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Reporting large virtual currency transactions to FINTRAC : FINTRAC's compliance guidance

Updated on October 23, 2023

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

This guidance came into effect on June 1, 2021.

This guidance explains the requirement to report large virtual currency transactions to FINTRAC.

Note:

In this guidance

Related links

1. Who must comply

All reporting entities must comply with the large virtual currency 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 virtual currency 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 Virtual Currency 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.

For more information, please refer to:

Legal references

2. What is a large virtual currency transaction

A large virtual currency transaction occurs when you receive virtual currency in an amount equivalent to $10,000 or more in a single transaction.

Virtual currency is a digital representation of value, or the private key of a cryptographic system that enables access to a digital representation of value, that can be used for payment or investment purposes.

Virtual currency is not a fiat currency but it can be readily exchanged for:

For greater clarity, this definition does not include certain digital currencies, such as:

For example, such digital currencies include:

Legal references

3. When to submit a Large Virtual Currency Transaction Report

You must submit a Large Virtual Currency Transaction Report to FINTRAC when you receive virtual currency in an amount equivalent to $10,000 or more in a single transaction.

To determine if a transaction is reportable, you must:

Note:

Legal references

24-hour rule

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

For more information, please refer to:

Legal reference

Exchange rates

You must use the exchange rate you establish in the normal course of your business to determine whether you have reached the reporting threshold amount, as the Bank of Canada does not publish exchange rates for virtual currency.

Your process for establishing an exchange rate must be outlined in your compliance policies and procedures.

Legal references

4. How to submit a report to FINTRAC

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

Reporting entities that need to submit high volumes of reports are strongly encouraged to use FINTRAC API report submission since the Large Virtual Currency Transaction Report Upload will be decommissioned in April 2024.

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 virtual currency transactions

In this section

Note

Form structure

The form for reporting large virtual currency transactions has 4 sections:

Structure of the Large Virtual Currency 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:

  • you (the reporting entity), and
  • your 24-hour period for reviewing aggregate transactions
Transaction information Information about each transaction being reported
Starting action Information about how the transaction started
Completing action Information about how the transaction was completed

Note: To access most fields and their category (mandatory, mandatory for processing or reasonable efforts), refer to:

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

Flashy Coin receives 16,000 United States Dollar Tether (USDT) (which is equivalent to $21,580 CAD) from wallet address a1a2a3 that was requested to be added to wallet address b1b2b3, which belongs to Sam.

Flashy Coin is unable to identify a conductor after taking reasonable measures and submits a report indicating that Sam was the beneficiary of a single transaction with:

  • 1 starting action (the receipt of 16,000 USDT by Flashy Coin)
  • 1 completing action (disposition of 16,000 USDT added to a Flashy Coin wallet) where Sam is the beneficiary
Example 2

Flashy Coin receives 4 Ethereum (ETH) (which is equivalent tot $10,560 CAD) from wallet address c1c2c3, that was requested to be added to wallet address d1d2d3, which belongs to Alex.

Alex immediately transfers 2 ETH ($5,280) into Flashy Coin’s staking program.

After taking reasonable measures Flashy Coin is able to determine that Alex sent the initial virtual currency from their own unhosted wallet (c1c2c3) and is therefore the conductor.

Flashy Coin submits a report indicating that Alex was the conductor and beneficiary of a single transaction with:

  • 1 starting action (the receipt of 4 ETH by Flashy Coin conducted by Alex)
  • 2 completing actions where Alex is the beneficiary of both completing actions:
    • one disposition of 4 ETH added to a Flashy Coin wallet, and
    • a second disposition of 2 ETH involving an outgoing virtual currency transfer into Flashy Coin’s staking program

6. Other requirements associated with large virtual currency 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 Virtual Currency 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 virtual currency 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 Virtual Currency Transaction Report and a Suspicious Transaction Report for the same transaction.

For more information:

Record keeping

When you submit a Large Virtual Currency 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 virtual currency transactions.

For specific 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 virtual currency transaction.

For more information:

Ministerial directives

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

For more information:

Voluntary self-declaration of non-compliance

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

For more information:

7. Exceptions to reporting large virtual currency transactions

Note: The following exceptions refer to the initial receipt of virtual currency, but any further transaction or activity may have reporting obligations, in addition to other obligations.

You are not required to submit a Large Virtual Currency Transaction Report if you receive:

For example, you do not need to report the receipt of virtual currency when it is received or purchased as holdings for your business.

Legal references

Annex A: Field instructions to complete a Large Virtual Currency Transaction Report

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

In this annex

Note

Standardized field instructions

This section contains instructions for:

In this section

Field categories

In this guidance, 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 Virtual Currency Transaction Report can include multiple transactions conducted within 24 consecutive hours that total an amount equivalent to $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 Virtual Currency Transaction Report contains multiple transactions conducted within 24 consecutive hours and 1 of these transactions is equivalent to $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 Virtual Currency 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 Virtual Currency 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 ‘24-hour aggregation type’ field.
  • Only 1 ministerial directive (IR2020) is available for a Large Virtual Currency Transaction Report.

Transaction information

Information about the transaction
Instructions for the fields under “Information about the transaction”
Fields Instructions
* Date and time virtual currency was received

Enter the date and time that the virtual currency was received for the transaction.

It cannot be a future date and must not be earlier than June 1, 2021.

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:

* Method of transaction

Select the method that describes how you received the virtual currency.

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

† If “Other,” please specify Provide a brief description on how you received the virtual currency.
‡ Threshold indicator

Indicate whether the value of the virtual currency 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
* Transaction identifier

This is a unique identifier.

It is commonly represented by a hash consisting of mixed numerical and alphabetical characters.

‡ 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. For example:

  • Etherium was transferred into Flashy Coin’s staking program to be held for passive income.
  • Bitcoin was exchanged into Canadian funds and sent to Sam’s connected bank account to pay for their monthly rent.
  • Litecoin was received at Flashy coin to be used for investment on the Flashy Coin trading platform.

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

Information about where the virtual currency was received

Provide information about the physical location where the virtual currency was received.

For example if the virtual currency was received at a virtual currency ATM, provide the reporting entity location number of that ATM.

If no physical location is applicable (for instance the transaction was conducted online), provide the location number of your main location, such as a head office or headquarters.

Instructions for the field under “Information about where the virtual currency was received”
Field Instructions
* Reporting entity location number

This represents information about where the transaction took place.

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, including:

Instructions for the fields under “Starting action”
Fields Instructions
* Amount Enter the total amount of virtual currency involved in the starting action.
* Virtual currency type

Select the virtual currency type used in the transaction.

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

† If “Other”, please specify Instructions not specified
* Exchange rate used for the transaction Provide the rate of exchange to Canadian dollars that you used for the transaction.
* Sending virtual currency address

Provide the sending virtual currency address(es) for every starting action for the transaction.

The sending virtual currency address is made up of a number of alpha-numeric characters and its length is determined by the type of virtual currency used.

The sending virtual currency address is associated with whoever is sending the virtual currency (typically the conductor).

How was the virtual currency obtained?

This field requires information on the source of the virtual currency.

This is how the conductor initially obtained the virtual currency used for the transaction, not where the virtual currency may have been transferred from.

For example, the virtual currency was obtained through:

  • rewards withdrawal from a mining pool
  • the sale of a non-fungible token
  • the sale of Bitcoin on a peer-to-peer (P2P) platform

This information must be reported if obtained.

‡ Was information about the source of virtual currency obtained?

This field is a “Yes/No” question.

Select “Yes” if you have:

  • the name of any person or entity that is the source of the virtual currency involved in the transaction
  • their account number or policy number, or
  • an identifying number if there is no account number or policy number

Otherwise, select “No” to indicate that you do not have the information.

Source of virtual currency

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

If there are multiple sources, you must provide information for each source. This includes their name and the following:

You must report this information if you obtained it in the ordinary course of business. This means you must report the information if you obtained it for any reason related to the services you provide to clients.

Source of virtual currency – person
Instructions for the fields under “Source of virtual currency – 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 virtual currency.

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 virtual currency – entity
Instructions for the fields under “Source of virtual currency – entity”
Fields Instructions
† Name of entity Refer to Name fields under “Standardized field instructions”.
Account number

Provide the account number for the source of virtual currency.

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 virtual currency fields

Although the following 3 fields are all about the source of virtual currency, they are different:

The following examples demonstrate their differences.

Example 1

On April 23, 2023, Vicky Violet’s virtual currency wallet (hosted at Flashy Coin) receives 4 Etherium ($10,128) from wallet address a1a2a3.

Vicky tells Flashy Coin that she obtained the virtual currency when she sold her non-fungible token.

Vicky was only able to provide the name of the non-fungible token platform and the wallet address of the buyer because she did not have information on the buyer’s name.

As such, the source of virtual currency fields would be completed as follows:

How the source of virtual currency fields would be completed for this example
Source of virtual currency fields Information provided in the field
How was the virtual currency obtained? Sale of a non-fungible token
Was information about the source of virtual currency obtained? Yes
Source of virtual currency Wallet address provided under identifying number as a1a2a3
Example 2

On April 23, 2023, Vicky Violet’s virtual currency wallet (hosted at Flashy Coin) receives 90 Litecoin ($10,710) from wallet address c1c2c3.

Vicky tells Flashy Coin that she obtained this virtual currency when she withdrew her mining pool rewards (the mining pool is operated by Epic Hashing).

She was only able to provide the name and wallet address of the mining pool.

As such, the source of virtual currency fields would be completed as follows:

How the source of virtual currency fields would be completed for this example
Source of virtual currency fields Information provided in the field
How was the virtual currency obtained? Rewards withdrawal from mining pool
Was information about the source of virtual currency obtained? Yes
Source of virtual currency Entity name Epic Hashing, wallet address provided under identifying number as c1c2c3

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

Conductor indicator
Instructions for the field under “Conductor indicator”
Field Instructions
‡ Have you obtained any conductor information related to this transaction?

If the conductor is a client or if you have information about a conductor that is not your client, you must answer “Yes”.

You must select “No” only if, despite taking reasonable measures to do so, you were not able to obtain any information on the conductor that was not your client.

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
† Is the conductor a client of the reporting entity? Instructions not specified
† 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)
Username A username is how a person refers to themselves online.
† 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)
Information about conducting the transaction online – person

Note: Information for this section is required only when the transaction occurs online.

Instructions for the fields under “Information about conducting the transaction online – person”
Fields Instructions
Type of device used Select which device was used to conduct the transaction online.
† If “Other”, please specify Provide the type of device used.
Device identifier number

The device identifier number is a number assigned to the device, such as:

  • a Media Access Control (MAC) address, or
  • International Mobile Equipment Identity (IMEI) number
Internet protocol (IP) address Instructions not specified
Date/time of online session in which request was made This is the date and time the conductor accessed the online environment where the transaction was requested.
On behalf of indicator – person
Instructions for the field under “On behalf of indicator – person”
Field Instructions
† Was this transaction conducted on behalf of another person or entity?

This 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
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
† Is the conductor a client of the reporting entity? Instructions not specified
† Name of entity Refer to Name fields under “Standardized field instructions”.
Username A username is how an entity refers to themselves online.
† 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)
† Nature of entity’s principal business Refer to Occupation/business fields under “Standardized field instructions”.
† Is the entity registered or incorporated? Instructions not specified
† Registration or incorporation number

Provide the registration or incorporation number of the entity conducting the transaction.

You must provide the jurisdiction of issue if you provide a registration or incorporation number.

† Jurisdiction of issue (country) Instructions not specified
† Jurisdiction of issue (province or state) Instructions not specified
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)
Information about conducting the transaction online – entity

Note: Information for this section is required only when the transaction occurs online.

Instructions for the fields under “Information about conducting the transaction online – entity”
Fields Instructions
Type of device used Select which device was used to conduct the transaction online.
† If “Other”, please specify Provide the type of device used.
Device identifier number

The device identifier number is a number assigned to the device, such as:

  • a Media Access Control (MAC) address, or
  • International Mobile Equipment Identity (IMEI) number
Internet protocol (IP) address Instructions not specified
Date/time of online session in which request was made This is the date and time the conductor accessed the online environment where the transaction was requested.
On behalf of indicator – entity
Instructions for the field under “On behalf of indicator – entity”
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”.
Is the entity registered or incorporated? Instructions not specified
Registration or incorporation number

Provide the registration or incorporation number of the entity on whose behalf the transaction was conducted.

You must provide the jurisdiction of issue if you provide a registration or incorporation number.

Jurisdiction of issue (country) Instructions not specified
Jurisdiction of issue (province or state) (code) Instructions not specified
Jurisdiction of issue (province or state) (name) Instructions not specified
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, including:

The first completing action of each transaction in the report should indicate that the disposition is added to a virtual currency wallet.

Instructions for the “Completing action” fields
Fields Instructions
* Details of disposition

This describes what happened to the virtual currency involved in the transaction.

For example, if the disposition was an amount added to a virtual currency wallet at a money services business you would select “added to a virtual currency wallet” from the table.

If the values provided do not adequately describe the disposition of the transaction, indicate “Other” and provide details in that field.

† If “Other”, please specify If the disposition is “Other”, provide details that describe the disposition of the transaction.
† Amount Instructions not specified
† Virtual currency type Instructions not specified
† If “Other”, please specify Instructions not specified
† Receiving virtual currency address

Provide the virtual currency address for the person or entity receiving the virtual currency.

The first completing action of each transaction must have at least one receiving virtual currency address listed in the report.

The receiving virtual currency address could:

  • be associated with the beneficiary of the virtual currency, or
  • include the address in which you (the reporting entity) received the virtual currency, if that is how your business operates
† Currency Instructions not specified
† Value in Canadian dollars

Provide the Canadian dollar value of the disposition if it is not virtual currency.

For example, provide the value of the virtual currency used to purchase jewellery.

† Reference number

If the transaction involved a reference number that is used as an equivalent to an account number, provide it, as well as any other number connected to the reference number.

Do not provide the account number information in this field—instead, provide that information in the account number field.

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

Provide the account number if the transaction involves an account at an account-based reporting entity (for example, a financial entity).

† Account type Instructions not specified
† If “Other”, please specify Instructions not specified
† Account currency Instructions not specified
† Account virtual currency type Instructions not specified
† If “Other”, please specify Instructions not specified
Date account opened Instructions not specified
‡ Was there any other person or entity involved in the completing action? 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)
† Username A username is how a person refers to themselves online.
Account holder – entity
Instructions for the field under “Account holder – entity”
Field Instructions
† Name of entity Refer to Name fields under “Standardized field instructions”.
† Username A username is how a person refers to themselves online.
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 person who receives the virtual currency.

The beneficiary can be the same person or entity that conducts the transaction or someone else.

The beneficiary cannot be the reporting entity.

Instructions for the field under “Beneficiary”
Field Instructions
‡ Was there a beneficiary for this completing action? There must always be a minimum of 1 beneficiary per transaction.
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)
Username A username is how a person refers to themselves online.
Client number Instructions not specified
Apartment/Room/Suite/Unit number Refer to Unstructured address field 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)
Entity beneficiary
Instructions for the fields under “Entity beneficiary”
Fields Instructions
† Name of entity Refer to Identification fields under “Standardized field instructions”.
Username A username is how an entity refers to themselves online.
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”.
† Is the entity registered or incorporated? Instructions not specified
† Registration or incorporation number

Provide the registration or incorporation number of the entity beneficiary.

You must provide the jurisdiction of issue if you provide a registration or incorporation number.

† Jurisdiction of issue (country) Instructions not specified
† Jurisdiction of issue (province or state) Instructions not specified
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)

Annex B: Scenarios

The examples and scenarios used in this guidance are intended to help explain your reporting requirements. The following scenarios demonstrate form completion and the expected field information in a Large Virtual Currency Transaction Report based on the client’s instructions and transaction(s) in each scenario.

Note about these scenarios

Legend for symbols used in fields
Field categories Instructions
Mandatory These fields are indicated with an asterisk symbol (*) and must be completed.
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.

In this annex

Scenario B.1: Virtual currency exchange to fiat currency

Scenario

On June 29, 2021, Sam Pepper logged into the Flashy Coin website and sold 1 Bitcoin (BTC) for Canadian dollars ($31,000) and then deposited it into his connected bank account (held at Golden Bank Financial Services).

Large Virtual Currency Transaction Report requirement

Infographic summarizing scenario B.1

Infographic summarizing scenario B.1: Virtual currency exchange to fiat currency
Infographic summarizing scenario B.1: Virtual currency exchange to fiat currency

Scenario B.2: Receipt of virtual currency

Scenario

Large Virtual Currency Transaction Report requirement

Infographic summarizing scenario B.2

Infographic summarizing scenario B.2: Receipt of virtual currency
Infographic summarizing scenario B.2: Receipt of virtual currency

Expected field information in the report

General information – Scenario B.2
General information about Flashy Coin
Fields Information provided by Flashy Coin
* Reporting entity number

###### (Flashy Coin)

The 7-digit identifier assigned to Flashy Coin when it enrolled with FINTRAC Web Reporting System (FWR).

‡ Reporting entity report reference number

LVCTR-FC-001

The unique number for this report assigned by Flashy Coin or its service provider.

* Activity sector Money services business
* Contact number

###### (Jamie Salt)

The unique number for the person that FINTRAC can liaise with.

Report information – Scenario B.2
“Report information” provided by Flashy Coin
Fields Information provided by Flashy Coin
‡ Aggregation type Not applicable
‡ 24-hour period start date/time

2021-06-29T00:00:00-04:00

Flashy Coin’s start date and time for the 24-hour period.

‡ 24-hour period end date/time

2021-06-29T23:59:59-04:00

Flashy Coin’s end date and time for the 24-hour period.

Transaction information – Scenario B.2
“Transaction information” provided by Flashy Coin
Fields Information provided for transaction 1 of 1
* Date/time virtual currency was received

2021-06-29T11:23:55-04:00

The date and time Flashy Coin received the virtual currency.

* Method of transaction

Online

The method that describes how Flashy Coin received the virtual currency.

‡ Threshold indicator Above threshold
* Transaction identifier

a1881rr24a2d9856bcf5f19512261ll9033eafaefb9eb0

The unique identifier, or a hash, with mixed numerical and alphabetical characters.

‡ Reporting entity transaction reference number

20210629-112355-0015

The unique reference number assigned to the transaction by Flashy Coin. The number is unique to the report level.

* Reporting entity location number

01 (Hawk Junction Location)

This is where the transaction was received.

Starting action 1 of transaction 1 – Scenario B.2
“Starting action” information provided by Flashy Coin
Fields Information provided for starting action 1 of transaction 1
* Amount 130
* Virtual currency type

Litecoin

The virtual currency type used in the transaction.

* Exchange rate

93.90

The rate of exchange to Canadian dollars that Flashy Coin used for the transaction.

* Sending virtual currency address

c1c2c3c4c5c6c7c8c9

The alpha-numeric address associated with the sender (typically the conductor) of the virtual currency.

‡ Was information about the source of virtual currency obtained? No
‡ Have you obtained any conductor information related to the transaction? No
Completing action 1 of transaction 1 – Scenario B.2
“Completing action” information provided by Flashy Coin
Fields Information provided for completing action 1 of transaction 1
* Details of disposition

Added to virtual currency wallet

This describes what happened to the virtual currency in the transaction.

† Amount 130
† Virtual currency type Litecoin
† Receiving virtual currency address

b1b2b3b4b5b6b7b8b9

The address of the person or entity receiving the virtual currency.

‡ Was there any other person or entity involved in the completing action? No
Beneficiary indicator – Scenario B.2
“Beneficiary indicator” information provided by Flashy Coin
Fields Information provided by Flashy Coin
‡ Was there a beneficiary for this completing action? Yes
Information about the beneficiary – Scenario B.2
“Information about the beneficiary” provided by Flashy Coin
Fields Information provided by Flashy Coin
† Surname Pepper
† Given name Sam
House/Building number 123
† Street address Giggles Way
† City Orton
† Country CA
† Province or state (code) ON
Postal or zip code K2K 3P3
Telephone number 613-555-2368
Email address Sam.pepper@myemail.ca
Date of birth 1977-03-07
Identification 1 of 1 – Scenario B.2
‘Identification 1 of 1” information provided by Flashy Coin
Fields Information provided by Flashy Coin
† Identifier type Passport
† Number associated with identifier type H1234556798
† Jurisdiction of issue (country) CA
† Jurisdiction of issue (province or state) (code) ON

Scenario B.3: Receipt of virtual currency (24-hour rule)

Scenario

Sam Pepper has 3 wallets hosted by Flashy Coin:

On June 29, 2021, Sam Pepper received virtual currency (Litecoin) to his virtual currency addresses/wallets that are hosted by Flashy Coin. The details of the transactions are described in the following table:

Details of virtual currency transactions received by Sam Pepper on June 29, 2021
Transaction Date and time of transaction Beneficiary Amount of virtual currency received Virtual address/wallet Host of virtual currency address
Transaction 1 June 29, 2021 at 10:15 am Sam Pepper 60 Litecoin ($5,590.04 CAD) d1d2d3d4d5d6d7d8d9 Flashy Coin (Hawk Junction location)
Transaction 2 June 29, 2021 at 2:08 pm Sam Pepper 60 Litecoin ($5,769.89 CAD) e1e2e3e4e5e6e7e8e9 Flashy Coin
Transaction 3 June 29, 2021 at 7:39 pm Sam Pepper 60 Litecoin ($5,643.60 CAD) f1f2f3f4f5f6f7f8f9 Flashy Coin

Flashy Coin follows its policies and procedures for receiving virtual currency transfers and asks Sam where the virtual currency came from.

Sam is unable to provide a source of the virtual currency or identify the sender, which means Flashy Coin cannot report conductor information.

Flashy Coin will need to follow their risk-based policies and procedures for determining whether any follow-up measures must be taken. However, Flashy Coin will need to submit the Large Virtual Currency Transaction Report.

Large Virtual Currency Transaction Report requirement

Flashy Coin must submit a report because Sam Pepper is the beneficiary of the 3 transactions and they aggregate above threshold.

Infographic summarizing scenario B.3

Infographic summarizing scenario B.4a: Outgoing international funds transfer – Person conductor
Infographic summarizing scenario 3: Receipt of virtual currency (24-hour rule)

Expected field information in the report

General information – Scenario B.3
General information about Flashy Coin
Fields Information provided by Flashy Coin
* Reporting entity number

###### (Flashy Coin)

The 7-digit identifier assigned to Flashy Coin when it enrolled with FINTRAC Web Reporting System (FWR).

‡ Reporting entity report reference number

LVCTR-FC-002

The unique number for this report assigned by Flashy Coin or its service provider.

* Activity sector Money services business
* Contact number

###### (Jamie Salt)

The unique number for the person that FINTRAC can liaise with.

Report information – Scenario B.3
“Report information” provided by Flashy Coin
Fields Information provided by Flashy Coin
‡ Aggregation type

Beneficiary

The type of aggregation when multiple transactions occur in Flashy Coin’s 24-hour reporting period.

‡ 24-hour period start date/time

2021-06-29T00:00:00-04:00

Flashy Coin’s start date and time for the 24-hour period.

‡ 24-hour period end date/time

2021-06-29T23:59:59-04:00

Flashy Coin’s end date and time for the 24-hour period.

Transaction information – Scenario B.3
“Transaction information” provided by Flashy Coin
Fields Information provided for transaction 1 of 3 Information provided for transaction 2 of 3 Information provided for transaction 3 of 3
* Date/time virtual currency was received

2021-06-29T10:15:55-04:00

The date and time Flashy Coin received the virtual currency.

2021-06-29T14:08:55-04:00 2021-06-29T19:39:01-04:00
* Method of transaction

Other

The method that describes how Flashy Coin received the virtual currency.

Other Other
‡ Threshold indicator Below threshold Below threshold Below threshold
* Transaction identifier

110eea569810268e90e901e9de0c83c1cedd02d1d854d

The unique identifier, or a hash, with mixed numerical and alphabetical characters.

277a2ac146ca70722d2ac926c843635dda85044bdb9a6 9e7fcb145e7b1be291cb7b717dc5b43cad9eedf3546ee1
‡ Reporting entity transaction reference number

20210629-101555-0087

The unique reference number assigned to the transaction by Flashy Coin. The number is unique to the report level.

20210629-140855-0244 20210629-193901-2776
* Reporting entity location number

01 (Hawk Junction Location)

This is where the transaction was received.

01 (Hawk Junction Location)

This is where the transaction was received.

01 (Hawk Junction Location)

This is where the transaction was received.

Starting action – Scenario B.3
“Starting action” information provided by Flashy Coin
Fields Information provided for starting action of transaction 1 of 3 Information provided for starting action of transaction 2 of 3 Information provided for starting action of transaction 3 of 3
* Amount 60 60 60
* Virtual currency type

Litecoin

The virtual currency type used in the transaction.

Litecoin Litecoin
* Exchange rate

93.90

The rate of exchange to Canadian dollars that Flashy Coined used for the transaction.

96.16 94.06
* Sending virtual currency address

a1a2a3a4a5a6a7a8a9

The alpha-numeric address associated with the sender (typically the conductor) of the virtual currency.

b1b2b3b4b5b6b7b8b9 c1c2c3c4c5c6c7c8c9
‡ Was information about the source of virtual currency obtained? No No No
‡ Have you obtained any conductor information related to the transaction? No No No
Completing action – Scenario B.3
“Completing action” information provided by Flashy Coin
Fields Information provided for completing action of transaction 1 of 3 Information provided for completing action of transaction 2 of 3 Information provided for completing action of transaction 3 of 3
* Details of disposition

Added to virtual currency wallet

This describes what happened to the virtual currency in the transaction.

Added to virtual currency wallet Added to virtual currency wallet
† Amount 60 60 60
† Virtual currency type Litecoin Litecoin Litecoin
† Receiving virtual currency address

d1d2d3d4d5d6d7d8d9

The address of the person or entity receiving the virtual currency.

e1e2e3e4e5e6e7e8e9 f1f2f3f4f5f6f7f8f9
‡ Was there any other person or entity involved in the completing action? No No No
Beneficiary indicator – Scenario B.3
“Beneficiary indicator” information provided by Flashy Coin
Field Information provided for transaction 1 of 3 Information provided for transaction 2 of 3 Information provided for transaction 3 of 3
‡ Was there a beneficiary for this completing action? Yes Yes Yes
Information about the beneficiary – Scenario B.3
“Information about the beneficiary” provided by Flashy Coin
Fields Information provided for transaction 1 of 3 Information provided for transaction 2 of 3 Information provided for transaction 3 of 3
† Surname Pepper Pepper Pepper
† Given name Sam Sam Sam
Alias Professor Pepper Professor Pepper Professor Pepper
Username Sam.pepper@myemail.ca Sam.pepper@myemail.ca Sam.pepper@myemail.ca
Client number 1001 1001 1001
House/Building number 123 123 123
† Street address Giggles Way Giggles Way Giggles Way
† City Orton Orton Orton
† Country CA CA CA
† Province or state (code) ON ON ON
Postal or zip code K2K 3P3 K2K 3P3 K2K 3P3
Telephone number 613-555-2368 613-555-2368 613-555-2368
Email address Sam.pepper@myemail.ca Sam.pepper@myemail.ca Sam.pepper@myemail.ca
Date of birth 1977-03-07 1977-03-07 1977-03-07
Country of residence CA CA CA
Occupation Musician Musician Musician
Identification – Scenario B.3
“Identification” information provided by Flashy Coin
Fields Information provided for transaction 1 of 3 Information provided for transaction 2 of 3 Information provided for transaction 3 of 3
† Identifier type Passport Passport Passport
† Number associated with identifier type H1234556798 H1234556798 H1234556798
† Jurisdiction of issue (country) CA CA CA
† Jurisdiction of issue (province or state) (code) ON ON ON

Details and history

Published: September 2021

List of changes and updates
Date [YYYY-MM-DD] Summary of changes
2023-10-23
  • Inclusion of annex with reporting scenarios
  • Reorganization and reformatting of content to ensure better readability and flow
  • Using plain language, where possible, in order to enhance readability
  • Minor adjustments to comply with Canada.ca Content Style Guide

For assistance

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

Date Modified: