Language selection

Search

Reporting large cash transactions to FINTRAC : FINTRAC's compliance guidance

From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)

This guidance explains the requirement to report large cash transactions to FINTRAC.

This guidance replaces the following guidance, which have been archived online:

Note:

In this guidance

Related links

1. Who must comply

All reporting entities must comply with the large cash transaction reporting requirements.

If you are a person who is a reporting entity, and you are also an employee of a reporting entity, your employer is responsible for meeting the large cash transaction reporting requirements associated with your activities as an employee. 

Similarly, if you are a reporting entity that is an agent of or authorized to act on behalf of another reporting entity, it is the responsibility of the reporting entity for which you are an agent or acting on behalf to meet the reporting requirements associated with the activities you conduct on its behalf. This does not apply if you are a life insurance broker or agent (unless you are an employee as explained above).

A service provider can submit and correct a Large Cash Transaction Report on your behalf. However, as the reporting entity, you are ultimately responsible for meeting the requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and associated Regulations, even if a service provider is reporting on your behalf. This legal responsibility cannot be delegated.

Legal references

2. What is a large cash transaction

A large cash transaction occurs when you receive $10,000 or more in cash in a single transaction.

Cash includes:

Cash does not include:

3. When to submit a Large Cash Transaction Report

You must submit a Large Cash Transaction Report to FINTRAC when you receive $10,000 or more in cash in a single transaction from a person or entity.

If you are a foreign money services business, you must submit a report only when you receive $10,000 or more in cash in a single transaction from a person or entity in Canada.

Note: You must submit a Large Cash Transaction Report to FINTRAC within 15 calendar days after the day on which you receive the cash.

Legal references

24-hour rule

You must also submit a Large Cash Transaction Report to FINTRAC in accordance with the 24-hour rule. That is, you must submit a report when:

For more information:

Legal reference

Foreign currency

If you receive cash in a foreign currency, convert the amount into Canadian dollars using the exchange rate published by the Bank of Canada in effect at the time of the transaction to determine whether you have reached the reporting threshold amount of $10,000 CAD.

If an exchange rate is not published by the Bank of Canada, then you must use the rate you establish in the normal course of your business at the time of the transaction.

Your process for establishing an exchange rate to determine if you have reached the reporting threshold amount should be outlined in your compliance policies and procedures.

Legal references

4. How to submit a report to FINTRAC

You must submit a Large Cash Transaction Report to FINTRAC electronically using the following options:

Note about paper form: If you do not have the technical capability to submit reports electronically to FINTRAC, you must submit reports in paper form.

Legal references

5. The form for reporting large cash transactions

In this section

Note

Form structure

The form for reporting large cash transactions has 4 sections:

Structure of the Large Cash Transaction Report form: Main sections and types of information for each section
Main sections of the form Type of information for each section
General information
  • Information about your business including contact details
  • Aggregation type and 24-hour window for aggregation
  • Ministerial directives
  • Reporting entity report reference number
Transaction information
  • Date and time of transaction
  • Method of transaction
  • Location where the transaction was conducted
  • Purpose of the transaction
  • Whether the transaction is below or above $10,000 CAD
  • Reporting entity transaction reference number
Starting action
  • Amount and currency of cash received
  • Information about the source of cash
  • Conductor (person or entity that conducted the transaction and their associated information)
  • Third party (person or entity on whose behalf the transaction is conducted and their associated information)
Completing action
  • Details of disposition
  • Amount and currency
  • Account and/or reference 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)

Note

Form highlights

The structure of the form allows you to include:

Important information about the number of transactions, starting actions and completing actions in a report

Example 1

Ms. Green walks into ABC Credit Union with $10,000 CAD cash and instructs that the full amount be deposited into her savings account. Therefore, ABC Credit Union submits a Large Cash Transaction Report indicating that Ms. Green conducted a single transaction with:

  • 1 starting action (the receipt of $10,000 CAD cash by the credit union), and
  • 1 completing action (disposition of $10,000 involving a deposit to an account) where Ms. Green is also the beneficiary
Example 2

Mr. Blue walks into the General MSB Company in Calgary with $11,000 CAD cash and instructs that $5,000 be exchanged to USD and $6,000 be sent to Ms. Brown in Toronto. In this example, the General MSB Company submits a report indicating that Mr. Blue conducted a transaction in Calgary with:

  • 1 starting action (the receipt of $11,000 CAD cash by the business), and
  • 2 completing actions (a first disposition of $5,000 involving exchange to fiat currency and a second disposition of $6,000 involving an outgoing domestic funds transfer) where Mr. Blue and Ms. Brown are the respective beneficiaries

The following chart (Figure 1) demonstrates a Large Cash Transaction Report with multiple transactions, starting actions and completing actions.

Figure 1: Illustration of a Large Cash Transaction Report with multiple transactions, starting actions and completing actions
Illustration of a Large Cash Transaction Report with multiple transactions, starting actions and completing actions
Description of figure 1: Illustration of a Large Cash Transaction Report with multiple transactions, starting actions and completing actions

Specifically, this chart shows a Large Cash Transaction Report with 3 transactions.

This report contains a General information section and shows the information for each transaction where:

  • Transaction 1 has 1 starting action and 1 completing action
  • Transaction 2 has 2 starting actions and 2 completing actions
  • Transaction 3 has 1 starting action and 2 competing actions
Figure 1 legend
Type of line Meaning
Solid line
  • Required minimum transaction in a report
  • Required minimum starting action and completing action (for each transaction)
Dashed line
  • Additional optional transactions
  • Additional optional starting action
  • Additional optional completing actions

6. Other requirements associated with large cash transactions

In this section

Compliance program

Your compliance program's policies and procedures must outline your process and criteria on:

If you have an automated or triggering system in place to detect when the threshold amount is reached for reporting, a person may still assess the transaction(s), as a best practice, to ensure the submission of a Large Cash Transaction Report.

Your compliance program must also include training on suspected money laundering and terrorist financing activities in relation to your business.

For more information:

Suspicious transactions

In addition to reporting large cash transactions, you may also be required to submit Suspicious Transaction Reports to FINTRAC when you have reasonable grounds to suspect that a transaction is related to the commission, or the attempted commission, of a money laundering or terrorist activity financing offence. Therefore, you may be required to submit a Large Cash Transaction Report and a Suspicious Transaction Report for the same transaction.

For more information:

Electronic funds transfers

If the disposition of a large cash transaction involves a reportable electronic funds transfer, then you must submit an Electronic Funds Transfer Report to FINTRAC in addition to a Large Cash Transaction Report.

For more information:

Record keeping

When you submit a Large Cash Transaction Report to FINTRAC, you must keep a copy of it for at least 5 years from the date the report was created.

For more information:

Legal references

Verifying the identity of persons and entities

There are requirements on when and how to verify the identity of persons and entities for large cash transactions.

For more information:

Third party determination

There are requirements to determine whether a person or entity is acting on behalf of another person or entity for the receipt of a large cash transaction.

For more information:

Ministerial directives

You must consider all requirements issued under a ministerial directive along with your large cash transaction reporting requirements.

For more information:

Voluntary self-declaration of non-compliance

If you discover instances of non-compliance related to your large cash transaction reporting requirements, FINTRAC strongly encourages you to report a voluntary self-declaration of non-compliance.

For more information:

7. Exceptions to reporting large cash transactions

You are not required to submit a Large Cash Transaction Report if you receive an amount of $10,000 or more in cash in a single transaction if the amount is received from:

Legal references

Life insurance companies, brokers or agents

If you are a life insurance company, broker or agent, you are not required to submit a Large Cash Transaction Report when you are dealing in reinsurance or if the transaction:

Legal references

Financial entities

If you are a financial entity, you are not required to submit a Large Cash Transaction Report on certain clients that are corporations if you choose, in specific circumstances, to provide FINTRAC with specified information on those clients.

For more information:

Legal references

Foreign subsidiaries or branches

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

Annex A: Field instructions to complete a Large Cash Transaction Report

This annex contains instructions on how to complete the fields in a Large Cash Transaction Report.

In this annex

Note

Standardized field instructions

This section contains instructions for:

In this section

Field categories

Fields are categorized as either:

Instructions for field categories
Field categories Instructions
Mandatory

These fields are indicated with an asterisk symbol (*) and must be completed.

Because a Large Cash Transaction Report can include multiple transactions conducted within 24 consecutive hours that total $10,000 or more, the information for some mandatory fields may not have been obtained at the time of the transaction. In this case, the fields become "reasonable measures" fields, and the instructions for reasonable measures (below in this table) must be applied.

Note: If a Large Cash Transaction Report contains multiple transactions conducted within 24 consecutive hours and 1 of these transactions is $10,000 CAD or more, then the mandatory fields will apply.

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, SOR/2002-184, section 152(2)
Mandatory for processing These fields are indicated with a double dagger symbol (‡) and must be completed.  
Mandatory if applicable These fields are indicated with a dagger symbol (†) and must be completed if they are applicable to you or the transaction being reported.  
Reasonable measures

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.

If you obtain the information, you must report it. You must also provide the information if it is contained within your systems or records.

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, SOR/2002-184, section 152(1)

Name fields

Instructions for the name fields
Name fields Instructions
Surname Provide the last name of the person.
Given name

Provide the first name of the person.

Note: If a person has only a single name, enter "XXX" in the "Given name" field and the person's single name in the "Surname" field.

Other/Initial Provide the middle or other name(s) of the person, or their initial(s) if no other names apply.
Alias Provide the name a person uses, or by which they are known, other than the name provided under surname, given name, or other/initial.
Name of entity Provide the full name of the entity.

Address fields

Provide the address details in the structured or unstructured fields (as applicable) as explained below.

Structured address fields

Structured address fields include:

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, British Columbia, Canada A1B 2C3, complete the address fields as follows:

Example illustrating how to provide information if you have the ability to separate address information
Structured address fields Information provided
Apartment/Room/Suite/Unit number 10
House/Building number 123
Street address Main Street
City Richmond
Country Canada
Postal code A1B 2C3
If you are unable to separate the address information into the structured address fields

If, for example, your system groups the Apartment/Room/Suite/Unit number with the House/Building number and Street address, then provide:

If there is no civic address

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, Saskatchewan, Canada X1Y 2Z2, complete the address fields as follows:

Example illustrating how to provide information if there is no civic address
Structured address fields Information provided
Street address Third house to the right after the community center
City Tinytown
Province SK
Country Canada
Postal code X1Y 2Z2

Note: 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 and the data originates from outside your organization. For example, when you are in final receipt of an electronic funds transfer and the foreign address of the person who requested the transfer information cannot be easily populated into the structured address fields.

If possible, enter information about the country in the Country field and provide the unstructured address information in the following format:

Invalid addresses

The following are not valid addresses, and should not be provided in either the structured or unstructured address fields:

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.
Persons who are transient or have no fixed address

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 information:

Address information to provide for persons who are transient or have no fixed address
Type of person What to provide
Canadian residents Their permanent Canadian address, even if that is not where they are currently residing
Foreign clients travelling in Canada for a short period of time Their foreign residential address
Foreign clients living in Canada for a longer period of time (such as a student) The person's temporary Canadian address

Occupation/business fields

Instructions for the occupation/business fields
Occupational/business fields Instructions
Occupation

When entering occupation information, you should be as descriptive as possible. For example, if the person is:

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

You can enter a numeric classification code and the code title in this field (for example, NOC – National Occupational Classification). However, a numeric code on its own is not sufficient as you need a written description of the occupation as explained above.

Note: If your client indicates that they are the manager of Blue Moon Auto Parts Ltd., you would enter “manager of auto parts company” in the occupation field and “Blue Moon Auto Parts Ltd.” in the name of employer field as explained below.

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 numeric classification code and the code title in this field (for example, NAICS – North American Industry Classification System). However, a numeric code on its own is not sufficient, as you need a written description of the nature of the entity’s principal business as explained above.

Identification fields

Instructions for the identification fields
Identification fields Instructions
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.

Note: Don’t report a Social Insurance Number (SIN) 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:

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.

How to provide the jurisdiction that issued the documentation used for identification
Type of jurisdiction What and how to provide
A country Enter that country as the jurisdiction of issue.
A province or state in Canada, the United States or Mexico Select the province or state code from the list of options.
A province or state outside Canada, the United States or Mexico

Provide:

  • that province or state name as the jurisdiction of issue, and
  • the corresponding country information

Telephone number fields

Instructions for the telephone number fields
Location of telephone number Instructions
Canada or the United States Enter the area code and local number (for example, 999-999-9999).
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 2-digit country code
  • a 3-digit city code, and
  • an 8-digit local number

Specific field instructions

This section contains instructions for the report fields and are laid out in the same order as they appear on the Large Cash Transaction Report form.

Note: For some fields, the instructions:

In this section

General information

Instructions for the fields under “General information”
Fields Instructions
* Reporting entity number

You must enroll in FINTRAC Web Reporting System (FWR) to submit reports electronically.

Provide the 7-digit identifier number assigned to you by FINTRAC at enrolment.

‡ Reporting entity report reference number

A number assigned to each report by:

  • you (the reporting entity), or
  • the individual or organization submitting the report on your behalf

This number must be unique to your business, meaning it can only be used once.

Which one of the following types of reporting entities best describes you?
Instructions for the question related to the type of reporting entities best describing you
Field Instructions
* Activity sector

Enter your business activity sector.

If you are involved in more than 1 type of business activity, indicate the one applicable to the transaction being reported.

If there is more than 1 business activity for 1 or more transactions on the report, select only 1 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 FINTRAC Web Reporting System (FWR) prior to submitting your report(s).

Report information

Indicate whether the report is related to 1 or multiple transactions that occurred within a consecutive 24-hour period.

When you provide a date and time, you must include the time zone. The fields below provide instructions for formatting.

Instructions for the fields under “Report information”
Fields Instructions
‡ Aggregation type

Indicate the type of aggregation used when multiple transactions occur within a consecutive 24-hour period:

  • conductor
  • on behalf of (third party)
  • beneficiary

If the report is for 1 transaction only, or for a ministerial directive, then aggregating transactions does not apply and you should select “Not applicable”.

Note: You must provide a start date/time and end date/time in the fields below, even if there is no aggregation and you select “not applicable” in the aggregation type field.

‡ 24-hour period start date and time

Provide the start date and time of the 24-hour period.

You must include the time zone (that is, UTC offset) in the 24-hour period start time field.

You must enter the start time in the following format: HH:MM:SS±ZZ:ZZ.

For example, 1:25:06 pm in Ottawa, Ontario would be reported as 13:25:06-05:00.

‡ 24-hour period end date and time

Provide the end date and time of the 24-hour period.

If your 24-hour period starts at 8:00 am, it would end at 7:59 am the following day.

You must include the time zone (that is, UTC offset) in the 24-hour period end time field.

The field above provides instructions for formatting.

Note: The start date/time and end date/time that you provide will establish the 24-hour period in which you look for possible aggregate transactions, and report all applicable transactions within.

Because you must aggregate on each party separately (conductor, on behalf of [third party], or beneficiary), it is possible to have multiple 24-hour windows (for example, a 24-hour window for conductors that is different than your 24-hour window for beneficiaries).

Ministerial directive

If a transaction is being reported to FINTRAC under a ministerial directive, then indicate this by selecting the ministerial directive in the report.

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

Note:

  • A Large Cash Transaction Report submitted under a ministerial directive can contain only 1 transaction and it must be below threshold. Therefore, if you indicate that the transaction is being submitted under a ministerial directive, you must also select “Not applicable” in the "Aggregation type" field.
  • Only 1 ministerial directive (IR2020) is available for a Large Cash Transaction Report.

Transaction information

Information about the transaction
Instructions for the fields under “Information about the transaction”
Fields Instructions
† Date and time of transaction

Enter the date and time of the large cash transaction.

It cannot be a future date and it must be different from the posting date.

A report can contain multiple transactions that took place in different time zones, but these transactions should all be within your 24-hour aggregation window that is indicated by the 24 hour period start date and time and the 24 hour period end date and time in the report.

Examples

If your report indicates that the 24-hour window is from 12:00 am to 11:59 pm Eastern Standard Time (EST) and you have transactions that occurred in both EST and Pacific Standard Time (PST) zones, you will need to do the following:

Instructions for transactions that took place in different time zones
Time zone where transactions have occurred Instructions
Eastern Standard Time (EST) zone Include the transactions in the report if they fall within your 24-hour window.
Pacific Standard Time (PST) zone

Convert the time of the transactions to EST to determine if they fall within your 24-hour window.

If they fall within the 24-hour window after conversion, then include them in the report.

You can include these transactions in PST or EST time as long as they are within your 24-hour window.

Your process to convert and report transactions that occur in different time zones should be documented in your policies and procedures to ensure your reporting is consistent.

For more information:

This field is mandatory, unless you:

  • are a financial entity, and
  • indicate that the transaction was a night deposit or quick drop

In this case, if you do not provide the date and time of transaction in this field, you must provide the date and time of posting (refer to the field Date and time of posting (if different from date and time of transaction)).

* Method of transaction

Select the method that describes how you received the cash.

If the method is not listed, select “Other.”

Note:

  • “Night deposit” and “quick drop” are only applicable to financial entities.
  • If you select either of these methods of transaction, you will not be required to complete the conductor information fields.
† If “Other,” please specify Provide a brief description on how you received the cash.
Date and time of posting (if different from date and time of transaction)

Enter the date and time the transaction is posted, if this differs from the date and time of the transaction. It cannot be a future date and it must be different from the transaction date.

This field is mandatory if:

  • the transaction was a night deposit or quick drop and the date of transaction was not provided, or
  • the posting date differs from the transaction date

In all other cases, this is a reasonable efforts field.

If only a posting date is available, you will still need to enter a posting time. In this case, select the same time zone as your 24-hour window and enter the time as 00:00:00 ensuring the date and time stays within your 24-hour window.

A report can contain multiple transactions that took place in different time zones. You must determine if these transactions fall within your 24-hour window as explained in the field description for Date and time of transaction.

‡ Threshold indicator

Indicate whether the value of the cash received for the transaction was above or below $10,000 at the time of receipt.

Select:

  • “above threshold” if the transaction is equal to $10,000 or more
  • “below threshold” if it is under $10,000
‡ Reporting entity transaction reference number

This is a unique number assigned to each transaction by:

  • you (the reporting entity), or
  • the individual or organization submitting the report on your behalf
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 Canadian dollar (CAD) to British pound sterling (GBP) for vacation purposes.
  • A client brings in cash to purchase a bank draft in order to buy a boat.

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

Information about where the transaction was conducted

Provide information about the physical location where the transaction took place.

For example, if the transaction was conducted at:

Instructions for the field under “Information about where the transaction was conducted”
Field Instructions
* 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.

The location number is:

  • created and assigned to you by FINTRAC during the enrolment process to FINTRAC Web Reporting System (FWR), and
  • maintained by your FWR administrator.

For more information about this, contact your FWR administrator.

Starting action

Provide information about how the transaction was started.

Instructions for the fields under “Starting action”
Fields Instructions
* Amount

Enter the total amount of cash involved in the starting action.

If this amount was not in Canadian dollars (CAD), do not convert it to CAD but provide the currency type in the next field.

* Currency

Enter the currency of the starting action, including if it was in Canadian dollars.

If the currency type is not in the list provided, you must select “Other” and provide the full name of the currency.

How was the cash obtained?

This is how the conductor initially acquired the cash used for the transaction, not where the funds may have been transferred from.

For example, you can obtain cash 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 cash 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 cash
  • 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.

‡ Does this transaction involve a deposit to a business account?

This field is a "Yes/No" question.

A business account means a business account at an account-based reporting entity such as:

  • a financial entity
  • securities dealer, or
  • casino
Source of cash

If you have information on any source of cash involved in the transaction, you must report it.

If there are multiple sources, you must provide information for each source.

Source of cash – person
Instructions for the fields under “Source of cash – person”
Fields Instructions
† Surname Refer to Name fields under “Standardized field instructions”.
† Given name Same instructions (Name fields)
Other/initial Same instructions (Name fields)
Account number

Provide the account number for the source of cash.

It is acceptable to include the financial institution number and branch number as part of an account number.

Policy number Instructions not specified
Identifying number If there is no account or policy number, provide an identifying number if available.
Source of cash – entity
Instructions for the fields under “Source of cash – entity”
Fields Instructions
† Name of entity Refer to Name fields under “Standardized field instructions”.
Account number

Provide the account number for the source of cash.

It is acceptable to include the financial institution number and branch number as part of an account number.

Policy number Instructions not specified
Identifying number If there is no account or policy number, provide an identifying number if available.
Note about the source of cash fields

Although the following 3 fields are all about how the conductor obtained the cash and the source of cash, they are different:

The following example demonstrates their differences.

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 cash fields would be completed as follows:

How the source of cash fields would be completed for this example
Source of cash fields Information provided in the field
How was the cash obtained? Sale of car
Was information about the source (person / entity) of cash obtained? Yes
Source of cash Griffin Grey

For more information on completing these fields, please refer to Starting action and Source of cash under the “Specific field instructions”.

Conductor – person

Provide all the information you have on 1, or multiple persons specified as the conductors of the transaction.

Instructions for the fields under “Conductor – person”
Fields Instructions
† Surname Refer to Name fields under “Standardized field instructions”.
† Given name Same instructions (Name fields)
Other/Initial Same instructions (Name fields)
Alias Same instructions (Name fields)
† Client number A unique identifying number assigned by the reporting entity to the person conducting the transaction.
Apartment/Room/Suite/Unit number Refer to Address fields under “Standardized field instructions”.
House/Building number Same instructions (Address fields)
† Street address Same instructions (Address fields)
† City Same instructions (Address fields)
District Same instructions (Address fields)
† Country Same instructions (Address fields)
† Province or state (code) Same instructions (Address fields)
† Province or state (name) Same instructions (Address fields)
Sub-province and/or sub-locality Same instructions (Address fields)
Postal or zip code Same instructions (Address fields)
Unstructured address details Refer to Unstructured address field under “Standardized field instructions”.
Telephone number Refer to Telephone number fields under “Standardized field instructions”.
Extension Same instructions (Telephone number fields)
Email address Instructions not specified
† Date of birth Instructions not specified
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.

† Occupation Refer to Occupation/business fields under “Standardized field instructions”.
Name of employer Same instructions (Occupation/business fields)
Identification of the conductor – person
Instructions for the fields under “Identification of the conductor – person”
Fields Instructions
† Identifier type Refer to Identification fields under “Standardized field instructions”.
† If “Other”, please specify Same instructions (Identification fields)
† Number associated with identifier type Same instructions (Identification fields)
† Jurisdiction of issue (country) Same instructions (Identification fields)
† Jurisdiction of issue (province or state) (code) Same instructions (Identification fields)
† Jurisdiction of issue (province or state) (name) Same instructions (Identification fields)
Conductor – entity

Provide all the information you have on 1, or multiple entities specified as the conductors of the transaction.

Instructions for the fields under “Conductor – entity”
Fields Instructions
† Name of entity Refer to Name fields under “Standardized field instructions”.
† Client number A unique identifying number assigned by the reporting entity to the entity conducting the transaction.
Apartment/Room/Suite/Unit number Refer to Address fields under “Standardized field instructions”.
House/Building number Same instructions (Address fields)
† Street address Same instructions (Address fields)
† City Same instructions (Address fields)
District Same instructions (Address fields)
† Country Same instructions (Address fields)
† Province or state (code) Same instructions (Address fields)
† Province or state (name) Same instructions (Address fields)
Sub-province and/or sub-locality Same instructions (Address fields)
Postal or zip code Same instructions (Address fields)
Unstructured address details Refer to Unstructured address field under “Standardized field instructions”.
Telephone number Refer to Telephone number fields under “Standardized field instructions”.
Extension Same instructions (Telephone number fields)
Email address Instructions not specified
† Nature of entity’s principal business Refer to Occupation/business fields under “Standardized field instructions”.
‡ Do you have incorporation or registration information? Instructions not specified
Incorporated or registered? Instructions not specified
† 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.

If the jurisdiction is a province or state:

  • in Canada, the United States or Mexico, select the code from the list of options
  • outside Canada, the United States or Mexico, provide the name of the province or state
† 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.

If the jurisdiction is a province or state:

  • in Canada, the United States or Mexico, select the code from the list of options
  • outside Canada, the United States or Mexico, provide the name of the province or state

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

Identification of the conductor – 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.

Instructions for the fields under “Identification of the conductor – entity”
Fields Instructions
† Identifier type Refer to Identification fields under “Standardized field instructions”.
† If “Other”, please specify Same instructions (Identification fields)
† Number associated with identifier type Same instructions (Identification fields)
† Jurisdiction of issue (country) Same instructions (Identification fields)
† Jurisdiction of issue (province or state) (code) Same instructions (Identification fields)
† Jurisdiction of issue (province or state) (name) Same instructions (Identification fields)
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 3 persons who are authorized to:

Instructions for the fields under “Person authorized to bind the entity or act with respect to the account”
Fields Instructions
† Surname Refer to Name fields under “Standardized field instructions”.
† Given name Same instructions (Name fields)
Other/Initial Same instructions (Name fields)
Conductor (business account)

Provide the name of conductor (person or entity) if you indicated that this transaction involves a deposit to a business account.

A deposit into a business account is only applicable at an account-based reporting entity such as:

Instructions for the fields under “Conductor (business account)”
Fields Instructions
† Surname Refer to Name fields under “Standardized field instructions”.
† Given name Same instructions (Name fields)
Other/Initial Same instructions (Name fields)
† Name of entity Same instructions (Name fields)
On behalf of indicator
Instructions for the field under “On behalf of indicator”
Field Instructions
† Was this transaction conducted on behalf of another person or entity?

This field is a “Yes/No” question.

Select “Yes” if the transaction was conducted 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
Information about the third party (person on whose behalf the transaction was conducted)

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

Instructions for the fields under “Information about the third party (person on whose behalf the transaction was conducted)”
Fields Instructions
† Surname Refer to Name fields under “Standardized field instructions”.
† Given name Same instructions (Name fields)
Other/Initial Same instructions (Name fields)
Alias Same instructions (Name fields)
Client number Instructions not specified
Apartment/Room/Suite/Unit number Refer to Address fields under “Standardized field instructions”.
House/Building number Same instructions (Address fields)
† Street address Same instructions (Address fields)
† City Same instructions (Address fields)
District Same instructions (Address fields)
† Country Same instructions (Address fields)
† Province or state (code) Same instructions (Address fields)
† Province or state (name) Same instructions (Address fields)
Sub-province and/or sub-locality Same instructions (Address fields)
Postal or zip code Same instructions (Address fields)
Unstructured address details Refer to Unstructured address field under “Standardized field instructions”.
Telephone number Refer to Telephone number fields under “Standardized field instructions”.
Extension Same instructions (Telephone number fields)
Email address Instructions not specified
Date of birth Instructions not specified
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.

† Occupation Refer to Occupation/business fields under “Standardized field instructions”.
Name of employer Same instructions (Occupation/business fields)
Identification of the third party (person on whose behalf the transaction was conducted)
Instructions for the fields under “Identification of the third party (person on whose behalf the transaction was conducted)”
Fields Instructions
Identifier type Refer to Identification fields under “Standardized field instructions”.
† If “Other”, please specify Same instructions (Identification fields)
Number associated with identifier type Same instructions (Identification fields)
Jurisdiction of issue (country) Same instructions (Identification fields)
Jurisdiction of issue (province or state) (code) Same instructions (Identification fields)
Jurisdiction of issue (province or state) (name) Same instructions (Identification fields)
Relationship of the third party (person named above) to the person or entity conducting the transaction
Instructions for the fields under “Relationship of the third party (person named above) to the person or entity conducting the transaction”
Fields Instructions
† Relationship

Select the relationship of the “on behalf of” party to the person or entity conducting 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 Instructions not specified
Information about the third party (entity on whose behalf the transaction was conducted)

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

Instructions for the fields under “Information about the third party (entity on whose behalf the transaction was conducted)”
Fields Instructions
† Name of entity Refer to Identification fields under “Standardized field instructions”.
Client number Instructions not specified
Apartment/Room/Suite/Unit number Refer to Address fields under “Standardized field instructions”.
House/Building number Same instructions (Address fields)
† Street address Same instructions (Address fields)
† City Same instructions (Address fields)
District Same instructions (Address fields)
† Country Same instructions (Address fields)
† Province or state (code) Same instructions (Address fields)
† Province or state (name) Same instructions (Address fields)
Sub-province and/or sub-locality Same instructions (Address fields)
Postal or zip code Same instructions (Address fields)
Unstructured address details Refer to Unstructured address field under “Standardized field instructions”.
Telephone number Refer to Telephone number fields under “Standardized field instructions”.
Extension Same instructions (Telephone number fields)
Email address Instructions not specified
† Nature of entity’s principal business Refer to Occupation/business fields under “Standardized field instructions”.
‡ Do you have incorporation or registration information? Instructions not specified
Incorporated or registered? Instructions not specified
† Incorporation number / † Jurisdiction of issue (country, province or state)

Provide the incorporation number and jurisdiction of issue of the entity on whose behalf the transaction was conducted for each jurisdiction where the entity is incorporated.

If the jurisdiction is a province or state:

  • in Canada, the United States or Mexico, select the code from the list of options
  • outside Canada, the United States or Mexico, provide the name of the province or state
† Registration number / † Jurisdiction of issue (country, province or state)

Provide the registration number and jurisdiction of issue of the entity on whose behalf the transaction was conducted for each jurisdiction where the entity is registered.

If the jurisdiction is a province or state:

  • in Canada, the United States or Mexico, select the code from the list of options
  • outside Canada, the United States or Mexico, provide the name of the province or state

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

Identification of the third party (entity on whose behalf the transaction was conducted)

Provide the following information that was used to verify the identity of the entity on whose behalf the transaction was conducted.

For some entities, this information may be the same as the registration or incorporation information.

Instructions for the fields under “Identification of the third party (entity on whose behalf the transaction was conducted)”
Fields Instructions
Identifier type Refer to Identification fields under “Standardized field instructions”.
† If “Other”, please specify Same instructions (Identification fields)
Number associated with identifier type Same instructions (Identification fields)
Jurisdiction of issue (country) Same instructions (Identification fields)
Jurisdiction of issue (province or state) (code) Same instructions (Identification fields)
Jurisdiction of issue (province or state) (name) Same instructions (Identification fields)
Person authorized to bind the third party (entity) or act with respect to the account (maximum 3)
Instructions for the fields under “Person authorized to bind the third party (entity) or act with respect to the account”
Fields Instructions
Surname Refer to Name fields under “Standardized field instructions”.
Given name Same instructions (Name fields)
Other/Initial Same instructions (Name fields)
Relationship of the third party (entity named above) to the person or entity conducting the transaction
Instructions for the fields under “Relationship of the third party (entity named above) to the person or entity conducting the transaction”
Fields Instructions
† Relationship

Select the relationship of the “on behalf of” party to the person or entity conducting 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 Instructions not specified

Completing action

Provide information about how the transaction was completed.

* Details of disposition

This field describes what happened to the cash involved in the transaction. Select the following disposition(s) based on the client’s instructions.

Instructions for types of disposition to select for the field “* Details of disposition”
Types of dispositions to select from Instructions
Added to virtual currency wallet

Select when virtual currency is added to a virtual currency wallet.

This cannot be the first disposition. For example, the cash received must be exchanged to virtual currency (first disposition) before it can be added to a virtual currency wallet (subsequent disposition).

Denomination exchange Select when the cash received is exchanged from one unit value to another (for example, 20s to 100s) within the same currency.
Deposit to account Select when cash is deposited into an account at an account-based reporting entity, such as a bank or credit union.
Exchange to fiat currency

Select for:

  • a fiat-to-fiat currency exchange (for example, CAD to USD), or
  • a virtual currency-to-fiat exchange (for example, bitcoin to CAD)

A virtual currency-to-fiat exchange cannot be the first disposition. The cash received must be exchanged to virtual currency (first disposition) before the virtual currency can be exchanged to fiat (subsequent disposition).

Exchange to virtual currency

Select for:

  • a fiat-to-virtual currency exchange (for example, CAD to bitcoin), or
  • a virtual currency-to-virtual currency exchange (for example, bitcoin to Ethereum (ETH))

A virtual currency-to-virtual currency exchange cannot be the first disposition. The cash received must be first exchanged to virtual currency (first disposition) before the virtual currency can be exchanged to another virtual currency.

Holding funds Select 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 Select when a client buys or makes a deposit to a Guaranteed Investment Contract (GIC), RRSP, stock from an exchange (for example, Toronto Stock Exchange (TSX)), or any other such investments.
Issued cheque

Select for the issuance of:

  • a certified cheque
  • a disbursement through a casino cheque, etc.
Life insurance policy purchase or deposit Select when a client buys or puts a deposit down to purchase a life insurance policy.
Outgoing domestic funds transfer Select when the transaction instructions are for the transfer of funds within Canada.
Outgoing email money transfer Select when the funds are transferred using a recipient's email address.
Outgoing international funds transfer Select when the transaction instructions are for the transfer of funds outside of Canada.
Outgoing mobile money transfer Select when the funds are transferred using a recipient's phone number.
Outgoing virtual currency transfer

Select when a reporting entity transfers virtual currency from a client’s virtual currency wallet to another virtual currency wallet.

This cannot be the first disposition. For example, the cash received must be exchanged to virtual currency (first disposition) before it can be added to a virtual currency wallet (second disposition) and then transferred to another virtual currency wallet.

Purchase of bank draft

Select 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

Select when a client purchases a casino product.

A casino product can include, but is not limited to:

  • chips
  • plaques, and
  • tokens
Purchase of jewellery

Select when a client purchases jewellery from a dealer in precious metals and precious stones.

Jewellery means objects made of precious metals, precious stones or pearls that are intended for personal adornment.

Purchase of money order

Select 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

Select when a client purchases precious metals from a dealer in precious metals and precious stones.

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

Select when a client purchases precious stones from a dealer in precious metals and precious stones.

Precious stones means:

  • diamonds
  • sapphires
  • emeralds
  • tanzanites
  • rubies, or
  • alexandrites
Purchase of prepaid payment product/card

Select when a client purchases a prepaid payment product.

The product must be tied to a prepaid payment product account held by a financial entity.

A prepaid payment product 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 prepaid payment product account held with the financial entity in advance of a transaction taking place.

Real estate purchase or deposit Select when a client purchases or puts a deposit down on real estate.
Purchase of / Payment for goods Select 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 Select 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

Select 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”.

Note: If the disposition is “Other”, provide details that describe the disposition of the transaction in the field “† If “Other”, please specify”.

Number of dispositions in a completing action

A completing action may have 1 or more dispositions, depending on the client’s instructions and your business process.

Example 1: A single disposition

Your client brings in $12,000 cash and instructs to deposit the entire amount into the client’s savings account.

There is only 1 disposition:

  • “deposit to account”.
Example 2: Multiple dispositions

Your client brings in $12,000 cash and instructs to:

  • deposit $5,000 into the client’s savings account, and
  • exchange $7,000 to bills in a larger denomination

There are 2 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 to transfer $12,000 to a friend outside Canada.

Financial entity

If your business process is to:

  • deposit the cash into the client’s account before the amount is sent to the client’s friend, there are 2 dispositions:
    • “deposit to account”, and
    • “outgoing international funds transfer”
  • send the amount to the friend without depositing into an account, then there is 1 disposition:
    • “outgoing international funds transfer”

Money services business

If your business process is to:

  • hold the funds until a later date on which you send the amount, there are 2 dispositions:
    • “holding funds”, and
    • “outgoing international funds transfer”
  • send the amount to the friend without holding the funds, then there is 1 disposition:
    • “outgoing international funds transfer”
Completing action fields – continued
Instructions for the “Completing action fields – continued”
Fields Instructions
† 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 Instructions not specified
† If “Other”, please specify Instructions not specified
Exchange rate Provide the rate of exchange that you used for the transaction.
† Value in Canadian dollars

Provide the Canadian dollar value of the disposition if it is not funds.
For example, provide the value of the virtual currency, jewellery, precious metals or precious stones that was 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.

† 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 Instructions not specified
† Branch number Instructions not specified
† 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 (for example, a money services business), but the transaction involves an account at an account-based reporting entity (for example, a financial entity), provide that account number in this field.

† Account type Instructions not specified
† If “Other”, please specify Instructions not specified
† Account currency Instructions not specified
Date account opened Instructions not specified
Account holder – person
Instructions for the fields under “Account holder – person”
Fields Instructions
† Surname Refer to Name fields under “Standardized field instructions”.
† Given name Same instructions (Name fields)
Other/Initial Same instructions (Name fields)
Account holder – entity
Instructions for the field under “Account holder – entity”
Field Instructions
† Name of entity Refer to Name fields under “Standardized field instructions”.
Involved in the completing action
Instructions for the field under “Involved in the completing action”
Field Instructions
‡ Was there any other person or entity involved in the completing action? Instructions not specified
Person involved in the completing action

If you have information about other persons involved in the completing action, you must include it.

Note: These persons cannot be:

Instructions for the fields under “Person involved in the completing action”
Fields Instructions
† Surname Refer to Name fields under “Standardized field instructions”.
† Given name Same instructions (Name fields)
Other/initial Same instructions (Name fields)
† Account number

Provide the account number of the person involved in the completing action.

It is acceptable to include the financial institution number and branch number as part of an account number.

† Policy number Instructions not specified
† Identifying number Instructions not specified
Entity involved in the completing action

If you have information about other entities involved in the completing action, you must include it.

Note: These entities cannot be:

Instructions for the fields under “Entity involved in the completing action”
Fields Instructions
† Name of entity Refer to Name fields under “Standardized field instructions”.
† Account number

Provide the account number of the entity involved in the completing action.

It is acceptable to include the financial institution number and branch number as part of an account number.

† Policy number Instructions not specified
† Identifying number Instructions not specified
Beneficiary

Provide beneficiary information for each completing action.

A beneficiary, for example, can be:

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
Instructions for the fields under “Person beneficiary”
Fields Instructions
† Surname Refer to Name fields under “Standardized field instructions”.
† Given name Same instructions (Name fields)
Other/Initial Same instructions (Name fields)
Alias Same instructions (Name fields)
Client number Instructions not specified
Apartment/Room/Suite/Unit number Refer to Address fields under “Standardized field instructions”.
House/Building number Same instructions (Address fields)
Street address Same instructions (Address fields)
City Same instructions (Address fields)
District Same instructions (Address fields)
Country Same instructions (Address fields)
Province or state (code) Same instructions (Address fields)
Province or state (name) Same instructions (Address fields)
Sub-province and/or sub-locality Same instructions (Address fields)
Postal or zip code Same instructions (Address fields)
Unstructured address details Refer to Unstructured address field under “Standardized field instructions”.
Telephone number Refer to Telephone number fields under “Standardized field instructions”.
Extension Same instructions (Telephone number fields)
Email address Instructions not specified
Date of birth Instructions not specified
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.

Occupation Refer to Occupation/business fields under “Standardized field instructions”.
Name of employer Same instructions (Occupation/business fields)
Identification of the person beneficiary
Instructions for the fields under “Identification of the person beneficiary”
Fields Instructions
Identifier type Refer to Identification fields under “Standardized field instructions”.
† If “Other”, please specify Same instructions (Identification fields)
Number associated with identifier type Same instructions (Identification fields)
Jurisdiction of issue (country) Same instructions (Identification fields)
Jurisdiction of issue (province or state) (code) Same instructions (Identification fields)
Jurisdiction of issue (province or state) (name) Same instructions (Identification fields)
Relationship of the beneficiary (person named above) to the person or entity conducting the transaction
Instructions for the fields under “Relationship of the beneficiary (person named above) to the person or entity conducting the transaction”
Fields Instructions
Relationship

Select the relationship of the beneficiary to the person or entity conducting the transaction.

If the beneficiary and conductor are the same, select “self.”

† If “Other”, please specify Instructions not specified
Entity beneficiary
Instructions for the fields under “Entity beneficiary”
Fields Instructions
† Name of entity Refer to Identification fields under “Standardized field instructions”.
Client number Instructions not specified
Apartment/Room/Suite/Unit number Refer to Address fields under “Standardized field instructions”.
House/Building number Same instructions (Address fields)
Street address Same instructions (Address fields)
City Same instructions (Address fields)
District Same instructions (Address fields)
Country Same instructions (Address fields)
Province or state (code) Same instructions (Address fields)
Province or state (name) Same instructions (Address fields)
Sub-province and/or sub-locality Same instructions (Address fields)
Postal or zip code Same instructions (Address fields)
Unstructured address details Refer to Unstructured address field under “Standardized field instructions”.
Telephone number Refer to Telephone number fields under “Standardized field instructions”.
Extension Same instructions (Telephone number fields)
Email address Instructions not specified
Nature of entity’s principal business Refer to Occupation/business fields under “Standardized field instructions”.
‡ Do you have incorporation or registration information? Instructions not specified
Incorporated or registered? Instructions not specified
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.

If the jurisdiction is a province or state:

  • in Canada, the United States or Mexico, select the code from the list of options
  • outside Canada, the United States or Mexico, provide the name of the province or state
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.

If the jurisdiction is a province or state:

  • in Canada, the United States or Mexico, select the code from the list of options
  • outside Canada, the United States or Mexico, provide the name of the province or state

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

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.

Instructions for the fields under “Identification of the entity beneficiary”
Fields Instructions
Identifier type Refer to Identification fields under “Standardized field instructions”.
† If “Other”, please specify Same instructions (Identification fields)
Number associated with identifier type Same instructions (Identification fields)
Jurisdiction of issue (country) Same instructions (Identification fields)
Jurisdiction of issue (province or state) (code) Same instructions (Identification fields)
Jurisdiction of issue (province or state) (name) Same instructions (Identification fields)
Person authorized to bind the entity beneficiary or act with respect to the account (maximum 3)
Instructions for the fields under “Person authorized to bind the entity beneficiary or act with respect to the account”
Fields Instructions
Surname Refer to Name fields under “Standardized field instructions”.
Given name Same instructions (Name fields)
Other/Initial Same instructions (Name fields)
Relationship of the entity beneficiary named above to the person or entity conducting the transaction
Instructions for the fields under “Relationship of the entity beneficiary named above to the person or entity conducting the transaction”
Fields Instructions
Relationship

Select the relationship of the beneficiary to the person or entity conducting the transaction.

If the beneficiary and conductor are the same, select “self.”

† If “Other”, please specify Instructions not specified

Annex B: Scenarios

The following scenarios demonstrate form completion and the expected field information in a Large Cash Transaction Report based on the client’s instructions and transaction(s) in each scenario.

Note about these scenarios

In this annex

Scenario B.1: Multiple transactions

Scenario

Bruno Brown walked into XYZ Bank and instructed the bank to deposit:

Bruno Brown advised the bank that he was a customer of Super Fun Video Games Company.

XYZ Bank was not able to obtain the source of cash for the $5,000 CAD nor the $5,000 USD.

Expected field information in the report

Because XYZ Bank’s process is to treat these instructions as 2 transactions, the bank submits a Large Cash Transaction Report with the following information.

General information – Scenario B.1
General information about XYZ Bank
Fields Information provided by XYZ Bank
Reporting entity number The reporting entity number assigned to XYZ Bank when it enrolled with FINTRAC Web Reporting System (FWR)
Reporting entity report reference number

The unique number for this report that was assigned by:

  • XYZ Bank, or
  • its service provider
Activity sector Bank
Contact information for this report Information about the person at XYZ Bank that FINTRAC can liaise with in the event that a follow up is required
Aggregation type Conductor
24-hour period for aggregation XYZ Bank’s 24-hour window for aggregation as indicated by the start and end times
Transaction information – Scenario B.1
“Transaction information” provided by XYZ Bank
Fields Information provided for transaction 1 of 2 Information provided for transaction 2 of 2
Date and time of transaction The date and time the cash was received by XYZ Bank The date and time the cash was received by XYZ Bank
Method of transaction In person In person
Threshold indicator Below threshold Below threshold
Reporting entity transaction reference number

The unique number for this transaction that was assigned by:

  • XYZ Bank, or
  • its service provider

The unique number for this transaction that was assigned by:

  • XYZ Bank, or
  • its service provider
Reporting entity location number Information about where the transaction took place Information about where the transaction took place
Starting action – Scenario B.1
“Starting action” information provided by XYZ Bank
Fields Information provided for starting action 1 of transaction 1 Information provided for starting action 1 of transaction 2
Amount 5,000 5,000
Currency CAD USD
Was information about the source (person /entity) of cash obtained? No No
Does this transaction involve a deposit to a business account other than a night deposit or quick drop? Yes No
Conductor information

Information that XYZ Bank has on Bruno Brown, including:

  • name
  • alias
  • client number
  • address
  • telephone number
  • email address
  • date of birth
  • country of residence
  • occupation
  • name of employer, and
  • identification details

Information that XYZ Bank has on Bruno Brown, including:

  • name
  • alias
  • client number
  • address
  • telephone number
  • email address
  • date of birth
  • country of residence
  • occupation
  • name of employer, and
  • identification details
Was this transaction conducted on behalf of another person or entity? No No
Completing action – Scenario B.1
“Completing action” information provided by XYZ Bank
Fields Information provided for completing action 1 of transaction 1 Information provided for completing action 1 of transaction 2
Details of disposition Deposit to account Deposit to account
Amount 5,000 5,000
Currency CAD USD
Financial institution number and branch number For XYZ Bank For XYZ Bank
Account number and account information For the business account of Super Fun Video Games Company For the personal account of Bruno Brown
Account holder Super Fun Video Games Company Bruno Brown
Was there any other person or entity involved in the completing action? No No
Beneficiary information

Information that XYZ Bank has on Super Fun Video Games Company including:

  • name
  • client number
  • address
  • telephone number
  • email address
  • nature of principal business
  • registration/incorporation details
  • identification details
  • person(s) authorized to bind the entity or act with respect to the account

Information that XYZ Bank has on Bruno Brown including:

  • name
  • alias
  • client number
  • address
  • telephone number
  • email address
  • date of birth
  • country of residence
  • occupation
  • name of employer, and
  • identification details
Relationship of the entity named above (beneficiary) to the person conducting the transaction Vendor / Supplier Self

Infographic summarizing scenario B.1

Infographic summarizing scenario B.1: Multiple transaction
Infographic summarizing scenario B.1: Multiple transaction

Scenario B.2: Multiple completing actions

Scenario

Odette Orange brings $10,500 cash to ABC Credit Union. Odette Orange instructs the teller to:

The credit union follows its policies and procedures on reasonable measures and asks Odette Orange where the money came from.

Odette Orange tells the credit union that she obtained the cash when she sold her boat to Benjamin Black.

Although Odette Orange is able to provide Benjamin Black’s name to the credit union, she is not able to provide any other source of cash information (such as account number, policy number or identifying number).

The exchange rate to convert CAD into Euro is 0.680586 and Olive Green has an account at The Celadon Bank in Dublin, Ireland.

In order to complete Odette Orange’s instructions, the teller follows the credit union’s business process and does the following:

Expected field information in the report

ABC Credit Union submits a Large Cash Transaction Report with the following information.

General information – Scenario B.2
General information about ABC Credit Union
Fields Information provided by ABC Credit Union
Reporting entity number The reporting entity number assigned to ABC Credit Union when it enrolled with FINTRAC Web Reporting System (FWR)
Reporting entity report reference number

The unique number for this report that was assigned by:

  • ABC Credit Union, or
  • its service provider
Activity sector Credit Union
Contact information for this report Information about the person at ABC Credit Union that FINTRAC can liaise with in the event that a follow up is required
Aggregation type Not applicable
24-hour period for aggregation ABC Credit Union’s 24-hour window for aggregation as indicated by the start and end times
Transaction information – Scenario B.2
“Transaction information” provided by ABC Credit Union
Fields Information provided for transaction 1 of 1
Date and time of transaction The date and time the cash was received by ABC Credit Union
Method of transaction In person
Threshold indicator Above threshold
Reporting entity transaction reference number

The unique number for this transaction that was assigned by:

  • ABC Credit Union, or
  • its service provider
Purpose of transaction Saving for vacation and wedding gift for friend in Ireland
Reporting entity location number Information about where the transaction took place
Starting action – Scenario B.2
“Starting action” information provided by ACB Credit Union
Fields Information provided for starting action 1 of transaction 1
Amount 10,500
Currency CAD
How was the cash obtained? Sale of boat
Was information about the source (person/entity) of cash obtained? Yes
Source of cash Benjamin Black
Does this transaction involve a deposit to a business account other than a night deposit or quick drop? No
Conductor information

Information that ABC Credit Union has on Odette Orange including:

  • name
  • alias
  • client number
  • address
  • telephone number
  • email address
  • date of birth
  • country of residence
  • occupation
  • name of employer, and
  • identification details
Was this transaction conducted on behalf of another person or entity? No
Completing action – Scenario B.2
“Completing action” information provided by ABC Credit Union
Fields Information provided for completing action 1 of transaction 1 Information provided for completing action 2 of transaction 1 Information provided for completing action 3 of transaction 1
Details of disposition Deposit to account Exchange to fiat currency Outgoing international funds transfer
Amount 10,500 3,402.93 3,402.93
Currency CAD EUR EUR
Exchange rate [Field left blank because not applicable] 0.680586 [Field left blank because not applicable]
Financial institution number and branch number For ABC Credit Union [Field left blank because not applicable] [Field left blank because not applicable]
Account number and account information For the personal account of Odette Orange [Field left blank because not applicable] For Olive Green’s account at The Celadon Bank in Dublin, Ireland
Account holder Odette Orange [Field left blank because not applicable] Olive Green
Was there any other person or entity involved in the completing action? No No No
Beneficiary information

Information that ABC Credit Union has on Odette Orange including:

  • name
  • alias
  • client number
  • address
  • telephone number
  • email address
  • date of birth
  • country of residence
  • occupation
  • name of employer, and
  • identification details

Information that ABC Credit Union has on Odette Orange including:

  • name
  • alias
  • client number
  • address
  • telephone number
  • email address
  • date of birth
  • country of residence
  • occupation
  • name of employer, and
  • identification details

Olive Green’s name.

Also, if obtained, information about Olive Green including:

  • alias
  • client number
  • address
  • telephone number
  • email address
  • date of birth
  • country of residence
  • occupation
  • name of employer, and
  • identification details
Relationship of the person named above (beneficiary) to the person conducting the transaction Self Self Friend

Infographic summarizing scenario B.2

Infographic summarizing scenario B.2: Multiple completing actions
Infographic summarizing scenario B.2: Multiple completing actions

Scenario B.3: Virtual currency exchange

Scenario

Vicky Violet walked into the ABC Exchange Company and exchanged $20,000 in cash for Litecoin.

Expected field information in the report

ABC Exchange Company submits a Large Cash Transaction Report with the following information.

General information – Scenario B.3
General information about ABC Exchange Company
Fields Information provided by ABC Exchange Company
Reporting entity number The reporting entity number assigned to ABC Exchange Company when it enrolled with FINTRAC Web Reporting System (FWR)
Reporting entity report reference number

The unique number for this report that was assigned by:

  • ABC Exchange Company, or
  • its service provider
Activity sector Money services business
Contact information for this report Information about the person at ABC Exchange Company that FINTRAC can liaise with in the event that a follow up is required
Aggregation type Not applicable
24-hour period for aggregation ABC Exchange Company’s 24-hour window for aggregation as indicated by the start and end times
Transaction information – Scenario B.3
“Transaction information” provided by ABC Exchange Company
Fields Information provided for transaction 1 of 1
Date and time of transaction The date and time the cash was received by ABC Exchange Company
Method of transaction In person
Threshold indicator Above threshold
Reporting entity transaction reference number

The unique number for this transaction that was assigned by:

  • ABC Exchange Company, or
  • its service provider
Reporting entity location number Information about where the transaction took place
Starting action – Scenario B.3
“Starting action” information provided by ABC Exchange Company
Fields Information provided for starting action 1 of transaction 1
Amount 20,000
Currency CAD
Was information about the source (person /entity) of cash obtained? No
Does this transaction involve a deposit to a business account other than a night deposit or quick drop? No
Conductor information

Information that ABC Exchange Company has on Vicky Violet, including:

  • name
  • alias
  • client number
  • address
  • telephone number
  • email address
  • date of birth
  • country of residence
  • occupation
  • name of employer, and
  • identification details
Was this transaction conducted on behalf of another person or entity? No
Completing action – Scenario B.3
“Completing action” information provided by ABC Exchange Company
Fields Information provided for completing action 1 of transaction 1
Details of disposition Exchange to virtual currency
Amount 279.18
Virtual currency type Litecoin
Exchange rate 0.013959
Reference number and other related numbers Reference number assigned by ABC Exchange Company or its service provider, if applicable, and any other related numbers
Was there any other person or entity involved in the completing action? No
Beneficiary information

Information that ABC Exchange Company has on Vicky Violet including:

  • name
  • alias
  • client number
  • address
  • telephone number
  • email address
  • date of birth
  • country of residence
  • occupation
  • name of employer, and
  • identification details
Relationship of the entity named above (beneficiary) to the person conducting the transaction Self

Infographic summarizing scenario B.3

Infographic summarizing scenario B.3: Virtual currency exchange
Infographic summarizing scenario B.3: Virtual currency exchange

Scenario B.4a: Outgoing international funds transfer – Person conductor

Scenario

Thomas Tangerine walked into One Stop Money Shop with 10,000 where he:

Expected field information in the report

One Stop Money Shop submits a Large Cash Transaction Report with the following information.

General information – Scenario B.4a
General information about One Stop Money Shop
Fields Information provided by One Stop Money Shop
Reporting entity number The reporting entity number assigned to One Stop Money Shop when it enrolled with FINTRAC Web Reporting System (FWR)
Reporting entity report reference number

The unique number for this report that was assigned by:

  • One Stop Money Shop, or
  • its service provider
Activity sector Money services business
Contact information for this report Information about the person at One Stop Money Shop that FINTRAC can liaise with in the event that a follow up is required
Aggregation type Not applicable
24-hour period for aggregation One Stop Money Shop’s 24-hour window for aggregation as indicated by the start and end times
Transaction information – Scenario B.4a
“Transaction information” provided by One Stop Money Shop
Fields Information provided for transaction 1 of 1
Date and time of transaction The date and time the cash was received by One Stop Money Shop
Method of transaction In person
Threshold indicator Above threshold
Reporting entity transaction reference number

The unique number for this transaction that was assigned by:

  • One Stop Money Shop, or
  • its service provider
Purpose of transaction Payment for kitchen supplies (pots and pans)
Reporting entity location number Information about where the transaction took place
Starting action – Scenario B.4a
“Starting action” information provided by One Stop Money Shop
Fields Information provided for starting action 1 of transaction 1
Amount 10,000
Currency EUR
Was information about the source (person /entity) of cash obtained? No
Does this transaction involve a deposit to a business account other than a night deposit or quick drop? No
Conductor information

Information that One Stop Money Shop has on Thomas Tangerine, including:

  • name
  • alias
  • client number
  • address
  • telephone number
  • email address
  • date of birth
  • country of residence
  • occupation
  • name of employer, and
  • identification details
Was this transaction conducted on behalf of another person or entity? Yes
Information about the third party on whose behalf the transaction was conducted

Information that One Stop Money Shop has or obtained on Kitchen Supply Company including:

  • name
  • client number
  • address
  • telephone number
  • email address
  • nature of principal business
  • registration/incorporation details
  • identification details, and
  • person(s) authorized to bind the entity or act with respect to the account
Relationship of the entity named above (third party) to the person conducting the transaction Employer
Completing action – Scenario B.4a
“Completing action” information provided by One Stop Money Shop
Fields Information provided for completing action 1 of transaction 1
Details of disposition Outgoing international funds transfer
Amount 10,000
Currency EUR
Reference number and other related numbers Reference number assigned by One Stop Money Shop or its service provider, if applicable, and any other related numbers
Account number and account information For ABC Enterprises’ bank account in Italy
Account holder ABC Enterprises
Was there any other person or entity involved in the completing action? No
Beneficiary information

Name of ABC Enterprises

Also, if obtained, information about ABC Enterprises including:

  • client number
  • address
  • telephone number
  • email address
  • nature of principal business
  • registration/incorporation details
  • identification details, and
  • person(s) authorized to bind the entity or act with respect to the account
Relationship of the entity named above (beneficiary) to the person conducting the transaction Vendor / Supplier

Note: One Stop Money Shop must also submit an Electronic Funds Transfer Report to FINTRAC as it initiated an electronic funds transfer for an amount that is over $10,000 CAD.

For more information:

Infographic summarizing scenario B.4a

Infographic summarizing scenario B.4a: Outgoing international funds transfer – Person conductor
Infographic summarizing scenario B.4a: Outgoing international funds transfer – Person conductor

Scenario B.4b: Outgoing international funds transfer – Entity conductor

Scenario

Sophie Blue, CEO of Kitchen Supply Company, walked into One Stop Money Shop with €10,000 and did the following:

According to One Stop Money Shop’s policies and procedures, an entity will be reported as the conductor when:

Expected field information in the report

One Stop Money Shop submits a Large Cash Transaction Report with the following information.

General information – Scenario B.4b
General information about One Stop Money Shop
Fields Information provided by One Stop Money Shop
Reporting entity number The reporting entity number assigned to One Stop Money Shop when it enrolled with FINTRAC Web Reporting System (FWR)
Reporting entity report reference number

The unique number for this report that was assigned by:

  • One Stop Money Shop, or
  • its service provider
Activity sector Money services business
Contact information for this report Information about the person at One Stop Money Shop that FINTRAC can liaise with in the event that a follow up is required
Aggregation type Not applicable
24-hour period for aggregation One Stop Money Shop’s 24-hour window for aggregation as indicated by the start and end times
Transaction information – Scenario B.4b
“Transaction information” provided by One Stop Money Shop
Fields Information provided for transaction 1 of 1
Date and time of transaction The date and time the cash was received by One Stop Money Shop
Method of transaction In person
Threshold indicator Above threshold
Reporting entity transaction reference number

The unique number for this transaction that was assigned by:

  • One Stop Money Shop, or
  • its service provider
Purpose of transaction Payment for kitchen supplies (pots and pans)
Reporting entity location number Information about where the transaction took place
Starting action – Scenario B.4b
“Starting action” information provided by One Stop Money Shop
Fields Information provided for starting action 1 of transaction 1
Amount 10,000
Currency EUR
Was information about the source (person /entity) of cash obtained? No
Does this transaction involve a deposit to a business account other than a night deposit or quick drop? No
Conductor information

Information that One Stop Money Shop has on the Kitchen Supply Company, including:

  • name
  • client number
  • address
  • telephone number
  • email address
  • nature of principal business
  • registration/incorporation details
  • identification details, and
  • person(s) authorized to bind the entity or act with respect to the account
Was this transaction conducted on behalf of another person or entity? No
Completing action – Scenario B.4b
“Completing action” information provided by One Stop Money Shop
Fields Information provide for completing action 1 of transaction 1
Details of disposition Outgoing international funds transfer
Amount 10,000
Currency EUR
Reference number and other related numbers Reference number assigned by One Stop Money Shop or its service provider, if applicable, and any other related numbers
Account number and account information For ABC Enterprises’ bank account in Italy
Account holder ABC Enterprises
Was there any other person or entity involved in the completing action? No
Beneficiary information

Name of ABC Enterprises

Also, if obtained, information about ABC Enterprises including:

  • client number
  • address
  • telephone number
  • email address
  • nature of principal business
  • registration/incorporation details
  • identification details, and
  • person(s) authorized to bind the entity or act with respect to the account
Relationship of the entity named above (beneficiary) to the person conducting the transaction Vendor / Supplier

Note: One Stop Money Shop must also submit an Electronic Funds Transfer Report to FINTRAC as it initiated an electronic funds transfer for an amount that is over $10,000 CAD.

For more information:

Infographic summarizing scenario B.4b

Infographic summarizing scenario B.4b: Outgoing international funds transfer – Entity conductor
Infographic summarizing scenario B.4b: Outgoing international funds transfer – Entity conductor

For assistance

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

Date Modified: