Archived – Guideline 7A: Submitting Large Cash Transaction Reports to FINTRAC electronically

2. Who Has to Send a Large Cash Transaction Report to FINTRAC?

If you are one of the following individuals or entities, you must report large cash transactions to FINTRAC.

2.1 Financial entities

Financial entities are banks (that is, those listed in Schedule I or II of the Bank Act) or authorized foreign banks with respect to their operations in Canada, credit unions, caisses populaires, financial services cooperatives, credit union centrals, trust companies, loan companies and agents of the Crown that accept deposit liabilities.

If you are a financial entity and you have foreign subsidiaries or foreign branches, the large cash transaction reporting requirement does not apply to their operations outside Canada.

2.2 Life insurance companies, brokers and agents

A life insurance company means one regulated by provincial legislation, or a life company or foreign life company under the Insurance Companies Act. A life insurance broker or agent means an individual or entity registered or licensed provincially to carry on the business of arranging contracts of life insurance.

If you are a life insurance company and you have foreign subsidiaries or foreign branches, the large cash transaction reporting requirement does not apply to their operations outside Canada.

If you are a life insurance company, a broker or an independent agent and you are dealing in reinsurance, the large cash transaction reporting requirement does not apply. In addition, the requirement does not apply to the following types of transactions:

• the purchase of a policy that is an exempt policy (i.e., a policy issued for insurance protection and not for significant investment purposes as defined in subsection 306(1) of the Income Tax Regulations);
• the purchase of a group life insurance policy that does not provide a cash surrender value or a savings component;
• the purchase of an immediate or deferred annuity paid for entirely with funds directly transferred from a registered pension plan or the proceeds of a group life insurance policy;
• the purchase of a registered annuity policy or a registered retirement income fund;
• a registered plan, including a locked-in retirement plan, a registered retirement savings plan, a group registered retirement savings plan, a registered education savings plan and any other registered plan;
• where the account holder or settlor is a federally or provincially regulated pension fund;
• a transaction that is part of a reverse mortgage or structured settlement; or
• a transaction for a public body or a very large corporation. The same is true regarding a subsidiary of either of those entities, if the financial statements of the subsidiary are consolidated with those of the public body or very large corporation.

2.3 Securities dealers

A securities dealer is an individual or entity authorized under provincial legislation to engage in the business of dealing in securities or any other financial instruments or to provide portfolio management or investment advising services. A securities dealer employed by a securities dealer is not considered a reporting entity.

If you are a securities dealer and you have foreign subsidiaries or foreign branches, the large cash transaction reporting requirement does not apply to their operations outside Canada.

2.4 Money services businesses

A money services business means an individual or entity engaged in the business of any of the following activities:

• foreign exchange dealing;
• remitting or transmitting funds by any means or through any individual, entity or electronic funds transfer network; or
• issuing or redeeming money orders, traveller's cheques or other similar negotiable instruments. This does not include redeeming cheques payable to a named individual or entity. In other words, cashing cheques made out to a particular individual or entity is not included.

Money services businesses include alternative money remittance systems, such as Hawala, Hundi, Chitti, etc.

For more information about who is engaged in the money services business, see FINTRAC guidance for Money services businesses.

2.5 Agents of the Crown

Agents of the Crown are government departments or agents of His Majesty in right of Canada or of a province. If you are an agent of the Crown that sells or redeems money orders, you are subject to the reporting requirements explained in this guideline.

If you are an agent of the Crown that accepts deposit liabilities in the course of providing financial services to the public, such as a provincial savings office, you are considered a financial entity (see subsection 2.1).

If you are an agent of the Crown that sells precious metals to the public, you are considered a dealer in precious metals and stones (see subsection 2.9).

2.6 Accountants and accounting firms

An accountant means a chartered accountant, a certified general accountant or a certified management accountant. An accounting firm means an entity that is in the business of providing accounting services to the public that has at least one accountant who is a partner, an employee or an administrator.

If you are an accountant or an accounting firm, you are subject to the reporting requirements explained in this guideline when conducting any of the following activities on behalf of any individual or entity (other than your employer) or giving instructions in respect of those activities on behalf of any individual or entity (other than your employer):

• receiving or paying funds;
• purchasing or selling securities, real property or business assets or entities; or
• transferring funds or securities by any means.

You are not subject to these obligations for the receipt of professional fees. This means that the receipt of professional fees does not trigger your obligations. However, you are subject to the reporting requirements when you engage in any of the activities mentioned above, regardless of whether or not you received any fees or have a formal letter of engagement to do so. In other words, you are subject to the obligations even if you were doing the activities on a volunteer basis.

Activities of accountants or accounting firms other than those listed above, such as audit, review or compilation engagements carried out according to the recommendations in the Canadian Institute of Chartered Accountants (CICA) Handbook, do not trigger reporting obligations.

Giving advice to a client, in the context of your accountant-client relationship, is not considered providing instructions. If you need further clarification about this, refer to FINTRAC Interpretation Notice No. 2.

2.7 Real estate

Real estate brokers or sales representatives

Real estate brokers or sales representatives are individuals or entities that are registered or licensed in a province to sell or purchase real estate. They are subject to the reporting requirements explained in this guideline when they act as an agent regarding the purchase or sale of real estate. This includes the buying or selling of land, buildings, houses, etc. Such activities trigger these obligations whether or not the real estate broker or sales representative gets a commission for the real estate transaction and whether or not they have fiduciary duties regarding it.

If you are a real estate broker or sales representative, these obligations do not apply to you for activities related to property management. This means that if you only deal in rental property transactions, not purchases or sales, the obligations explained in this guideline do not apply to you.

Real estate developers

A real estate developer means an individual or an entity other than a real estate broker or sales representative, who in any calendar year after 2007 has sold one of the following to the public:

• at least five new houses or condominium units;
• at least one new commercial or industrial building;
• at least one new multi-unit residential building each of which contains five or more residential units; or
• at least two new multi-unit residential buildings that together contain five or more residential units.

If you are a real estate developer, you are subject to the reporting requirements explained in this guideline when you sell any of the following to the public:

• a new house;
• a new condominium unit;
• a new commercial or industrial building; or
• a new multi-unit residential building.

If you are an entity that is a corporation, you are subject to this whether you sell those buildings on your own behalf or on behalf of a subsidiary or affiliate. In this context, an entity is affiliated with another entity if one of them is wholly-owned by the other, both are wholly-owned by the same entity or their financial statements are consolidated.

2.8 Casinos

You have legislative requirements under the PCMLTFA if you are a casino. A casino is an entity that is authorized to do business in Canada if it is:

• located at a fixed place of business that includes games of roulette or card games; or
• located at a fixed place of business, where there are more than 50 slot machines or similar electronic games in the establishment. This could include a place of business such as a restaurant that has these electronic gaming machines; or
• accessible to the public through the Internet or other digital network. This does not include an entity if it is solely offering online bingo or the sale of lottery tickets.

A registered charity authorized to carry on business in a casino for a period of two consecutive days or less, under the supervision of the casino, is not considered to be a casino.

2.9 Dealers in precious metals and stones

A dealer in precious metals and stones (DPMS) means an individual or an entity that buys or sells precious metals, precious stones or jewellery, in the course of its business activities. Precious metals include gold, silver, palladium or platinum whether in coins, bars, ingots, granules or in any other similar form. Precious stones include diamonds, sapphires, emeralds, tanzanite, rubies or alexandrite. Jewellery means objects made of precious metals, precious stones or pearls intended for personal adornment.

If you are a DPMS, you are subject to the reporting requirements explained in this guideline if you engage in the purchase or sale of precious metals, precious stones or jewellery in an amount of $10,000 or more in a single transaction. However, you are not subject to the reporting requirements when you engage in a purchase or sale carried out for, in connection with, or for the purpose of manufacturing jewellery, extracting precious metals or precious stones from a mine or cutting or polishing precious stones.

An agent of the Crown (that is, a government department or an agent of His Majesty in right of Canada or of a province) is considered to be a DPMS when it sells precious metals to the public in an amount of $10,000 or more in a single transaction.

2.10 British Columbia notaries

A British Columbia notary means a British Columbia notary public or a British Columbia notary corporation. In this context, a notary public means an individual who is a member of the Society of Notaries Public of British Columbia. Also in this context, a notary corporation means an entity that provides notary services to the public in British Columbia under the Notaries Act of that province.

If you are a British Columbia notary, you are subject to the reporting requirements explained in this guideline when you engage in any of the following activities on behalf of any individual or entity (other than your employer), or give instructions on behalf of any individual or entity (other than your employer):

• receiving or paying funds (other than those received or paid for professional fees, disbursements, expenses or bail);
• purchasing or selling securities, real property or business assets or entities; or
• transferring funds or securities by any means.

3. Large Cash Transaction Reporting Requirements

3.1 Electronic reporting enrolment

As a reporting entity, you have to be enrolled with FINTRAC's electronic reporting system to report electronically. FINTRAC will provide you with an identifier number to include in your reports. For more information about FINTRAC's electronic reporting system enrolment, contact us as explained in section 7.

3.2 When does a large cash transaction report have to be made?

If you are a reporting entity as described in section 2, you have to send a large cash transaction report to FINTRAC in the following situations:

• If you receive an amount of $10,000 or more in cash in the course of a single transaction. Each such transaction must be sent to FINTRAC separately, in its own report.

• If you receive two or more cash amounts of less than $10,000 each that total $10,000 or more. In this case, if you are an individual, you have to make a large cash transaction report if you know the transactions were made within 24 consecutive hours of each other by or on behalf of the same individual or entity. If you are an entity, you have to make a large cash transaction report if your employee or senior officer knows the transactions were made within 24 consecutive hours of each other by or on behalf of the same individual or entity.

You have to send a large cash transaction report to FINTRAC within 15 calendar days after the transaction.

Employees or agents of another reporting entity

If you are an individual described in section 2 and you are an employee of a reporting entity, your employer is responsible for meeting the large cash transaction reporting requirement associated to any of your activities as an employee. This would apply, for example, in the case of an accountant employed by a bank.

Similarly, if you are an individual or entity described in section 2 and you are an agent of or you are authorized to act on behalf of a reporting entity, it is that reporting entity's responsibility to meet the large cash transaction reporting requirement associated to any of your activities on their behalf. This would apply for example in the case of a credit union acting as an agent for another credit union. However, if you are a life insurance broker or independent agent and as such are authorized to act on behalf of another reporting entity, you are responsible for meeting the large cash transaction reporting requirement to FINTRAC (unless you are an employee as explained above).

Exceptions to reporting large cash transactions

Do not make a large cash transaction report to FINTRAC if the cash is received from a financial entity or a public body. In this context, a financial entity means any of the following:

• a bank (that is, one that is listed in Schedule I or II of the Bank Act) or an authorized foreign bank with respect to its operations in Canada;
• a credit union or a caisse populaire;
• a financial services cooperative (in the province of Quebec) or a credit union central (in all other provinces);
• a trust and loan company; or
• an agent of the Crown that accepts deposit liabilities.

Also in this context, a public body means any of the following or their agent:

• a Canadian provincial or federal department or Crown agency;
• an incorporated Canadian municipal body (including an incorporated city, town, village, metropolitan authority, district, county, etc.);
• a hospital authority. A hospital authority means an organization that operates a public hospital and that is designated to be a hospital authority for GST/HST purposes. For more information on the designation of hospital authorities, refer to GST/HST Memoranda Series, Chapter 25.2, Designation of Hospital Authorities.

Financial entities may choose, in certain specific circumstances, an alternative to making large cash transaction reports for certain clients that are corporations. If you are a financial entity, see Guideline 9: Submitting Alternative to Large Cash Transaction Reports to FINTRAC for more information about this.

3.3 Cash transactions in foreign currency

If a cash transaction is in foreign currency, you will need to check whether it is the equivalent of 10,000 Canadian dollars or more to determine whether or not it is reportable as a large cash transaction. For this purpose only, use the last rate provided by the Bank of Canada available at the time of the transaction. This calculation is not based on the actual exchange rate used to process the transaction - this is only to check whether the $10,000 threshold is met for the transaction to be reportable as a large cash transaction.

For example, for a cash transaction in foreign currency that happened at 9:00 a.m. on Tuesday following a holiday Monday, you would use the Bank of Canada rate from the previous Friday to determine whether it is a large cash transaction. You can find the rate applicable at the time of a transaction on the Bank of Canada Web site at (https://www.bankofcanada.ca/rates/exchange/). If there is no Bank of Canada rate published for the currency of the transaction, use the actual exchange rate applied when you processed the transaction to determine whether it is reportable.

Once you have determined that a cash transaction in foreign currency is in fact reportable based on the Bank of Canada rate, you will have to send a large cash transaction report to FINTRAC. On this report, you will indicate any amounts involved in the transaction in foreign currency, and indicate the appropriate currency code. You are not required to provide information about any exchange rate applicable to the transaction in the large cash transaction report. The exchange rate is only relevant to determine whether or not the transaction is a large cash transaction.

3.4 Other requirements associated with large cash transactions

In addition to the reporting requirements explained in this guideline, consider the following relating to a large cash transaction:

Record keeping and client identification

Large cash transactions have associated record keeping and client identification requirements.

Electronic funds transfer report

If a large cash transaction involves an electronic funds transfer, you may have to make an electronic funds transfer report to FINTRAC about the same transaction in addition to the large cash transaction report.

For more information about making electronic funds transfer reports, consult Guideline 8: Submitting Electronic Funds Transfer Reports to FINTRAC.

Suspicious transaction report

If anything about a large cash transaction gives you reasonable grounds to suspect that it could be related to a money laundering or a terrorist activity financing offence, you have to make a suspicious transaction report to FINTRAC. This would be in addition to making the large cash transaction report about the same transaction as required.

The suspicious transaction report has very similar fields to those of a large cash transaction report. There are some differences, such as a field in the suspicious transaction report for you to explain your suspicion about the transaction. There is also a field in that report for you to describe what action, if any, was taken by you as a result of the suspicious transaction. This would include stating that you have made a large cash transaction report for the same transaction (if that is the case).

For more information about suspicious transaction reports, consult STR guidance.

Transactions related to terrorist property

If you know that any proposed transaction is related to property owned or controlled by or on behalf of a terrorist or a terrorist group, you cannot complete the transaction. This is because terrorist property must be frozen under the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism as well as the Criminal Code.

For more information about this and to find out what your obligations are regarding any terrorist property in your control or possession, consult the following:

• Guideline 1: Backgrounder
• Guideline 5: Submitting Terrorist Property Reports to FINTRAC

3.5 Means of reporting to FINTRAC

Electronic reporting

As a reporting entity, you will have to submit all large cash transaction reports to FINTRAC electronically if you have the technical capabilities to do so. The minimum technical capabilities are as follows:

• A personal computer with the following characteristics:
  • 32 MB memory (64 MB or higher is preferable);
  • 640 x 480 VGA video display (800 x 600 or higher is preferable);
  • an operating system running a Web browser; and
• An Internet connection

See section 3 for more information on submitting reports to FINTRAC electronically.

Paper reporting

If you do not have the technical capabilities to send reports electronically, you must submit reports on paper. See Guideline 7B: Submitting Large Cash Transaction Reports to FINTRAC by Paper for more information.

4. Electronic Reporting

4.1 Options for electronic reporting

As a reporting entity, you have to report large cash transactions electronically to FINTRAC if you have the technical capabilities (see subsection 4.5).

There are two options for electronic reporting:

• FINTRAC's secure Web site (FINTRAC web reporting); and
• Batch file transfer.

Both options provide for secure encrypted transmission to ensure data confidentiality and integrity. Reporting through batch will require more advanced technical capability than explained in subsection 4.5.

4.2 How to complete electronic reports

Reporting through FINTRAC web reporting

FINTRAC web reporting contains the large cash transaction reporting screens, with completion instructions. Drop-down menus appear wherever a code or specific selection is required.

Reporting through batch file transfer

To use the batch file reporting mechanism, you need a public key infrastructure (PKI) certificate and specialized software available from FINTRAC. For more information, refer to the Batch reporting page.

Consult the Standard Batch Reporting Instructions and Specification for more information about how to report large cash transactions through batch file transfer.

4.3 Acknowledgement of receipt of an electronic report

FINTRAC will send you an acknowledgement message when your large cash transaction report has been received electronically.

If you send your reports by batch, you will receive two acknowledgements. The first will confirm that your batch has been received by FINTRAC. The second will confirm that it has been processed.

For each report submitted through the FINTRAC web reporting system, you will receive an acknowledgement message including the date and time your report was received and the report's identification number. These acknowledgements will be stored on the FINTRAC web reporting system and available for viewing or printing.

4.4 Report corrections

If you need to request a change to a large cash transaction report in FINTRAC web reporting, you will do so based on the acknowledgement for that report.

In addition, if you send a large cash transaction report that contains incomplete or inaccurate information, FINTRAC may notify you. The notification will indicate the date and time your report was received, a FINTRAC-generated identification number, along with information on the fields that must be completed or corrected.

After receiving FINTRAC's notification, you must provide the necessary information to FINTRAC within the 15-calendar-day reporting deadline. In other words, this information should be sent to FINTRAC within 15 calendar days after the transaction. Your obligation to report will not be fulfilled until you send the complete report to FINTRAC.

If a correction is required to a report that you sent through the FINTRAC web reporting system, you will have to make that correction through the FINTRAC web reporting system.

If a correction is required to a report that you sent through batch file transfer, you will do this according to your choice of correction options upon enrolment for electronic reporting. For more information about this, refer to the Standard Batch Reporting Instructions and Specification and the documents about FINTRAC's enrolment for electronic reporting and use of FINTRAC’s web reporting system.

5. Instructions for Completing a Large Cash Transaction Report

5.1 General instructions

If you report through batch, you need to refer to the Standard Batch Reporting Instructions and Specification.

As explained in subsection 4.5, if you do not have the technical capability to report electronically, refer to Guideline 7B: Submitting Large Cash Transaction Reports to FINTRAC by Paper for more information.

Fields in reports are either mandatory, mandatory where applicable, or require "reasonable efforts" to complete, as follows:

• Mandatory: All fields of a report marked with an asterisk (*) have to be completed.
• Mandatory where applicable: The fields that have both an asterisk and "where applicable" next to them have to be completed if they are applicable to you or the transaction being reported.
• Reasonable efforts: For all other fields that do not have an asterisk, you have to make reasonable efforts to get the information. "Reasonable efforts" means that you tried to get the information requested on the report. If the information is available to you, you must provide it in the report. If the information was not available at the time of the transaction, and it is not contained in your files or records, the field may be left blank.

As explained in subsection 4.1, a large cash transaction report can be about multiple transactions of less than $10,000 each conducted within 24 consecutive hours of each other that add up to $10,000 or more. Because those individual transactions were under $10,000, the information for some mandatory fields in the report may not be available in your records or from the time of the transaction. In this case, "reasonable efforts" applies to those otherwise mandatory fields.

5.2 Accessing the FINTRAC web reporting screens

To access FINTRAC web reporting you must first be enrolled for electronic reporting with FINTRAC.

You can get to FINTRAC web reporting from the reporting section of FINTRAC's main website (https://fintrac-canafe.canada.ca). If you are authorized to complete large cash transaction reports, you will be able to select this report type in the FINTRAC web reporting system. You will be able to complete a new report or continue working on an incomplete report (that is, a report that was not previously submitted to FINTRAC).

Also, depending on your access rights, you will be able to submit a request for change to a completed report (that is, one that was previously submitted to FINTRAC). Subsection 5.4 contains instructions for submitting a change to a previously submitted report.

5.3 Instructions for submitting a new report

There are eight parts to the large cash transaction report, but some are only to be completed if the part is applicable.

If you report through batch, you should also refer to the Standard Batch Reporting Instructions and Specification.

5.4 Instructions for submitting a change to a previously submitted report

If you have to submit a change to a previously submitted large cash transaction report, you must provide any required changes to FINTRAC within the reporting deadline for the report. In other words, this information should be sent to FINTRAC within 15 calendar days of the large cash transaction.

If you report through batch, refer to the technical documentation called Standard Batch Reporting Instructions and Specification to find out how to submit changes for previously submitted reports by batch. If you choose to do this through FINTRAC web reporting instead of by batch, read subsection 5.5. That choice means that you cannot submit changes by batch.

If you report through FINTRAC web reporting, read subsection 5.5.

5.5 Submitting changes through FINTRAC web reporting

The following explains how to make a change to a previously submitted large cash transaction report through FINTRAC web reporting:

• Report returned for further action (RRFA)
  If a large cash transaction report is returned to you by FINTRAC for correction, you can access it through the queue for reports returned for further action. Select "Incomplete reports" from the "Report to FINTRAC" menu. The entire report will be available.

  If nothing is displayed, there are no reports awaiting further action in this queue, or none have been assigned to you.

• Change a report
  If you need to change a large cash transaction report that you previously submitted to FINTRAC, you will have to request that this report be sent back to you for this purpose. Select "Report to FINTRAC" to find the report in need of correction. Once you have selected the report you need to change, select the "Change report" button at the bottom of the screen.

Change details

Before any change to a report can be submitted to FINTRAC, you have to provide an explanation as to the change made. If it was not requested by FINTRAC, you also have to provide a reason for the change.

Remember that you must provide any required changes to FINTRAC within the reporting deadline for the report. In other words, this information should be sent to FINTRAC within 15 calendar days after the large cash transaction.

6. Comments?

These guidelines will be reviewed on a periodic basis. If you have any comments or suggestions to help improve them, please send your comments to the mailing address provided below or by email to guidelines-lignesdirectrices@fintrac-canafe.gc.ca.

7. How to Contact FINTRAC

For further information on FINTRAC and its activities, reporting and other obligations, please go to FINTRAC's Web site (https://www.fintrac-canafe.gc.ca) or contact FINTRAC:

Details and history

Published: August 2019

For assistance

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