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Report suspected sanctions evasion : FINTRAC's compliance guidance

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

This guidance explains the requirement to report to FINTRAC all completed and attempted transactions where there are reasonable grounds to suspect the transaction is related to the commission or the attempted commission of a sanctions evasion offence.

How to report sanctions evasion-related transactions

Sanctions evasion offence means an offence arising from the contravention of a restriction or prohibition established by an order or a regulation made under the United Nations Act, the Special Economic Measures Act or the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law).

Where there are reasonable grounds to suspect sanctions evasion by someone acting on behalf of a sanctioned person then you must report these transactions on FINTRAC’s Suspicious Transaction Reports.

For guidance, please see Reporting suspicious transactions to FINTRAC.

If a transaction is suspected of being related to both a money laundering or terrorist financing offence, and a sanctions evasion offence, you should submit one report containing details and all required information for each of the suspected offences.

Characteristics of financial activity associated with suspected sanctions evasion

For information on characteristics of financial transactions related to suspected sanctions evasion, consult FINTRAC’s Special Bulletin on financial activity associated with suspected sanctions evasion.

The Bulletin will assist you in:

You can also consult FINTRAC’s joint financial intelligence advisory on the illegal procurement of dual-use goods by Russian end-users. This advisory will support you in recognizing financial transactions and other related activity that is suspected of being associated with the laundering of the proceeds linked to the purchase and/or sale of dual-use goods for illegal export from Canada.

Apply ministerial directives

Ministerial Directives are currently in force with respect to:

For information on Ministerial Directives, including the associated obligations, consult Ministerial directives and transaction restrictions.

How to submit terrorist property reports and make a disclosure

In addition to your existing reporting obligations, every person in Canada and every Canadian outside Canada must also disclose to the RCMP or CSIS the existence of property that is owned or controlled by a designated person, as well as any proposed transactions related to that property.

For guidance on submitting terrorist property reports and how to disclose to the RCMP or CSIS, see Reporting terrorist property to FINTRAC.

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