Information about where the transaction was conducted or attempted

Provide information about the physical location where the transaction took place or was attempted. For example, if the transaction was conducted at a branch, provide the reporting entity location number of that branch. If the transaction was conducted at an ATM, provide the reporting entity location number of that ATM. If no physical location is applicable (for instance the transaction was conducted online), provide the location number of your main location, such as a head office or headquarters.

*Reporting entity location number

This represents information about where the transaction took place. For example, if the client deposited cash at Branch 1, then select the location number that is associated with Branch 1. If the client conducts a transaction online, then select the location number that is associated with the location that receives and initiates the client's online instructions.

The location number is created and assigned to you by FINTRAC during the FWR enrolment process and maintained by your FWR administrator. For more information about this, contact your FWR administrator.

Starting action

‡Direction of Starting Action (In /Out)

Indicate the direction of the starting action as either in or out for the funds, assets or virtual currency involved. The direction of the starting action is in when a client physically brings in or electronically transfers in funds, assets or virtual currency to your business to start a transaction. The direction of the starting action is out when your client requests to start a transaction with funds, assets or virtual currency already held by or deposited at your business.

‡Type of funds, assets or virtual currency (In)

If the direction of the starting action is in, select one of the following based on what the client brought or transferred in to start the transaction.

Bank Draft – To be used when the client brings in a bank draft to start a transaction. The term bank draft refers to a negotiable instrument that can be used as payment (similar to a cheque). Unlike a cheque though, a bank draft is guaranteed by the issuing bank.
Cash – To be used when the client brings in coins or bank notes that are intended for circulation in Canada or coins or bank notes of countries other than Canada to start a transaction.
Casino product – To be used when the client brings in chips, plaques, tokens or other casino products to start a transaction.
Cheque – To be used when the client brings in a cheque, including personal, certified and casino cheques, to start a transaction.
Domestic funds transfer – To be used when the starting action involves client instructions for the incoming transfer of funds from within Canada. This includes internal transfers within an organization where funds are transferred from one account to another account in the same organization.
Email money transfer – To be used when the starting action involves an incoming transfer using the recipient's email address.
International funds transfer – To be used when the starting action involves client instructions for the incoming transfer of funds from outside Canada.
Investment product – To be used when the starting action involves an incoming transfer of an investment product (for example, transfer of shares from one investment account to another).
Jewellery – To be used when the client brings in jewellery to start a transaction. Jewellery means objects made of precious metals, precious stones or pearls that are intended for personal adornment.
Mobile money transfer – To be used when the starting action involves an incoming transfer using the recipient's phone number.
Money Order – To be used when the client brings in a money order to start a transaction. A money order is a certificate, usually issued by a government or financial institution that allows the stated payee to receive cash on demand.
Precious Metals – To be used when the client brings in precious metal(s) to start a transaction. Precious metals means gold, silver, palladium and platinum in the form of coins, bars, ingots, granules or in other similar forms.
Precious Stones – To be used when the client brings in precious stone(s) to start a transaction. Precious stones means diamonds, sapphires, emeralds, tanzanites, rubies or alexandrites.
Virtual Currency – To be used when you receive virtual currency for a client as part of the starting action.
Other – To be used when the type of funds, assets or virtual currency physically brought in or electronically transferred in by the client to start the transaction is not captured by any other type listed above. Upon selecting "Other," you must provide a description of the type of funds, assets or virtual currency.

†Type of funds, assets or virtual currency (Out)

If the direction of the starting action is out, select one of the following based on what the client used to start the transaction.

Casino product – To be used when the client starts a transaction with chips, plaques, tokens or other casino products that are held by your business for the client.
Funds withdrawal – To be used when the client withdraws funds held or deposited at your business to start a transaction.
Investment product – To be used when the client starts a transaction with an investment product held by your business for the client.
Virtual Currency – To be used when a client starts a transaction with virtual currency held in a wallet or an account at your business.
Other – To be used when the type of funds, assets or virtual currency held by your business for the client to start the transaction is not captured by any other type listed above. Upon selecting "Other," you must provide a description of the type of funds, assets or virtual currency.

†If "Other," please specify

*Amount

Enter the total amount of funds, assets or virtual currency involved in the starting action. If this amount was not in Canadian dollars, do not convert it to CAD but provide the currency or virtual currency type in the next fields, as applicable.

†Currency / †Virtual currency type

Enter the currency (including if it was in Canadian dollars) or virtual currency of the starting action. If the currency or virtual currency type is not in the lists provided, you must select "Other" and provide the full name of the currency.

†If "Other," please specify

Exchange rate

Provide the rate of exchange that you used for the transaction. This can be an exchange rate for fiat currency or virtual currency.

†Sending virtual currency address

The sending virtual currency address is made up of a number of alpha-numeric characters, its length is determined by the type of virtual currency used. The sending virtual currency address is associated with whoever is sending the virtual currency (typically the conductor).

†Virtual currency transaction identifier

This is a unique identifier; it is commonly represented by a hash consisting of mixed numerical and alphabetical characters.

†Reference number

If the transaction involved a reference number, provide it in this field.

If the transaction involves an account at a financial entity, securities dealer or casino (account-based reporting entity), do not provide the account number information in this field—instead, provide that information in the account number field.

For all other reporting entities, if you have an internal account number that is used as a reference number, then provide the internal account number in this field.

Other number related to reference number

Provide any other number related to the reference number as applicable.

†Financial institution number

†Branch number

†Account number

If the transaction involves an account at a financial entity, securities dealer or casino (account-based reporting entities), provide that account number.

If you are not an account-based reporting entity, but the transaction involves an account at an account-based reporting entity, provide that account number in this field.

**Note: Although the financial institution number and branch number should be entered in the corresponding structured fields as available, it is also acceptable to include the financial institution number and branch number as part of an account number.

†Account type

†If "Other," please specify

†Account currency

†Account virtual currency type

†If "Other," please specify

Date account opened

Date account closed

†Status of account at time of transaction

Account holder – Person

†Surname

†Given name

Other/initial

Account holder – Entity

†Name of entity

**Note: Source of funds or virtual currency

The following fields are about how the conductor obtained the funds or virtual currency, and the source of funds or virtual currency:

How were the funds or virtual currency obtained?
Was information about the source (person /entity) of funds or virtual currency obtained?
Source of funds or virtual currency – person or entity

Although the information in these fields are related, they are different as demonstrated by the example below:

Example

Vicky Violet brings in $12,000 cash for deposit into her bank account and tells the bank that she obtained this cash when she sold her car to Griffin Grey. She was only able to provide Griffin Grey's name to the bank because she did not have information on his account number, policy number or identifying number. As such, the source of funds or virtual currency fields would be completed as follows:

How were the funds or virtual currency obtained? "Sale of car"
Was information about the source (person / entity) of funds or virtual currency obtained? "Yes"
Source of funds or virtual currency – "Griffin Grey"

Please see the specific field instructions that follow for more information on completing these fields.

How were the funds or virtual currency obtained?

This is how the conductor initially acquired the funds or virtual currency used for the transaction, not where the funds or virtual currency may have been transferred from. For example, you can obtain funds or virtual currency from activities such as employment, sale of a large asset and gifts. This information must be reported if obtained.

‡Was information about the source (person / entity) of funds or virtual currency obtained?

This field is a "Yes/No" question. Select "yes" if you have the name of any person or entity that is the source of the funds or virtual currency, their account number or policy number, or an identifying number if there is no account number or policy number. Otherwise, select "no" to indicate that you do not have the information.

Source of funds or virtual currency

If you have information on any source of the funds or virtual currency involved in the transaction, you must report it. If there are multiple sources, you must provide information for each source.

Source of funds or virtual currency - person

†Surname

†Given name

Other/initial

Account number

Policy number

Identifying number

If there is no account or policy number, provide an identifying number if available.

Source of funds or virtual currency - entity

†Name of entity

Account number

Policy number

Identifying number

If there is no account or policy number, provide an identifying number if available.

‡Conductor indicator

Indicate if you have obtained conductor information related to this transaction or attempted transaction. "No" should only be selected if the conductor is not your client, and after taking reasonable measures, you were not able to obtain any conductor details.

Conductor - person

Provide all the information you have on one, or multiple persons specified as the conductors of the transaction.

Surname

Given name

Other/Initial

Alias

Client number

A unique identifying number assigned by the reporting entity to the person conducting the transaction.

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Email address

URL

Enter the uniform resource location, commonly known as the web address, for the conductor. This includes the URL for personal or business websites, blogs and any social media.

Date of birth

Country of residence

Enter the primary country of residence for the person. It can be the same or different from the country entered in the address section.

Country of citizenship

Occupation

Name of employer

Information about the employer's address

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Identification of the person

Identifier type

†If "Other", please specify

Number associated with identifier type

Jurisdiction of issue (country)

Jurisdiction of issue (province or state)

Information about conducting or attempting to conduct the transaction online

Type of device used

†If "Other", please specify

Username

A username is how a person or an entity refers to themselves online.

Device identifier number

The device identifier number is a number assigned to the device, such as a Media Access Control (MAC) address or International Mobile Equipment Identity (IMEI) number.

Internet protocol address

Date and time of online session in which request was made

This is the date and time the conductor accessed the online environment where the transaction was requested.

Conductor - entity

Provide all the information you have on one, or multiple entities specified as the conductors of the transaction.

Name of entity

Client number

A unique identifying number assigned by the reporting entity to the entity conducting the transaction.

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Email address

URL

Identification of the entity

Provide the following information that was used to verify the identity of the entity. For some entities, this information may be the same as the registration or incorporation information provided below.

Identifier type

†If "Other", please specify

Number associated with identifier type

Jurisdiction of issue (country)

Jurisdiction of issue (province or state)

Information about conducting or attempting to conduct the transaction online

Type of device used

†If "Other", please specify

Username

Device identifier number

Internet protocol address

Date and time of online session in which request was made

Person authorized to bind the entity or act with respect to the account (maximum 3)

If the conductor is an entity, you must provide the information for up to three persons who are authorized to bind the entity or act with respect to the account.

Surname

Given name

Other/Initial

Information respecting the structure of the entity

Entity structure / type

If "Entity other than a corporation or trust" is selected, please specify

Nature of entity's principal business

Is the entity registered or incorporated?

Incorporation number / Jurisdiction of issue (country, province or state)

Provide the incorporation number and jurisdiction of issue of the entity conducting the transaction for each jurisdiction where the entity is incorporated.

Registration number / Jurisdiction of issue (country, province or state)

Provide the registration number and jurisdiction of issue of the entity conducting the transaction for each jurisdiction where the entity is registered.

For Canadian entities, a registration number can include the 9-digit business number assigned to that entity by the Canada Revenue Agency (CRA).

Corporate Information

Director(s) of a corporation

Surname

Given name

Other/Initial

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Person who directly or indirectly owns or controls 25% or more shares of the corporation

Surname

Given name

Other/Initial

Trust Information

Trustee(s) of a trust

Surname

Given name

Other/Initial

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Settlor(s) of a trust

Surname

Given name

Other/Initial

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Widely held or publicly traded trust information

Person who directly or indirectly owns or controls 25% or more units of a widely held or publicly traded trust

Surname

Given name

Other/Initial

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Beneficiary(s) of a trust, other than a widely held or publicly traded trust

Surname

Given name

Other/Initial

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Entity other than a corporation or trust Information

Person who directly or indirectly owns or controls 25% or more of an entity other than a corporation or trust

Surname

Given name

Other/Initial

On behalf of indicator

‡Was this transaction conducted or attempted on behalf of another person or entity?

This field is a "Yes/No" question. Select "yes" if the transaction was conducted or attempted on behalf of another person or entity. The "on behalf of" party is also known as the "third party" or the party providing instructions for the transaction.

If the transaction was conducted or attempted on behalf of another person or entity, you must include the relevant information.

On behalf of - person

Surname

Given name

Other/Initial

Alias

Client number

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

URL

Email address

Date of birth

Country of residence

Country of citizenship

Occupation

Name of employer

Information about the employer's address

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Identification of the person on whose behalf the transaction was conducted

Identifier type

†If "Other", please specify

Number associated with identifier type

Jurisdiction of issue (country)

Jurisdiction of issue (province or state)

Relationship of the person name above to the person or entity conducting or attempting to conduct the transaction

Relationship

Select the relationship of the "on behalf of" party to the person or entity conducting or attempting to conduct the transaction. The "on behalf of" party is understood to be the person or entity that instructs the person or entity conducting the transaction.

†If "Other", please specify

On behalf of – entity

Name of entity

Client number

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Email address

URL

Identification of the entity on whose behalf the transaction was conducted

Identifier type

†If "Other", please specify

Number associated with identifier type

Jurisdiction of issue (country)

Jurisdiction of issue (province or state)

Person authorized to bind the entity or act with respect to the account (maximum 3)

If the third party is an entity, you must provide the information for up to three persons who are authorized to bind the entity or act with respect to the account.

Surname

Given name

Other/Initial

Information respecting the structure of the entity

Entity structure / type

If "Entity other than a corporation or trust" is selected, please specify

Nature of entity's principal business

Is the entity registered or incorporated?

Incorporation number / Jurisdiction of issue (country, province or state)

Provide the incorporation number and jurisdiction of issue of the entity conducting the transaction for each jurisdiction where the entity is incorporated.

Registration number / Jurisdiction of issue (country, province or state)

Provide the registration number and jurisdiction of issue of the entity conducting the transaction for each jurisdiction where the entity is registered.

Corporate Information

Director(s) of a corporation

Surname

Given name

Other/Initial

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Person who directly or indirectly owns or controls 25% or more shares of the corporation

Surname

Given name

Other/Initial

Trust Information

Trustee(s) of a trust

Surname

Given name

Other/Initial

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Settlor(s) of a trust

Surname

Given name

Other/Initial

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Widely held or publicly traded trust information

Person who directly or indirectly owns or controls 25% or more units of a widely held or publicly traded trust

Surname

Given name

Other/Initial

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Beneficiary(s) of a trust, other than a widely held or publicly traded trust

Beneficiary

Surname

Given name

Other/Initial

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Entity other than a corporation or trust information

Person who directly or indirectly owns or controls 25% or more of an entity other than a corporation or trust

Surname

Given name

Other/Initial

Relationship of the entity named above to the person or entity conducting or attempting to conduct the transaction

Relationship

†If "Other", please specify

Completing action

*Details of disposition

The disposition describes what happened to the funds or virtual currency involved in the transaction. Select the following disposition(s) based on the client's instructions.

Added to virtual currency wallet – To be used when virtual currency is added to a virtual currency wallet.
Cash withdrawal (non-account based) – To be used when cash is withdrawn from a non-account based reporting entity, such as a money services business.
Cash withdrawal (account based) – To be used when cash is withdrawn from an account-based reporting entity, such as a bank or credit union.
Denomination exchange – To be used when the cash received is exchanged from one unit value to another (for example, 20s to 100s) within the same currency.
Deposit to account – To be used when funds or virtual currency are deposited into an account at an account-based reporting entity, such as a bank or credit union.
Payment to account –. To be used when funds or virtual currency are used to pay down a loan, mortgage, line of credit or credit card account balance.
Exchange to fiat currency – To be used for a fiat-to-fiat currency exchange (for example, CAD to USD) or a virtual currency-to-fiat exchange (for example, BTC to CAD).
Exchange to virtual currency – To be used for a fiat-to-virtual currency exchange (for example, CAD to BTC) or a virtual currency-to-virtual currency exchange (for example, BTC to ETH).
Holding funds – To be used when a non-account-based reporting entity (for example, a money services business) receives cash and holds these funds for a client for the purpose of a future transaction (for example, buy virtual currency when it hits a certain threshold).
Investment product purchase or deposit – To be used when a client buys or makes a deposit to a Guaranteed Investment Contract (GIC), RRSP, stock from an exchange (for example, TSX), or any other such investments.
Issued cheque – To be used for the issuance of a certified cheque, a disbursement through a casino cheque, etc.
Life insurance policy purchase or deposit – To be used when a client buys or puts a deposit down to purchase a life insurance policy.
Outgoing domestic funds transfer – To be used when the transaction instructions are for the transfer of funds within Canada.
Outgoing email money transfer – To be used when the funds are transferred using a recipient's email address.
Outgoing international funds transfer – To be used when the transaction instructions are for the transfer of funds outside of Canada.
Outgoing mobile money transfer – To be used when the funds are transferred using a recipient's phone number.
Outgoing virtual currency transfer – To be used when a reporting entity transfers virtual currency from a client's virtual currency wallet to another virtual currency wallet.
Purchase of bank draft – To be used when a client purchases a bank draft from a financial entity. The term bank draft refers to a negotiable instrument that can be used as payment (similar to a cheque). Unlike a cheque though, a bank draft is guaranteed by the issuing bank.
Purchase of casino product – To be used when a client purchases a casino product. A casino product can include, but is not limited to, chips, plaques and tokens.
Purchase of jewellery – To be used when a client purchases jewellery from a dealer in precious metals and precious stones (DPMS). Jewellery means objects made of precious metals, precious stones or pearls that are intended for personal adornment.
Purchase of money order – To be used when a client purchases a money order. A money order is a certificate, usually issued by a government or financial institution that allows the stated payee to receive cash on demand. A money order functions much like a cheque as the purchaser of the money order may stop the payment.
Purchase of precious metals – To be used when a client purchases precious metals from a DPMS. Precious metals means gold, silver, palladium and platinum in the form of coins, bars, ingots, granules or in other similar forms.
Purchase of precious stones – To be used when a client purchases precious stones from a DPMS. Precious stones means diamonds, sapphires, emeralds, tanzanites, rubies or alexandrites.
Purchase of prepaid payment product/card – To be used when a client purchases a prepaid payment product (PPP). The PPP must be tied to a PPP account held by a financial entity. A PPP is a product that is issued by a financial entity that enables a person or entity to engage in a transaction by giving them electronic access to funds or to virtual currency paid into a PPP account held with the financial entity in advance of a transaction taking place.
Real estate purchase or deposit – To be used when a client purchases or puts a deposit down on real estate.
Purchase of / Payment for goods – To be used when a client purchases or pays for goods not already captured by any other disposition type included in the list above (for example, car, yacht).
Purchase of / Payment of services – To be used when a client purchases or pays for services not already captured by any other disposition type included in the list above (for example, cable, internet, hydro).
Other – To be used when the disposition is not captured by any other disposition type included in the list above. Upon selecting "Other," you must provide a description of the disposition. "Other" should not be used to combine multiple dispositions that are listed above. Specifically, if the completing action has multiple dispositions that are included in the list above, then each disposition should be selected and not combined under "Other".

A completing action may have one or more dispositions, depending on the client's instructions and your business process.

Example 1: A single disposition

Your client requests that $12,000 from the client's savings account be used to purchase a bank draft. There is only one disposition — "purchase of bank draft."

Example 2: Multiple dispositions

Your client brings in $12,000 cash and instructs that $5,000 be deposited into the client's savings account and $7,000 be exchanged to bills in a larger denomination. There are two dispositions—"deposit to account" and "denomination exchange."

Example 3: A single disposition or multiple dispositions (Depending on your business process)

Your client brings in $12,000 cash and instructs that $12,000 be transferred to a friend outside Canada.

If you are financial entity, you may have a business process to deposit the cash into the client's account before the amount is sent to the client's friend. In this case, there are two dispositions—"deposit to account" and "outgoing international funds transfer." If your business process is to send the amount to the friend without depositing into an account, then there is one disposition—"outgoing international funds transfer."
If you are an MSB, you may have a process to hold the funds until a later date on which you send the amount. In this case, there are two dispositions — "holding funds" and "outgoing international funds transfer." If your business process is to send the amount to the friend without holding the funds, then there is one disposition—"outgoing international funds transfer."

†If "Other", please specify

If the disposition is "Other", provide details that describe the disposition of the transaction.

*Amount

Enter the amount involved in the completing action. For example, this may be the amount of:

virtual currency after an exchange to virtual currency
funds being initiated for an outgoing international funds transfer
funds indicated on the bank draft

†Currency

If the disposition involves a fiat currency, enter the currency even if it was in Canadian dollars. If the currency type is not in the list provided, you must select "Other" and provide the name of the currency.

†Virtual currency type

If the disposition involves virtual currency, select the virtual currency. If the currency type is not in the list provided, you must select "Other" and provide the name of the virtual currency.

†If "Other", please specify

†Exchange rate

Provide the rate of exchange that you used for the transaction. This can be an exchange rate for fiat currency or virtual currency.

†Value in Canadian dollars

Provide the Canadian dollar value of the disposition if it is not funds or virtual currency. For example, provide the value of the jewellery, precious metals or precious stones that were purchased. This may be the market, retail or other value that you would use in the ordinary course of your business at the time of transaction, and as detailed by and in accordance with your policies and procedures.

†Virtual currency transaction identifier

This is a unique identifier; it is commonly represented by a hash consisting of mixed numerical and alphabetical characters.

†Receiving virtual currency address

The virtual currency address for the person or entity receiving the virtual currency. The receiving virtual currency address could be associated with the beneficiary of the virtual currency, or it could include the address in which you (the reporting entity) received the virtual currency, if that is how your business operates.

†Reference number

If the transaction involved a reference number, provide it in this field.

For all other reporting entities, if you have an internal account number that is used as a reference number, then provide the internal account number in this field.

Other number related to reference number

Provide any other number related to the reference number as applicable.

†Financial institution number

†Branch number

†Account number

If the transaction involves an account at a financial entity, securities dealer or casino (account-based reporting entities), provide that account number.

If you are not an account-based reporting entity, but the transaction involves an account at an account-based reporting entity, provide that account number in this field.

†Account type

†If "Other", please specify

†Account currency

†Account virtual currency type

†If "Other", please specify

Date account opened

Date account closed

†Status of account at the time of transaction

Account holder

†Surname

†Given name

Other/Initial

†Name of entity

Involved in the completing action

‡Was there any other person or entity involved in the completing action?

Person involved in the completing action

If you have information about other persons involved in the completing action, you must include it. These persons cannot be the conductor, on behalf of party, or beneficiary of the transaction.

†Surname

†Given name

Other/Initial

Account number

Policy number

Identifying number

Entity involved in the completing action

If you have information about other entities involved in the completing action, you must include it. These entities cannot be the conductor, on behalf of party, or beneficiary to the transaction.

†Name of entity

Account number

Policy number

Identifying number

‡Beneficiary indicator

Have you obtained any beneficiary information related to this transaction or attempted transaction? (Only select No if the beneficiary is not your client and, after taking reasonable measures, you were not able to obtain any beneficiary details.)

Beneficiary

Provide beneficiary information for each completing action. A beneficiary, for example, can be the person who receives the virtual currency, the person named on a money order, or the person who receives the jewellery. The beneficiary can be the same person or entity that conducts the transaction or someone else. The beneficiary cannot be the reporting entity.

Person beneficiary

†Surname

†Given name

Other/Initial

Alias

Username

Client number

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Email address

Date of birth

Country of residence

Occupation

Name of employer

Identification of the person beneficiary

Identifier type

†If "Other", please specify

Number associated with identifier type

Jurisdiction of issue (country)

Jurisdiction of issue (province or state)

Entity beneficiary

†Name of entity

Username

Client number

Apt/Room/Suite/Unit number

House/Building number

Street address

City

District

Country

Province or state

Sub-province and/or sub-locality

Postal or zip code

Unstructured address details

Telephone number

Extension

Email address

Nature of entity's principal business

Is the entity registered or incorporated?

Incorporation number / Jurisdiction of issue (country, province or state)

Provide the incorporation number and jurisdiction of issue of the entity that is the beneficiary for each jurisdiction where the entity is incorporated.

Registration number / Jurisdiction of issue (country, province or state)

Provide the registration number and jurisdiction of issue of the entity that is the beneficiary for each jurisdiction where the entity is registered.

Identification of the entity beneficiary

Provide the following information that was used to verify the identity of the entity that is a beneficiary. For some entities, this information may be the same as the registration or incorporation information provided above.

Identifier type

†If "Other," please specify

Number associated with identifier type

Jurisdiction of issue (country)

Jurisdiction of issue (province or state)

Person authorized to bind the entity or act with respect to the account (maximum 3)

Surname

Given name

Other/Initial

Details of suspicion

**Note: The "Details of suspicion" section of the STR form must not be completed if the transaction is being reported to FINTRAC under a Ministerial Directive.

*Description of suspicious activity

This section is the narrative that explains your grounds for suspicion and should include the results of your assessment of facts, context and ML/TF indicators that led to your decision to submit an STR to FINTRAC. The narrative should not assume that the reader will be familiar with acronyms or terminology specific to your business. The narrative provided in this section should focus on the question: "Why do you think the transaction is suspicious of ML/TF?"

It is important that your narrative is consistent with the information in the structured fields of the STR form. For example, if you are referring to specific account activity in this section, the details of those accounts and transactions should be entered in the structured fields. It is also important that you do not refer to any internal files or documents since FINTRAC cannot have access to these internal files or documents for its analysis. It is also not possible to see graphics, underlined, italicized or bolded text included in an STR.

Detailed and high quality STRs provide valuable and actionable intelligence for FINTRAC and this section is shared with law enforcement and intelligence agencies in FINTRAC disclosures.

Suspicion type

Public-Private Partnership Project Name

Does this report include information about an individual who you have determined to be a politically exposed person (PEP)?

Related Reports

Are there previously submitted reports that may relate to the suspicious activity mentioned in this report?

Reporting entity report reference number

Reporting entity transaction reference number

Action taken

**Note: The "Action taken" section of the STR form must not be completed if the transaction is being reported to FINTRAC under a Ministerial Directive.

*Description of action taken

Describe the action(s) that you have taken or will be taking as a result of the suspicious transaction(s). The following are examples of actions taken:

reporting the information directly to law enforcement;
initiating enhanced transaction monitoring;
closing the account(s) in question or exiting the business relationship; and/or
cancelling, reversing or rejecting the transaction.

Reporting an STR to FINTRAC does not prevent you from contacting law enforcement directly. However, even if you do contact law enforcement directly about your suspicions of money laundering or terrorist financing, you must still submit an STR to FINTRAC. Some STRs have included the law enforcement agency's contact information in this part of the STR when the suspicion was also reported directly to law enforcement and this information can be helpful.

Annex 2 - Scenarios

Scenario 1 – Person deposits cheque and sends an email money transfer

On July 6, 2022, Gordie Gold deposited a $1,500 cheque from Iron Construction Ltd. into a joint account (with Gemma Gold) at Moon Rays Financial by using his access card at an automated banking machine (ABM). The cheque, which was payable to Gordie Gold, included the following memo line: Pay cheque—Job # 5. On the same evening, Gordie logged into online banking using his access card and sent an email money transfer (EMT) in the amount of $2,500 from his joint account with Gemma to Sunny Silver's account at Solar Bank. Sunny is not a client of Moon Rays Financial. The EMT message indicates the following: July 2022 rent. Moon Rays Financial is submitting this STR as it identified multiple indicators and determined that there is reasonable grounds to suspect the transactions are related to the commission of a money laundering offence.

General information

Information about Moon Rays Financial

Reporting entity number: The reporting entity number assigned to Moon Rays Financial when it enrolled with FWR
Reporting entity report reference number: The unique number for this report that was assigned by Moon Rays Financial or its service provider
Activity sector: Bank
Contact information for this report: Information about the person at Moon Rays Financial that FINTRAC can liaise with in the event that a follow up is required

Transaction 1 of 2

Information about transaction 1 of 2

Transaction status: Completed
Date of transaction: The date the cheque was deposited at Moon Rays Financial (July, 6, 2022)
Time of transaction: The time the cheque was deposited at Moon Rays Financial on July 6, 2022
Method of transaction: Automated banking machine
Reporting entity transaction reference number: The unique number for this transaction that was assigned by Moon Rays Financial or its service provider
Reporting entity location number: Information about where the transaction took place (ABM location)

Starting action 1 of transaction 1

Information about starting action 1 of transaction 1

Direction of starting action: In
Type of funds, assets or virtual currency (In/Out): Cheque
Amount: 1,500
Currency: CAD
Financial Institution and branch number: The financial institution and branch number indicated on the cheque
Account number: The account number indicated on the cheque
Was information about the source (person /entity) of funds or virtual currency obtained? No
Account holder: Iron Construction Ltd. (as indicated on the cheque)
Conductor information: Information about Gordie Gold including name, alias, client number, address, telephone number, email address, URL, date of birth, country of residence, country of citizenship, occupation, name and address of employer, and identification details
Was this transaction conducted or attempted on behalf of another person or entity? No

Completing action 1 of transaction 1

Information about completing action 1 of transaction 1

Details of disposition: Deposit to account
Amount: 1,500
Currency: CAD
Financial institution number and branch number: For Moon Rays Financial
Account number and account information: For the joint account of Gordie and Gemma Gold at Moon Rays Financial
Account holder: Gordie and Gemma Gold
Was there any other person or entity involved in the completing action? No
Beneficiary information: Information about Gordie and Gemma Gold including name, alias, username, client number, address, telephone number, email address, date of birth, country of residence, occupation, name of employer and identification details

Transaction 2 of 2

Information about transaction 2 of 2

Transaction status: Completed
Date of transaction: The date the online transaction was conducted (July 6, 2022)
Time of transaction: The time the online transaction was conducted on July 6, 2022
Method of transaction: Online
Reporting entity transaction reference number: The unique number for this transaction that was assigned by Moon Rays Financial or its service provider
Reporting entity location number: Information about where the transaction took place – specifically, the location number that is associated with the location that receives and initiates the client's online instructions

Starting action 1 of transaction 2

Information about starting action 1 of transaction 2

Direction of starting action: Out
Type of funds, assets or virtual currency (In/Out): Funds withdrawal
Amount: 2,500
Currency: CAD
Financial Institution and branch number: For Moon Rays Financial
Account number and account information: For the joint account of Gordie and Gemma Gold at Moon Rays Financial
Was information about the source (person /entity) of funds or virtual currency obtained? No
Account holder: Gordie and Gemma Gold
Conductor information: Information about Gordie Gold including name, alias, client number, address, telephone number, email address, URL, date of birth, country of residence, country of citizenship, occupation, name and address of employer, and identification details
Online transaction information for completed or attempted transaction: Type of device used, username, device identifier number, internet protocol address, date and time of online session
Was this transaction conducted or attempted on behalf of another person or entity? No

Completing action 1 of transaction 2

Information about completing action 1 of transaction 2

Details of disposition: Outgoing email money transfer
Amount: 2,500
Currency: CAD
Financial institution number and branch number: For Solar Bank
Account number: For the account of Sunny Silver at Solar Bark
Account holder: Sunny Silver
Was there any other person or entity involved in the completing action? No
Beneficiary information: Sunny Silver's name. Also, if obtained, information about Sunny Silver including alias, username, client number, address, telephone number, email address, date of birth, country of residence, occupation, name of employer and identification details

Details of Suspicion

The description of the facts, context and indicators that allowed Moon Rays Financial to establish that there are reasonable grounds to suspect that the transaction(s) are related to the commission of a money laundering offence.

In this scenario, this could include the information from the cheque memo line (Pay cheque—Job # 5) and the EMT message (July 2022 rent).

Action taken

The action that Moon Rays Financial has taken as a result of the suspicious transaction(s).

**Note:

If the conductor (Gordie Gold) has multiple email addresses, provide the email address that conductor used to send the EMT in the email address field for the conductor. Gordie's other email addresses can be provided in the narrative section of the report (Details of suspicion). The beneficiary email address field should be the email address that was used by the beneficiary to receive the EMT.

Scenario 2 – Entity exchanges cash to virtual currency and transfers to wallet

On July 7, 2022, Gordie Gold walked into Cosmic Virtual Currency Money Service Business (Cosmic VC MSB) with $9,997 CAD cash. Gordie advised Cosmic VC MSB that he is representing Gordie's Painting Inc.—a company in which he is the CEO and sole director and shareholder. Gordie also advised Cosmic VC MSB that the cash was payment from a recently sold painting to a client, Sunny Silver. Gordie requested that the cash be exchanged to Ethereum (ETH) so that it could be added to Cosmic VC MSB's custodial virtual currency wallet. The virtual currency exchange rate was 0.0007. Gordie then requested the ETH be transferred to his personal external virtual currency wallet which was later identified as being associated with darknet market activity. Cosmic VC MSB is submitting this STR as it identified multiple indicators and determined that there is reasonable grounds to suspect the transaction is related to the commission of a money laundering offence.

General information

Information about Cosmic VC MSB

Reporting entity number: The reporting entity number assigned to Cosmic VC MSB when it enrolled with FWR
Reporting entity report reference number: The unique number for this report that was assigned by Cosmic VC MSB or its service provider
Activity sector: Money services business
Contact information for this report: Information about the person at Cosmic VC MSB that FINTRAC can liaise with in the event that a follow up is required

Transaction 1 of 1

Information about transaction 1 of 1

Transaction status: Completed
Date of transaction: The date the cash was received by Cosmic VC MSB (July, 7, 2022)
Time of transaction: The time the cash was received by Cosmic VC MSB on July 7, 2022
Method of transaction: In person
Reporting entity transaction reference number: The unique number for this transaction that was assigned by Cosmic VC MSB or its service provider
Reporting entity location number: Information about where the transaction took place

Starting action 1 of transaction 1

Information about starting action 1 of transaction 1

Direction of starting action: In
Type of funds, assets or virtual currency (In/Out): Cash
Amount: 9,997
Currency: CAD
How were the funds or virtual currency obtained? Gordie Gold advised that he received the cash when he sold a painting to his client, Sunny Silver
Was information about the source (person /entity) of funds or virtual obtained? Yes
Source of funds or virtual currency: Sunny Silver
Conductor information: Information about Gordie's Painting Inc. including name, client number, address, telephone number, email address, URL, and identification details
Additional information about the conductor if it is an entity: Person(s) authorized to bind the entity (Gordie Gold), type of entity (corporation), nature of entity's principal business (painting/contracting), incorporation and/or registration information, director(s) of the corporation (Gordie Gold), person(s) who directly or indirectly owns or controls 25% or more shares of the corporation (Gordie Gold)
Was this transaction conducted or attempted on behalf of another person or entity? No

Completing action 1 of transaction 1

Information about completing action 1 of transaction 1

Details of disposition: Exchange to virtual currency
Amount: 7
Virtual currency type: ETH
Exchange rate: .0007
Was there any other person or entity involved in the completing action? No
Beneficiary information: Information about Gordie's Painting Inc. including name, username, client number, address, telephone number, email address, nature of entity's principal business (painting/contracting), incorporation and/or registration information, identification details, person(s) authorized to bind the entity (Gordie Gold)

Completing action 2 of transaction 1

Information about completing action 2 of transaction 1

Details of disposition: Added to virtual currency wallet
Amount: 7
Virtual currency type: ETH
Virtual currency transaction identifier: The unique identifier for this transaction (completing action 2) that is commonly represented by a hash consisting of mixed numerical and alphabetical characters
Receiving virtual currency address: The virtual currency address for Cosmic VC MSB as it received the virtual currency
Was there any other person or entity involved in the completing action? No
Beneficiary information: Information about Gordie's Painting Inc. including name, username, client number, address, telephone number, email address, nature of entity's principal business (painting/contracting), incorporation and/or registration information, identification details, person(s) authorized to bind the entity (Gordie Gold)

Completing action 3 of transaction 1

Information about completing action 3 of transaction 1

Details of disposition: Outgoing virtual currency transfer
Amount: 7
Virtual currency type: ETH
Virtual currency transaction identifier: The unique identifier for this transaction (completing action 3) that is commonly represented by a hash consisting of mixed numerical and alphabetical characters
Receiving virtual currency address: The virtual currency address for Gordie Gold as he received the virtual currency in his personal wallet
Was there any other person or entity involved in the completing action? No
Beneficiary information: Information about Gordie Gold including name, alias, username, client number, address, telephone number, email address, date of birth, country of residence, occupation, name of employer and identification details

Details of Suspicion

The description of the facts, context and indicators that allowed Cosmic VC MSB to establish that there are reasonable grounds to suspect that the transaction(s) are related to the commission of a money laundering offence.

Action taken

The action that Cosmic VC MSB has taken as a result of the suspicious transaction(s).

Scenario 3 – Person deposits on behalf of another person who later purchases casino chips and then redeems these chips

On July 8th, 2022, Gordie Gold came into Vega Casino to deposit $9,000 cash on behalf of Sunny Silver. The cash was deposited into Sunny's account and Gordie advised the casino that he and Sunny were friends. The casino, however, was not able to obtain information about the purpose of the transaction or the source of funds. On July 9th, 2022 Sunny purchased casino chips at Vega Casino using funds in her casino account totaling $9,000. After leaving the front desk, Sunny was seen passing the chips to Chuck who is an individual known to the casino. Within an hour, Sunny returned to the front desk to redeem the remaining casino chips and requested a cheque payable to herself totaling $5,000. Vega Casino is submitting this STR as it identified multiple indicators and determined that there is reasonable grounds to suspect the transactions are related to the commission of a money laundering offence.

General information

Information about Vega Casino

Reporting entity number: The reporting entity number assigned to Vega Casino when it enrolled with FWR
Reporting entity report reference number: The unique number for this report that was assigned by Vega Casino or its service provider
Activity sector: Casino
Contact information for this report: Information about the person at Vega Casino that FINTRAC can liaise with in the event that a follow up is required

Transaction 1 of 3

Information about transaction 1 of 3

Transaction status: Completed
Date of transaction: The date Vega Casino received the cash from Gordie Gold (July 8, 2022)
Time of transaction: The time Vega Casino received the cash on July 8, 2022
Method of transaction: In person
Reporting entity transaction reference number: The unique number for this transaction that was assigned by Vega Casino or its service provider
Reporting entity location number: Information about where the transaction took place

Starting action 1 of transaction 1

Information about starting action 1 of transaction 1

Direction of starting action: In
Type of funds, assets or virtual currency (In/Out): Cash
Amount: 9,000
Currency: CAD
Was information about the source (person /entity) of funds or virtual currency obtained? No
Conductor information: Information about Gordie Gold including name, alias, client number, address, telephone number, email address, URL, date of birth, country of residence, country of citizenship, occupation, name and address of employer, and identification details
Was this transaction conducted or attempted on behalf of another person or entity? Yes
Information about the person on whose behalf the transaction is conducted or attempted: Information about Sunny Silver including name, alias, client number, address, telephone number, URL, email address, date of birth, country of residence, country of citizenship, occupation, name and address of employer and identification details
Relationship of the person named above to the person or entity conducting or attempting to conduct the transaction: Friend

Completing action 1 of transaction 1

Information about completing action 1 of transaction 1

Details of disposition: Deposit to account
Amount: 9,000
Currency: CAD
Account number and account information: For Sunny Silver's account at Vega Casino
Account holder: Sunny Sliver
Was there any other person or entity involved in the completing action? No
Beneficiary information: Information about Sunny Silver including name, alias, username, client number, address, telephone number, email address, date of birth, country of residence, occupation, name of employer and identification details

Transaction 2 of 3

Information about transaction 2 of 3

Transaction status: Completed
Date of transaction: The date the casino chips were purchased (July 9, 2022)
Time of transaction: The time the casino chips were purchased on July 9, 2022
Method of transaction: In person
Reporting entity transaction reference number: The unique number for this transaction that was assigned by Vega Casino or its service provider
Reporting entity location number: Information about where the transaction took place

Starting action 1 of transaction 2

Information about starting action 1 of transaction 2

Direction of starting action: Out
Type of funds, assets or virtual currency (In/Out): Funds withdrawal
Amount: 9,000
Currency: CAD
Account number and account information: For Sunny Silver's account at Vega Casino
Was information about the source (person /entity) of funds or virtual currency obtained? No
Account holder: Sunny Sliver
Conductor information: Information about Sunny Silver including name, alias, client number, address, telephone number, email address, URL, date of birth, country of residence, country of citizenship, occupation, name and address of employer, and identification details
Was this transaction conducted or attempted on behalf of another person or entity? No

Completing action 1 of transaction 2

Information about completing action 1 of transaction 2

Details of disposition: Purchase of casino product
Amount: 9,000
Currency: CAD
Was there any other person or entity involved in the completing action? Yes
Name of other person involved: Chuck
Beneficiary information: Information about Sunny Silver including name, alias, username, client number, address, telephone number, email address, date of birth, country of residence, occupation, name of employer and identification details

Transaction 3 of 3

Information about transaction 3 of 3

Transaction status: Completed
Date of transaction: The date the casino chips were redeemed (July 9, 2022)
Time of transaction: The time the casino chips were redeemed on July 9, 2022
Method of transaction: In person
Reporting entity transaction reference number: The unique number for this transaction that was assigned by Vega Casino or its service provider
Reporting entity location number: Information about where the transaction took place

Starting action 1 of transaction 3

Information about starting action 1 of transaction 3

Direction of starting action: In
Type of funds, assets or virtual currency (In/Out): Casino product
Amount: 5,000
Currency: CAD
Was information about the source (person /entity) of funds or virtual currency obtained? No
Conductor information: Information about Sunny Silver including name, alias, client number, address, telephone number, email address, URL, date of birth, country of residence, country of citizenship, occupation, name and address of employer, and identification details
Was this transaction conducted or attempted on behalf of another person or entity? No

Completing action 1 of transaction 3

Information about completing action 1 of transaction 3

Details of disposition: Issued cheque
Amount: 5,000
Currency: CAD
Was there any other person or entity involved in the completing action? No
Beneficiary information: Information about Sunny Silver including name, alias, username, client number, address, telephone number, email address, date of birth, country of residence, occupation, name of employer and identification details

Details of Suspicion

The description of the facts, context and indicators that allowed Vega Casino to establish that there are reasonable grounds to suspect that the transaction(s) are related to the commission of a money laundering offence.

Action taken

The action that Vega Casino has taken as a result of the suspicious transaction(s).

Scenario 4 – Person transfers funds between accounts and pays utility bill and credit card

On July 9th, 2022, Gordie Gold logged into online banking at Moon Rays Financial using his access card and does the following:

transfers $1,500 from his joint account with Gemma Gold to his own personal account—and both accounts are held at Moon Rays Financial
pays an electric bill to ABC Electric Company (billing account reference number 12345-678) for $500 using funds from his own personal account
pays a credit card account balance of $1,000 to ABC Credit Card Company (credit card number 1234-5678-1234-5678) using funds from his personal account

Moon Rays Financial is submitting this STR as it identified multiple indicators and determined that there is reasonable grounds to suspect the transactions are related to the commission of a money laundering offence.

General information

Information about Moon Rays Financial

Reporting entity number: The reporting entity number assigned to Moon Rays Financial when it enrolled with FWR
Reporting entity report reference number: The unique number for this report that was assigned by Moon Rays Financial or its service provider
Activity sector: Bank
Contact information for this report: Information about the person at Moon Rays Financial that FINTRAC can liaise with in the event that a follow up is required

Transaction 1 of 3

Information about transaction 1 of 3

Transaction status: Completed
Date of transaction: The date the online transaction was conducted (July 9, 2022)
Time of transaction: The time the online transaction was conducted on July 9, 2022
Method of transaction: Online
Reporting entity transaction reference number: The unique number for this transaction that was assigned by Moon Rays Financial or its service provider
Reporting entity location number: Information about where the transaction took place–specifically, the location number that is associated with the location that receives and initiates the client's online instructions

Starting action 1 of transaction 1

Information about starting action 1 of transaction 1

Direction of starting action: Out
Type of funds, assets or virtual currency (In/Out): Funds withdrawal
Amount: 1,500
Currency: CAD
Financial Institution and branch number: For Moon Rays Financial
Account number and account information: For the joint account of Gordie and Gemma Gold at Moon Rays Financial
Was information about the source (person /entity) of funds or virtual currency obtained? No
Account holder: Gordie and Gemma Gold
Conductor information: Information about Gordie Gold including name, alias, client number, address, telephone number, email address, URL, date of birth, country of residence, country of citizenship, occupation, name and address of employer, and identification details
Online transaction information for completed or attempted transaction: Type of device used, username, device identifier number, internet protocol address, date and time of online session
Was this transaction conducted or attempted on behalf of another person or entity? No

Completing action 1 of transaction 1

Information about completing action 1 of transaction 1

Details of disposition: Outgoing domestic funds transfer
Amount: 1,500
Currency: CAD
Financial Institution and branch number: For Moon Rays Financial
Account number and account information: For Gordie Gold's personal account at Moon Rays Financial
Account holder: Gordie Gold
Was there any other person or entity involved in the completing action? No
Beneficiary information: Information about Gordie Gold including name, alias, username, client number, address, telephone number, email address, date of birth, country of residence, occupation, name of employer and identification details

Transaction 2 of 3

Information about transaction 2 of 3

Transaction status: Completed
Date of transaction: The date the online transaction was conducted (July 9, 2022)
Time of transaction: The time the online transaction was conducted on July 9, 2022
Method of transaction: Online
Reporting entity transaction reference number: The unique number for this transaction that was assigned by Moon Rays Financial or its service provider
Reporting entity location number: Information about where the transaction took place–specifically, the location number that is associated with the location that receives and initiates the client's online instructions

Starting action 1 of transaction 2

Information about starting action 1 of transaction 2

Direction of starting action: Out
Type of funds, assets or virtual currency (In/Out): Funds withdrawal
Amount: 500
Currency: CAD
Financial Institution and branch number: For Moon Rays Financial
Account number and account information: For Gordie Gold's personal account at Moon Rays Financial
Was information about the source (person /entity) of funds or virtual currency obtained? No
Account holder: Gordie Gold
Conductor information: Information about Gordie Gold including name, alias, client number, address, telephone number, email address, URL, date of birth, country of residence, country of citizenship, occupation, name and address of employer, and identification details
Online transaction information for completed or attempted transaction: Type of device used, username, device identifier number, internet protocol address, date and time of online session
Was this transaction conducted or attempted on behalf of another person or entity? No

Completing action 1 of transaction 2

Information about completing action 1 of transaction 2

Details of disposition: Purchase of / Payment of services
Amount: 500
Currency: CAD
Reference number: 12345-678 (the reference number associated with the bill payment)
Was there any other person or entity involved in the completing action? No
Beneficiary information: ABC Electric Company's name. Also, if obtained, information about ABC Electric Company including username, client number, address, telephone number, email address, nature of entity's principal business (utility company), incorporation and/or registration information, identification details, person(s) authorized to bind the entity

Transaction 3 of 3

Information about transaction 3 of 3

Transaction status: Completed
Date of transaction: The date the online transaction was conducted (July 9, 2022)
Time of transaction: The time the online transaction was conducted on July 9, 2022
Method of transaction: Online
Reporting entity transaction reference number: The unique number for this transaction that was assigned by Moon Rays Financial or its service provider
Reporting entity location number: Information about where the transaction took place—specifically, the location number that is associated with the location that receives and initiates the client's online instructions

Starting action 1 of transaction 3

Information about starting action 1 of transaction 3

Direction of starting action: Out
Type of funds, assets or virtual currency (In/Out): Funds withdrawal
Amount: 1,000
Currency: CAD
Financial Institution and branch number: For Moon Rays Financial
Account number and account information: For Gordie Gold's personal account at Moon Rays Financial
Was information about the source (person /entity) of funds or virtual currency obtained? No
Account holder: Gordie Gold
Conductor information: Information about Gordie Gold including name, alias, client number, address, telephone number, email address, URL, date of birth, country of residence, country of citizenship, occupation, name and address of employer, and identification details
Online transaction information for completed or attempted transaction: Type of device used, username, device identifier number, internet protocol address, date and time of online session
Was this transaction conducted or attempted on behalf of another person or entity? No

Completing action 1 of transaction 3

Information about completing action 1 of transaction 3

Details of disposition: Payment to account
Amount: 1,000
Currency: CAD
Account number: 1234-5678-1234-5678 (the credit card number for the credit card account in which payment was made to)
Was there any other person or entity involved in the completing action? No
Beneficiary information: ABC Credit Card Company's name. Also, if obtained, information about ABC Credit Card Company including username, client number, address, telephone number, email address, nature of entity's principal business (credit card company), incorporation and/or registration information, identification details, person(s) authorized to bind the entity

Details of Suspicion

Action taken

The action that Moon Rays Financial has taken as a result of the suspicious transaction(s).

Details and history

Published: December 2022

For assistance

If you have questions about this guidance, please contact FINTRAC by email at guidelines-lignesdirectrices@fintrac-canafe.gc.ca.

Footnote 1

Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), S.C. 2000, c. 17, s. 10.

Return to footnote 1 referrer

Footnote 2

PCMLTFA, S.C. 2000, c. 17, s. 8.

Return to footnote 2 referrer

Footnote 3

PCMLTFA, S.C. 2000, c. 17, s.7.

Return to footnote 3 referrer

Footnote 4

Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations (PCMLTFSTRR), SOR/2001-317, s. 9(2).

Return to footnote 4 referrer

Footnote 5

PCMLTFSTRR, SOR/2001-317, s.12.

Return to footnote 5 referrer

Footnote 6

PCMLTFSTRR, SOR/2001-317, s. 12.1(1).

Return to footnote 6 referrer

Footnote 7

Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), SOR/2002-184, s. 85(1).

Return to footnote 7 referrer

Footnote 8

PCMLTFR, SOR/2002-184, s 85(2).

Return to footnote 8 referrer

Footnote 9

PCMLTFSTRR, SOR/2001-317, s. 11(2).

Return to footnote 9 referrer

Footnote 10

PCMLTFSTRR, SOR/2001-317, s. 11(1) and 11(3).

Return to footnote 10 referrer

Definitions

Accountant

A chartered accountant, a certified general accountant, a certified management accountant or, if applicable, a chartered professional accountant. (comptable)

Reference:
Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), SOR/2002-184, s. 1(2).

Accounting firm

An entity that is engaged in the business of providing accounting services to the public and has at least one partner, employee or administrator that is an accountant. (cabinet d'expertise comptable)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Act

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). (la Loi)

Reference:
Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations (PCMLTFAMPR), SOR/2007-292, s. 1, Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations (PCMLTFRR), SOR/2007-121, s. 1, PCMLTFR, SOR/2002-184, s. 1(2), and Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations (PCMLTFSTRR), SOR/2001-317, s. 1(2).

Administrative monetary penalties (AMPs)

Civil penalties that may be issued to reporting entities by FINTRAC for non-compliance with the PCMLTFA and associated Regulations. (pénalité administrative pécuniaire [PAP])

Affiliate

An entity is affiliated with another entity if one of them is wholly owned by the other, if both are wholly owned by the same entity or if their financial statements are consolidated. (entité du même groupe)

Reference:
PCMLTFR, SOR/2002-184, s. 4.

Annuity

Has the same meaning as in subsection 248(1) of the Income Tax Act. (rente)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

As soon as practicable

A time period that falls in-between immediately and as soon as possible, within which a suspicious transaction report (STR) must be submitted to FINTRAC. The completion and submission of the STR should take priority over other tasks. In this context, the report must be completed promptly, taking into account the facts and circumstances of the situation. While some delay is permitted, it must have a reasonable explanation. (aussitôt que possible)

Attempted transaction

Occurs when an individual or entity starts to conduct a transaction that is not completed. For example, a client or a potential client walks away from conducting a $10,000 cash deposit. (opération tentée)

Authentic

In respect of verifying identity, means genuine and having the character of an original, credible, and reliable document or record. (authentique)

Authorized person

A person who is authorized under subsection 45(2). (personne autorisée)

Reference:
Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), S.C. 2000, c 17, s. 2(1).

Authorized user

A person who is authorized by a holder of a prepaid payment product account to have electronic access to funds or virtual currency available in the account by means of a prepaid payment product that is connected to it. (utilisateur autorisé)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Beneficial owner(s)

Beneficial owners are the individuals who are the trustees, and known beneficiaries and settlors of a trust, or who directly or indirectly own or control 25% or more of i) the shares of a corporation or ii) an entity other than a corporation or trust, such as a partnership. The ultimate beneficial owner(s) cannot be another corporation or entity; it must be the actual individual(s) who owns or controls the entity. (bénéficiaire effectif)

Beneficiary

A beneficiary is the individual or entity that will benefit from a transaction or to which the final remittance is made. (bénéficiaire)

Branch

A branch is a part of your business at a distinct location other than your main office. (succursale)

British Columbia notary corporation

An entity that carries on the business of providing notary services to the public in British Columbia in accordance with the Notaries Act, R.S.B.C. 1996, c. 334. (société de notaires de la Colombie-Britannique)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

British Columbia notary public

A person who is a member of the Society of Notaries Public of British Columbia. (notaire public de la Colombie-Britannique)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Cash

Coins referred to in section 7 of the Currency Act, notes issued by the Bank of Canada under the Bank of Canada Act that are intended for circulation in Canada or coins or bank notes of countries other than Canada. (espèces)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2).

Casino

A government, organization, board or operator that is referred to in any of paragraphs 5(k) to (k.3) of the Act. (casino)

Reference:
PCMLTFR, SOR/2002-184, s 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2).

Certified translator

An individual that holds the title of professional certified translator granted by a Canadian provincial or territorial association or body that is competent under Canadian provincial or territorial law to issue such certification. (traducteur agréé)

Clarification request

A clarification request is a method used to communicate with money services businesses (MSBs) or foreign money services businesses (FMSBs) when FINTRAC needs more information about their registration form. This request is usually sent by email. (demande de précisions)

Client

A person or entity that engages in a financial transaction with another person or entity. (client)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Client identification information

The identifying information that you have obtained on your clients, such as name, address, telephone number, occupation or nature of principal business, and date of birth for an individual. (renseignements d'identification du client)

Competent authority

For the purpose of the criminal record check submitted with an application for registration, a competent authority is any person or organization that has the legally delegated or invested authority, capacity, or power to issue criminal record checks. (autorité compétente)

Completed transaction

Is a transaction conducted by a person or entity, that is completed and results in the movement of funds, virtual currency, or the purchase or sale of an asset. (opération effectuée)

Completing action

With respect to a reportable transaction, information related to the instructions provided by the person or entity making the request to the reporting entity to complete a transaction. For example, an individual arrives at a bank and requests to purchase a bank draft. The completing action is the details of how the reporting entity fulfilled the person or entity’s instructions which led to the transaction being completed. This includes what the funds or virtual currency initially brought to the reporting entity was used for (see “disposition”). A transaction may have one or more completing actions depending on the instructions provided by the person or entity. (action d’achèvement)

Compliance officer

The individual, with the necessary authority, that you appoint to be responsible for the implementation of your compliance program. (agent de conformité)

Compliance policies and procedures

Written methodology outlining the obligations applicable to your business under the PCMLTFA and its associated Regulations and the corresponding processes and controls you put in place to address your obligations. (politiques et procédures de conformité)

Compliance program

All elements (compliance officer, policies and procedures, risk assessment, training program, effectiveness review) that you, as a reporting entity, are legally required to have under the PCMLTFA and its associated Regulations to ensure that you meet all your obligations. (programme de conformité)

Context

Clarifies a set of circumstances or provides an explanation of a situation or financial transaction that can be understood and assessed. (contexte)

Correspondent banking relationship

A relationship created by an agreement or arrangement under which an entity referred to in any of paragraphs 5(a), (b), (d),(e) and (e.1) or an entity that is referred to in section 5 and that is prescribed undertakes to provide to a prescribed foreign entity prescribed services or international electronic funds transfers, cash management or cheque clearing services. (relation de correspondant bancaire)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 9.4(3) and PCMLTFR, SOR/2002-184, s. 16(1)(b).

Country of residence

The country where an individual has lived continuously for 12 months or more. The individual must have a dwelling in the country concerned. For greater certainty, a person only has one country of residence no matter how many dwelling places they may have, inside or outside of that country. (pays de résidence)

Credit card acquiring business

A credit card acquiring business is a financial entity that has an agreement with a merchant to provide the following services:

enabling a merchant to accept credit card payments by cardholders for goods and services and to receive payments for credit card purchases;
processing services, payment settlements and providing point-of-sale equipment (such as computer terminals); and
providing other ancillary services to the merchant.

(entreprise d'acquisition de cartes de crédit)

Credit union central

A central cooperative credit society, as defined in section 2 of the Cooperative Credit Associations Act, or a credit union central or a federation of credit unions or caisses populaires that is regulated by a provincial Act other than one enacted by the legislature of Quebec. (centrale de caisses de crédit)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Crowdfunding platform

A website or an application or other software that is used to raise funds or virtual currency through donations. (plateforme de sociofinancement)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Crowdfunding platform services

The provision and maintenance of a crowdfunding platform for use by other persons or entities to raise funds or virtual currency for themselves or for persons or entities specified by them. (services de plateforme de sociofinancement)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Current

In respect of a document or source of information that is used to verify identity, is up to date, and, in the case of a government-issued photo identification document, must not have been expired when the ID was verified. (à jour)

Dealer in precious metals and stones

A person or entity that, in the course of their business activities, buys or sells precious metals, precious stones or jewellery. It includes a department or an agent of His Majesty in right of Canada or an agent or mandatary of His Majesty in right of a province when the department or the agent or mandatary carries out the activity, referred to in subsection 65(1), of selling precious metals to the public. (négociant en métaux précieux et pierres précieuses)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Deferred profit sharing plan

Has the same meaning as in subsection 248(1) of the Income Tax Act. (régime de participation différée aux bénéfices)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Deposit slip

A record that sets out:

(a) the date of the deposit;
(b) the name of the person or entity that makes the deposit;
(c) the amount of the deposit and of any part of it that is made in cash;
(d) the method by which the deposit is made; and
(e) the number of the account into which the deposit is made and the name of each account holder.

(relevé de dépôt)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Directing services

A business is directing services at persons or entities in Canada if at least one of the following applies:

The business's marketing or advertising is directed at persons or entities located in Canada;
The business operates a ".ca" domain name; or,
The business is listed in a Canadian business directory.

Additional criteria may be considered, such as if the business describes its services being offered in Canada or actively seeks feedback from persons or entities in Canada. (diriger des services)

Distributed ledger

For the purpose of section 151 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), a digital ledger that is maintained by multiple persons or entities and that can only be modified by a consensus of those persons or entities. (registres distribués)

Reference:
PCMLTFR, SOR/2002-184, s. 151(2).

Disposition

With respect to a reportable transaction, the disposition is what the funds or virtual currency was used for. For example, an individual arrives at a bank with cash and purchases a bank draft. The disposition is the purchase of the bank draft. (répartition)

Electronic funds transfer

The transmission—by any electronic, magnetic or optical means—of instructions for the transfer of funds, including a transmission of instructions that is initiated and finally received by the same person or entity. In the case of SWIFT messages, only SWIFT MT-103 messages and their equivalent are included. It does not include a transmission or instructions for the transfer of funds:

(a) that involves the beneficiary withdrawing cash from their account;
(b) that is carried out by means of a direct deposit or pre-authorized debit;
(c) that is carried out by cheque imaging and presentment
(d) that is both initiated and finally received by persons or entities that are acting to clear or settle payment obligations between themselves; or
(e) that is initiated or finally received by a person or entity referred to in paragraphs 5(a) to (h.1) of the Act for the purpose of internal treasury management, including the management of their financial assets and liabilities, if one of the parties to the transaction is a subsidiary of the other or if they are subsidiaries of the same corporation.

(télévirement)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Employees profit sharing plan

Has the same meaning as in subsection 248(1) of the Income Tax Act. (régime de participation des employés aux bénéfices)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Entity

A body corporate, a trust, a partnership, a fund or an unincorporated association or organization. (entité)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Facts

Actual events, actions, occurrences or elements that exist or are known to have happened or existed. Facts are not opinions. For example, facts surrounding a transaction or multiple transactions could include the date, time, location, amount or type of transaction or could include the account details, particular business lines, or the client's financial history. (faits)

Family member

For the purposes of subsection 9.3(1) of the Act, a prescribed family member of a politically exposed foreign person, a politically exposed domestic person or a head of an international organization is:

(a) their spouse or common-law partner;
(b) their child;
(c) their mother or father;
(d) the mother or father of their spouse or common-law partner; or
(e) a child of their mother or father.

(membre de la famille)

Reference:
PCMLTFR, SOR/2002-184, s. 2(1).

Fiat currency

A currency that is issued by a country and is designated as legal tender in that country. (monnaie fiduciaire)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2).

Final receipt

In respect of an electronic funds transfer, means the receipt of the instructions by the person or entity that is to make the remittance to a beneficiary. (destinataire)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Financial entity

Means:

(a) an entity that is referred to in any of paragraphs 5(a), (b) and (d) to (f) of the Act;
(b) a financial services cooperative;
(c) a life insurance company, or an entity that is a life insurance broker or agent, in respect of loans or prepaid payment products that it offers to the public and accounts that it maintains with respect to those loans or prepaid payment products, other than:
1. (i) loans that are made by the insurer to a policy holder if the insured person has a terminal illness that significantly reduces their life expectancy and the loan is secured by the value of an insurance policy;
2. (ii) loans that are made by the insurer to the policy holder for the sole purpose of funding the life insurance policy; and
3. (iii) advance payments to which the policy holder is entitles that are made to them by the insurer;
(d) a credit union central when it offers financial services to a person, or to an entity that is not a member of that credit union central; and
(e) a department, or an entity that is an agent of His Majesty in right of Canada or an agent or mandatary of His Majesty in right of a province, when it carries out an activity referred to in section 76.

(entité financière)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Financial Action Task Force

The Financial Action Task Force on Money Laundering established in 1989. (Groupe d'action financière)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Financial services cooperative

A financial services cooperative that is regulated by an Act respecting financial services cooperatives, CQLR, c. C-67.3, other than a caisse populaire. (coopérative de services financiers)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Foreign currency

A fiat currency that is issued by a country other than Canada. (devise)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Foreign currency exchange transaction

An exchange, at the request of another person or entity, of one fiat currency for another. (opération de change en devise)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Foreign currency exchange transaction ticket

A record respecting a foreign currency exchange transaction—including an entry in a transaction register—that sets out:

(a) the date of the transaction;
(b) in the case of a transaction of $3,000 or more, the name and address of the person or entity that requests the exchange, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
(c) the type and amount of each of the fiat currencies involved in the payment made and received by the person or entity that requests the exchange;
(d) the method by which the payment is made and received;
(e) the exchange rates used and their source;
(f) the number of every account that is affected by the transaction, the type of account and the name of each account holder; and
(g) every reference number that is connected to the transaction and has a function equivalent to that of an account number.

(fiche d'opération de change en devise)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Foreign money services business

Persons and entities that do not have a place of business in Canada, that are engaged in the business of providing at least one of the following services that is directed at persons or entities in Canada, and that provide those services to their clients in Canada:

(i) foreign exchange dealing,
(ii) remitting funds or transmitting funds by any means or through any person, entity or electronic funds transfer network,
(iii) issuing or redeeming money orders, traveller's cheques or other similar negotiable instruments except for cheques payable to a named person or entity,
(iv) dealing in virtual currencies, or
(v) any prescribed service.

(entreprise de services monétaires étrangère)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 5(h.1), PCMLTFRR, SOR/2007-121, s. 1 and PCMLTFR, SOR/2002-184, s. 1(2).

Foreign state

Except for the purposes of Part 2, means a country other than Canada and includes any political subdivision or territory of a foreign state. (État étranger)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Funds

Means:

(a) cash and other fiat currencies, and securities, negotiable instruments or other financial instruments that indicate a title or right to or interest in them; or
(b) a private key of a cryptographic system that enables a person or entity to have access to a fiat currency other than cash.

For greater certainty, it does not include virtual currency. (fonds)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2).

Head of an international organization

A person who, at a given time, holds—or has held within a prescribed period before that time—the office or position of head of

a) an international organization that is established by the governments of states;
b) an institution of an organization referred to in paragraph (a); or
c) an international sports organization.

(dirigeant d'une organisation internationale)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 9.3(3).

Immediately

In respect of submitting a Terrorist Property Report (TPR), the time period within which a TPR must be submitted, which does not allow for any delay prior to submission. (immédiatement)

Information record

A record that sets out the name and address of a person or entity and:

(a) in the case of a person, their date of birth and the nature of their principal business or their occupation; and
(b) in the case of an entity, the nature of its principal business.

(dossier de renseignements)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Initiation

In respect of an electronic funds transfer, means the first transmission of the instructions for the transfer of funds. (amorcer)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Institutional trust

For the purpose of section 15 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), means a trust that is established by a corporation or other entity for a particular business purpose and includes a pension plan trust, a pension master trust, a supplemental pension plan trust, a mutual fund trust, a pooled fund trust, a registered retirement savings plan trust, a registered retirement income fund trust, a registered education savings plan trust, a group registered retirement savings plan trust, a deferred profit sharing plan trust, an employee profit sharing plan trust, a retirement compensation arrangement trust, an employee savings plan trust, a health and welfare trust, an unemployment benefit plan trust, a foreign insurance company trust, a foreign reinsurance trust, a reinsurance trust, a real estate investment trust, an environmental trust and a trust established in respect of endowment, a foundation or a registered charity. (fiducie institutionnelle)

Reference:
PCMLTFR, SOR/2002-184, s. 15(2).

International electronic funds transfer

An electronic funds transfer other than for the transfer of funds within Canada. (télévirement international)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Inter vivos trust

A personal trust, other than a trust created by will. (fiducie entre vifs)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Jewellery

Objects that are made of gold, silver, palladium, platinum, pearls or precious stones and that are intended to be worn as a personal adornment. (bijou)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Large cash transaction record

A record that indicates the receipt of an amount of $10,000 or more in cash in a single transaction and that contains the following information:

(a) the date of the receipt;
(b) if the amount is received for deposit into an account, the number of the account, the name of each account holder and the time of the deposit or an indication that the deposit is made in a night deposit box outside the recipient's normal business hours;
(c) the name and address of every other person or entity that is involved in the transaction, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
(d) the type and amount of each fiat currency involved in the receipt;
(e) the method by which the cash is received;
(f) if applicable, the exchange rates used and their source;
(g) the number of every other account that is affected by the transaction, the type of account and the name of each account holder
(h) every reference number that is connected to the transaction and has a function equivalent to that of an account number;
(i) the purpose of the transaction;
(j) the following details of the remittance of, or in exchange for, the cash received:
1. (i) the method of remittance;
2. (ii) if the remittance is in funds, the type and amount of each type of funds involved;
3. (iii) if the remittance is not in funds, the type of remittance and its value, if different from the amount of cash received; and
4. (iv) the name of every person or entity involved in the remittance and their account number or policy number or, if they have no account number or policy number, their identifying number; and
(k) if the amount is received by a dealer in precious metals and precious stones for the sale of precious metals, precious stones or jewellery:
1. (i) the type of precious metals, precious stones or jewellery;
2. (ii) the value of the precious metals, precious stones or jewellery, if different from the amount of cash received, and
3. (iii) the wholesale value of the precious metals, precious stones or jewellery.

(relevé d'opération importante en espèces)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Large virtual currency transaction record

A record that indicates the receipt of an amount of $10,000 or more in virtual currency in a single transaction and that contains the following information:

(a) the date of the receipt;
(b) if the amount is received for deposit into an account, the name of each account holder;
(c) the name and address of every other person or entity that is involved in the transaction, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
(d) the type and amount of each virtual currency involved in the receipt;
(e) the exchange rates used and their source;
(f) the number of every other account that is affected by the transaction, the type of account and the name of each account holder;
(g) every reference number that is connected to the transaction and has a function equivalent to that of an account number;
(h) every transaction identifier, including the sending and receiving addresses; and
(i) if the amount is received by a dealer in precious metals and precious stones for the sale of precious metals, precious stones or jewellery:
1. (i) the type of precious metals, precious stones or jewellery;
2. (ii) the value of the precious metals, precious stones or jewellery, if different from the amount of virtual currency received; and
3. (iii) the wholesale value of the precious metals, precious stones or jewellery.

(relevé d'opération importante en monnaie virtuelle)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Life insurance broker or agent

A person or entity that is authorized under provincial legislation to carry on the business of arranging contracts of life insurance. (représentant d'assurance-vie)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Life insurance company

A life company or foreign life company to which the Insurance Companies Act applies or a life insurance company regulated by a provincial Act. (société d'assurance-vie)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Listed person

Has the same meaning as in section 1 of the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism. (personne inscrite)

Reference:
PCMLTFSTRR, SOR/2001-317, s. 1(2).

Managing general agents (MGAs)

Life insurance brokers or agents that act as facilitators between other life insurance brokers or agents and life insurance companies. MGAs typically offer services to assist with insurance agents contracting and commission payments, facilitate the flow of information between insurer and agent, and provide training to, and compliance oversight of, insurance agents. (agent général de gestion)

Mandatary

A person who acts, under a mandate or agreement, for another person or entity. (mandataire)

Marketing or advertising

When a person or entity uses promotional materials such as advertisements, graphics for websites or billboards, etc., with the intent to promote money services business (MSB) services and to acquire business from persons or entities in Canada. (marketing ou publicité)

Minister

In relation to sections 24.1 to 39, the Minister of Public Safety and Emergency Preparedness and, in relation to any other provision of this Act, the Minister of Finance. (ministre)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Money laundering offence

An offence under subsection 462.31(1) of the Criminal Code. The United Nations defines money laundering as "any act or attempted act to disguise the source of money or assets derived from criminal activity." Essentially, money laundering is the process whereby "dirty money"—produced through criminal activity—is transformed into "clean money," the criminal origin of which is difficult to trace. (infraction de recyclage des produits de la criminalité)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Money laundering and terrorist financing indicators (ML/TF indicators)

Potential red flags that could initiate suspicion or indicate that something may be unusual in the absence of a reasonable explanation. [Indicateurs de blanchiment d'argent (BA) et de financement du terrorisme (FT) (indicateurs de BA/FT)]

Money services business

A person or entity that has a place of business in Canada and that is engaged in the business of providing at least one of the following services:

(i) foreign exchange dealing,
(ii) remitting funds or transmitting funds by any means or through any person, entity or electronic funds transfer network,
(iii) issuing or redeeming money orders, traveller's cheques or other similar negotiable instruments except for cheques payable to a named person or entity,
(iv) dealing in virtual currencies, or
(v) any prescribed service.

(entreprise de services monétaires)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 5(h), PCMLTFRR, SOR/2007-121, s. 1 and PCMLTFR, SOR/2002-184, s. 1(2).

Money services business agent

An individual or entity authorized to deliver services on behalf of a money services business (MSB). It is not an MSB branch. (mandataire d'une entreprise de services monétaires)

Nature of principal business

An entity's type or field of business. Also applies to an individual in the case of a sole proprietorship. (nature de l'entreprise principale)

New developments

Changes to the structure or operations of a business when new services, activities, or locations are put in place. For example, changes to a business model or business restructuring. (nouveaux développements)

New technologies

The adoption of a technology that is new to a business. For example, when a business adopts new systems or software such as transaction monitoring systems or client onboarding and identification tools. (nouvelles technologies)

No apparent reason

There is no clear explanation to account for suspicious behaviour or information. (sans raison apparente)

Occupation

The job or profession of an individual. (profession ou métier)

Person

An individual. (personne)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Person authorized to give instructions

In respect of an account, means a person who is authorized to instruct on the account or make changes to the account, such as modifying the account type, updating the account contact details, and in the case of a credit card account, requesting a limit increase or decrease, or adding or removing card holders. A person who is only able to conduct transactions on the account is not considered a person authorized to give instructions. (personne habilitée à donner des instructions)

Politically exposed domestic person

A person who, at a given time, holds—or has held within a prescribed period before that time—one of the offices or positions referred to in any of paragraphs (a) and (c) to (j) in or on behalf of the federal government or a provincial government or any of the offices or positions referred to in paragraphs (b) and (k):

(a) Governor General, lieutenant governor or head of government;
(b) member of the Senate or House of Commons or member of a legislature of a province;
(c) deputy minister or equivalent rank;
(d) ambassador, or attaché or counsellor of an ambassador;
(e) military officer with a rank of general or above;
(f) president of a corporation that is wholly owned directly by His Majesty in right of Canada or a province;
(g) head of a government agency;
(h) judge of an appellate court in a province, the Federal Court of Appeal or the Supreme Court of Canada;
(i) leader or president of a political party represented in a legislature;
(j) holder of any prescribed office or position; or
(k) mayor, reeve or other similar chief officer of a municipal or local government.

(national politiquement vulnérable)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 9.3(3).

Politically exposed foreign person

A person who holds or has held one of the following offices or positions in or on behalf of a foreign state:

(a) head of state or head of government;
(b) member of the executive council of government or member of a legislature;
(c) deputy minister or equivalent rank;
(d) ambassador, or attaché or counsellor of an ambassador;
(e) military officer with a rank of general or above;
(f) president of a state-owned company or a state-owned bank;
(g) head of a government agency;
(h) judge of a supreme court, constitutional court or other court of last resort;
(i) leader or president of a political party represented in a legislature; or
(j) holder of any prescribed office or position.

(étranger politiquement vulnérable)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Possibility

In regards to completing a suspicious transaction report (STR), the likelihood that a transaction may be related to a money laundering/terrorist financing (ML/TF) offence. For example, based on your assessment of facts, context and ML/TF indicators you have reasonable grounds to suspect that a transaction is related to the commission or attempted commission of an ML/TF offence. (possibilité)

Precious metal

Gold, silver, palladium or platinum in the form of coins, bars, ingots or granules or in any other similar form. (métal précieux)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Precious stones

Diamonds, sapphires, emeralds, tanzanite, rubies or alexandrite. (pierre précieuse)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Prepaid payment product

A product that is issued by a financial entity and that enables a person or entity to engage in a transaction by giving them electronic access to funds or virtual currency paid to a prepaid payment product account held with the financial entity in advance of the transaction. It excludes a product that:

(a) enables a person or entity to access a credit or debit account or one that is issued for use only with particular merchants; or
(b) is issued for single use for the purposes of a retail rebate program.

(produit de paiement prépayé)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Prepaid payment product account

An account – other than an account to which only a public body or, if doing so for the purposes of humanitarian aid, a registered charity as defined in subsection 248(1) of the Income Tax Act, can add funds or virtual currency – that is connected to a prepaid payment product and that permits:

(a) funds or virtual currency that total $1,000 or more to be added to the account within a 24-hour period; or
(b) a balance of funds or virtual currency of $1,000 or more to be maintained.

(compte de produit de paiement prépayé)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Prescribed

Prescribed by regulations made by the Governor in Council. (Version anglaise seulement)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Probability

The likelihood in regards to completing a suspicious transaction report (STR) that a financial transaction is related to a money laundering/terrorist financing (ML/TF) offence. For example, based on facts, having reasonable grounds to believe that a transaction is probably related to the commission or attempted commission of an ML/TF offence. (probabilité)

Production order

A judicial order that compels a person or entity to disclose records to peace officers or public officers. (ordonnance de communication)

Public body

Means

(a) a department or an agent of His Majesty in right of Canada or an agent or mandatary of His Majesty in right of a province;
(b) an incorporated city or town, village, metropolitan authority, township, district, county, rural municipality or other incorporated municipal body in Canada or an agent or mandatary in Canada of any of them; and
(c) an organization that operates a public hospital and that is designated by the Minister of National Revenue as a hospital authority under the Excise Tax Act, or an agent or mandatary of such an organization.

(organisme public)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Real estate broker or sales representative

A person or entity that is authorized under provincial legislation to act as an agent or mandatary for purchasers or vendors in respect of the purchase or sale of real property or immovables. (courtier ou agent immobilier)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Real estate developer

A person or entity that, in any calendar year after 2007, has sold to the public, other than in the capacity of a real estate broker or sales representative:

(a) five or more new houses or condominium units;
(b) one or more new commercial or industrial buildings; or
(c) one or more new multi-unit residential buildings each of which contains five or more residential units, or two or more new multi-unit residential buildings that together contain five or more residential units.

(promoteur immobilier)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Reasonable measures

Steps taken to achieve a desired outcome, even if they do not result in the desired outcome. For example, this can include doing one or more of the following:

asking the client,
conducting open source searches,
retrieving information already available, including information held in non-digital formats, or
consulting commercially available information.

(mesures raisonnables)

Receipt of funds record

A record that indicates the receipt of an amount of funds and that contains the following information:

(a) the date of the receipt;
(b) if the amount is received from a person, their name, address and date of birth and the nature of their principal business or their occupation;
(c) if the amount is received from or on behalf of an entity, the entity's name and address and the nature of their principal business;
(d) the amount of the funds received and of any part of the funds that is received in cash;
(e) the method by which the amount is received;
(f) the type and amount of each fiat currency involved in the receipt;
(g) if applicable, the exchange rates used and their source;
(h) the number of every account that is affected by the transaction in which the receipt occurs, the type of account and the name of each account holder;
(i) the name and address of every other person or entity that is involved in the transaction, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
(j) every reference number that is connected to the transaction and has a function equivalent to that of an account number; and
(k) the purpose of the transaction.

(relevé de réception de fonds)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Registered pension plan

Has the same meaning as in subsection 248(1) of the Income Tax Act. (régime de pension agréé)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Registered retirement income fund

Has the same meaning as in subsection 248(1) of the Income Tax Act. (fonds enregistré de revenu de retraite)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Reliable

In respect of information that is used to verify identity, means that the source is well known, reputable, and is considered one that you trust to verify the identity of the client. (fiable)

Representative for service

An individual in Canada that has been appointed by a person or entity that is a foreign money services business (FMSB), pursuant to the PCMLTFA, to receive notices and documents on behalf of the FMSB. (représentant du service)

Risk assessment

The review and documentation of potential money laundering/terrorist financing risks in order to help a business establish policies, procedures and controls to detect and mitigate these risks and their impact. (évaluation des risques)

Securities dealer

A person or entity that is referred to in paragraph 5(g) of the Act. (courtier en valeurs mobilières)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Senior officer

In respect of an entity, means:

(a) a director of the entity who is one of its full-time employees;
(b) the entity's chief executive officer, chief operating officer, president, secretary, treasurer, controller, chief financial officer, chief accountant, chief auditor or chief actuary, or any person who performs any of those functions; or
(c) any other officer who reports directly to the entity's board of directors, chief executive officer or chief operating officer.

(cadre dirigeant)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Service agreement

An agreement between a money services business (MSB) and an organization according to which the MSB will provide any of the following MSB services on an ongoing basis:

money transfers;
foreign currency exchange;
issuing or redeeming money orders, traveller's cheques or anything similar; or
dealing in virtual currencies.

(accord de relation commerciale)

Settlor

A settlor is an individual or entity that creates a trust with a written trust declaration. The settlor ensures that legal responsibility for the trust is given to a trustee and that the trustee is provided with a trust instrument document that explains how the trust is to be used for the beneficiaries. A settlor includes any individual or entity that contributes financially to that trust, either directly or indirectly. (constituant)

Shell bank

A foreign financial institution that:

(a) does not have a place of business that:
1. (i) is located at a fixed address—where it employs one or more persons on a full-time basis and maintains operating records related to its banking activities—in a country in which it is authorized to conduct banking activities; and
2. (ii) is subject to inspection by the regulatory authority that licensed it to conduct banking activities; and
(b) is not controlled by, or under common control with, a depository institution, credit union or foreign financial institution that maintains a place of business referred to in paragraph (a) in Canada or in a foreign country.

(banque fictive)

Reference:
PCMLTFR, SOR/2002-184, s. 1(1).

Signature

Includes an electronic signature or other information in electronic form that is created or adopted by a client of a person or entity referred to in section 5 of the Act and that is accepted by the person or entity as being unique to that client. (signature)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Signature card

In respect of an account, means a document that is signed by a person who is authorized to give instructions in respect of the account, or electronic data that constitutes the signature of such a person. (fiche-signature)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Source

The issuer or provider of information or documents for verifying identification. (source)

Source of funds or of virtual currency (VC)

The origin of the particular funds or VC used to carry out a specific transaction or to attempt to carry out a transaction. It is how the funds were acquired, not where the funds may have been transferred from. For example, the source of funds could originate from activities or occurrences such as employment income, gifts, the sale of a large asset, criminal activity, etc. (origine des fonds ou de la monnaie virtuelle (MV))

Source of wealth

The origin of a person's total assets that can be reasonably explained, rather than what might be expected. For example, a person's wealth could originate from an accumulation of activities and occurrences such as business undertakings, family estates, previous and current employment income, investments, real estate, inheritance, lottery winnings, etc. (origine de la richesse)

Starting action

With respect to a reportable transaction, information related to the instructions provided by the person or entity making the request to the reporting entity to start a transaction. For example, an individual arrives at a bank and requests to purchase a bank draft. The starting action is the details of the instructions for the purchase which includes the funds or virtual currency that the requesting person or entity brought to the reporting entity. A transaction must have at least one starting action. (action d’amorce)

SWIFT

The Society for Worldwide Interbank Financial Telecommunication. (SWIFT)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Terrorist activity

Has the same meaning as in subsection 83.01(1) of the Criminal Code. (activité terroriste)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Terrorist activity financing offence

An offence under section 83.02, 83.03 or 83.04 of the Criminal Code or an offence under section 83.12 of the Criminal Code arising out of a contravention of section 83.08 of that Act.

A terrorist financing offence is knowingly collecting or giving property (such as money) to carry out terrorist activities. This includes the use and possession of any property to help carry out the terrorist activities. The money earned for terrorist financing can be from legal sources, such as personal donations and profits from a business or charitable organization or from criminal sources, such as the drug trade, the smuggling of weapons and other goods, fraud, kidnapping and extortion. (infraction de financement des activités terroristes)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Third party

Any individual or entity that instructs another individual or entity to act on their behalf for a financial activity or transaction. (tiers)

Threats to the security of Canada

Has the same meaning as in section 2 of the Canadian Security Intelligence Service Act. (menaces envers la sécurité du Canada)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Training program

A written and implemented program outlining the ongoing training for your employees, agents or other individuals authorized to act on your behalf. It should contain information about all your obligations and requirements to be fulfilled under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its associated Regulations. (programme de formation)

Trust

A right of property held by one individual or entity (a trustee) for the benefit of another individual or entity (a beneficiary). (fiducie)

Trust company

A company that is referred to in any of paragraphs 5(d) to (e.1) of the Act. (société de fiducie)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Trustee

A trustee is the individual or entity authorized to hold or administer the assets of a trust. (fiduciaire)

Tutor

In the context of civil law, a person who has been lawfully appointed to the care of the person and property of a minor. (tuteur)

Two year effectiveness review

A review, conducted every two years (at a minimum), by an internal or external auditor to test the effectiveness of your policies and procedures, risk assessment, and training program. (examen bisannuel de l'efficacité)

Valid

In respect of a document or information that is used to verify identity, appears legitimate or authentic and does not appear to have been altered or had any information redacted. The information must also be valid according to the issuer, for example if a passport is invalid because of a name change, it is not valid for FINTRAC purposes. (valide)

Verify identity

To refer to certain information or documentation, in accordance with the prescribed methods, to identify a person or entity (client). (vérifier l'identité)

Very large corporation or trust

A corporation or trust that has minimum net assets of $75 million CAD on its last audited balance sheet. The corporation's shares or units have to be traded on a Canadian stock exchange or on a stock exchange designated under subsection 262(1) of the Income Tax Act. The corporation or trust also has to operate in a country that is a member of the Financial Action Task Force (FATF). (personne morale ou fiducie dont l'actif est très important)

Violation

A contravention of the Act or the regulations that is designated as a violation by regulations made under subsection 73.1(1). (violation)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Virtual currency

Means:

(a) a digital representation of value that can be used for payment or investment purposes that is not a fiat currency and that can be readily exchanged for funds or for another virtual currency that can be readily exchanged for funds; or
(b) a private key of a cryptographic system that enables a person or entity to have access to a digital representation of value referred to in paragraph (a).

(monnaie virtuelle)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2).

Virtual currency exchange transaction

An exchange, at the request of another person or entity, of virtual currency for funds, funds for virtual currency or one virtual currency for another. (opération de change en monnaie virtuelle)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Virtual currency exchange transaction ticket

A record respecting a virtual currency exchange transaction—including an entry in a transaction register—that sets out:

(a) the date of the transaction;
(b) in the case of a transaction of $1,000 or more, the name and address of the person or entity that requests the exchange, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
(c) the type and amount of each type of funds and each of the virtual currencies involved in the payment made and received by the person or entity that requests the exchange;
(d) the method by which the payment is made and received;
(e) the exchange rates used and their source;
(f) the number of every account that is affected by the transaction, the type of account and the name of each account holder;
(g) every reference number that is connected to the transaction and has a function equivalent to that of an account number; and
(h) every transaction identifier, including the sending and receiving addresses.

(fiche d'opération de change en monnaie virtuelle)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Working days

In respect of an electronic funds transfer (EFT) report or a large virtual currency transaction report, a working day is a day between and including Monday to Friday. It excludes Saturday, Sunday, and a public holiday. (jour ouvrable)

Date Modified:: 2022-12-16