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Draft guidance: Reporting suspicious transactions to FINTRAC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

In this guidance

  1. What is an STR?
  2. What are reasonable grounds to suspect (RGS)?
  3. When must I submit an STR?
  4. How do I submit STRs?
  5. What are the main considerations when submitting an STR?
  6. Do I have other requirements associated with suspicious transactions?
  7. Are there any exclusions to reporting suspicious transactions?
  8. Do I need to continue reporting suspicious transactions after I submit an STR?
  9. What are FINTRAC's expectations for completing an STR?
  10. 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

Diagram 1: Threshold of 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:

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 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:

  1. 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)
  2. 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:

  3. 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)
  4. 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)
  5. 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

**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:

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:

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:

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

STR example

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

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:

Validation of reports by FINTRAC

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

Using the occupation field as an example:

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.

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:

  1. 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
  2. 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).
  3. 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.
  4. 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:

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:

  1. 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.
  2. When was the transaction completed/attempted? If it was not completed, why not?
    • Provide the facts, context and ML/TF indicators regarding the transaction.
  3. What are the financial instruments or mechanisms used to conduct the transaction?
  4. Where did this transaction take place?
  5. 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.
  6. 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:

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:

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:

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:

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.

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:

  1. 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.

  2. 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. 

  3. 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.
  4. 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."

  5. 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.

  6. 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:

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

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 or attempting to conduct the transaction.

†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.

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.

†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:

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

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.

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.

Date Modified: