Reporting suspicious transactions to FINTRAC : FINTRAC's compliance guidance

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

This guidance explains the requirement to report suspicious transactions to FINTRAC.

This guidance replaces the following guidance, which have been archived online:

Note:

Throughout this guidance, references to dollar amounts (such as $10,000) are in Canadian dollars unless otherwise specified.
All references to transactions should be read to include both attempted transactions and completed transactions.
All references to the commission of a money laundering or terrorist activity financing offence also include the attempted commission of a money laundering or terrorist activity financing offence.
The examples and scenarios in this guidance are meant to help explain reporting requirements.
The details used in these examples and scenarios such as names of persons, names of entities, addresses, phone numbers and email addresses are fictitious.

In this guidance

1. Who must comply
2. What is a Suspicious Transaction Report
3. What are reasonable grounds to suspect
4. When to submit a Suspicious Transaction Report
5. How to submit a report to FINTRAC
6.The form for reporting suspicious transactions
7. Other requirements associated with suspicious transactions
8. Reporting subsequent suspicious transactions
9. FINTRAC's expectations for completing a Suspicious Transaction Report
10. Common Suspicious Transaction Report deficiencies to avoid
Annex A: Field instructions to complete a Suspicious Transaction Report
Annex B: Scenarios
For assistance

1. Who must comply

All reporting entities and their employees must report suspicious transactions.

If you are a person who is an employee of a reporting entity and your employer is actively reporting suspicious transactions, we do not require duplicate reporting. An employee is only expected to report suspicious transactions to FINTRAC in the rare instances where they believe that their employer has not submitted a Suspicious Transaction Report as required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and associated Regulations. To submit a Suspicious Transaction Report in this scenario, the employee may use the paper report form as explained in section 4 below.

A service provider can submit and correct a Suspicious Transaction Report on your behalf. However, as the reporting entity, you are ultimately responsible for meeting the requirements under the Act and associated Regulations, even if a service provider is reporting on your behalf. This legal responsibility cannot be delegated.

No person or entity will be prosecuted for sending a Suspicious Transaction Report in good faith or for providing FINTRAC with information about suspicions of money laundering or terrorist financing.

Legal references

Proceeds of Crime (Money Laundering) and Terrorist Financing Act, SC.2000. c17
- section 10
Proceed of Crime (Money Laundering) and Terrorist Financing Regulations, SOR/2002-184
- section 133(1)
- section 133(2)

2. What is a Suspicious Transaction Report

A suspicious transaction report is a type of report that you must submit to FINTRAC when a financial transaction occurs, or is attempted, in the course of your activities and there are reasonable grounds to suspect that the transaction is related to the commission or the attempted commission of a money laundering or terrorist activity financing offence.

Note: You are not allowed to inform anyone, including the client, of the contents of a Suspicious Transaction Report, or that you have made or will make such a report, if the intent is to prejudice a criminal investigation. This applies whether such an investigation has begun or not. It is important to not tip off your client about the fact that you are filing a Suspicious Transaction Report—therefore, you should not be requesting information that you would not normally request during a transaction if you believe this would tip off the client.

It is recommended that this guidance be read in conjunction with the following indicators, characteristics and guidance:

The Suspicious Transaction Report is one of the most valuable and unique report types submitted to FINTRAC. In addition to the prescribed information, Suspicious Transaction Reports allow you to expand the descriptive details surrounding a transaction that is derived from your assessment of what you are seeing through your business interactions and activities.

FINTRAC uses the following types of information in its analysis and production of financial disclosures:

aliases
nicknames
other names and initials
beneficial ownership information
IP addresses
account numbers
email addresses
virtual currency transaction addresses and their details
email money transfers (EMTs)
mobile money transfers
details of purchases
locations
relationships
background information

Because of the importance of FINTRAC's financial intelligence to the overall safety and security of Canadians and Canada's financial system, FINTRAC reviews and assesses every Suspicious Transaction Report it receives. When warranted, such as in the case of Suspicious Transaction Reports related to threats to the security of Canada, FINTRAC expedites its analysis in order to disclose financial intelligence to law enforcement and other intelligence partners within 24 hours.

Legal references

Proceed of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations, SOR/2001-317
- section 9(1)
Proceeds of Crime (Money Launder) and Terrorist Financing Act, SC.2000. c17
- section 8

3. What are reasonable grounds to suspect

Reasonable grounds to suspect is the required threshold to submit a Suspicious Transaction Report to FINTRAC and is a step above simple suspicion, meaning that there is a possibility that a money laundering or terrorist activity financing offence has occurred.

You do not have to verify the facts, context or money laundering or terrorist activity financing indicators that led to your suspicion, nor do you have to prove that a money laundering or terrorist activity financing offence has occurred in order to reach this threshold. Your suspicion must be reasonable and therefore, not biased or prejudiced.

Reaching this threshold means that you considered:

the facts
the context
the money laundering or terrorist activity financing indicators
the sanctions evasion characteristics related to a financial transaction

After having reviewed this information, you concluded that there are reasonable grounds to suspect that this particular financial transaction is related to the commission of a money laundering or terrorist activity financing offence. It also means that you are able to demonstrate and articulate your suspicion of money laundering or terrorist activity financing in such a way that another individual with similar knowledge, experience, or training would likely reach the same conclusion based on a review of the same information.

Many factors will support your assessment and conclusion that a money laundering or terrorist activity financing offence has possibly occurred. These factors, along with an explanation of your assessment, should be included in the narrative section of the Suspicious Transaction Report, specifically, the Details of suspicion section.

The reasonable grounds to suspect threshold may be better understood when you have an understanding of other thresholds:

simple suspicion
reasonable grounds to believe

Simple suspicion is a lower threshold than reasonable grounds to suspect and is synonymous with a "gut feeling" or "hunch". In other words, simple suspicion means that you have a feeling that something is unusual or suspicious, but do not have any facts, context or money laundering or terrorist activity financing indicators to support that feeling or to reasonably conclude that a money laundering or terrorist activity financing offence has occurred. Simple suspicion could prompt you to assess related transactions to see if there is any additional information that would support or confirm your suspicion.

Reasonable grounds to believe is a higher threshold than reasonable grounds to suspect and is beyond what is required to submit a Suspicious Transaction Report. Reasonable grounds to believe means that there are verified facts that support the probability that a money laundering or terrorist activity financing offence has occurred. In other words, there is enough evidence to support a reasonable and trained person to believe, not just suspect, that a money laundering or terrorist activity financing offence has occurred. For example, law enforcement must reach reasonable grounds to believe that criminal activity has occurred before they can obtain judicial authorizations, such as a production order.

If you are in receipt of a production order from law enforcement related to a predicate offence, you must perform an assessment of the facts, context, and money laundering or terrorist activity financing indicators to determine whether you have reasonable grounds to suspect that a particular transaction is related to the commission of a money laundering or terrorist activity financing offence.

For an overview of the different thresholds, see Figure 1: Threshold for suspicion.

Figure 1: Threshold of suspicion — Figure 1: Threshold for suspicion

4. When to submit a Suspicious Transaction Report

You must submit the Suspicious Transaction Report to FINTRAC as soon as practicable after you have completed measures that enable you to establish that there are reasonable grounds to suspect that the transaction or attempted transaction is related to the commission of a money laundering or terrorist activity financing offence.

Note: There is no monetary threshold associated with the reporting of a suspicious transaction.

Measures you can take to establish the reasonable grounds to suspect threshold

The measures you can take to establish that there are reasonable grounds to suspect that the transaction or attempted transaction is related to the commission of a money laundering or terrorist activity financing offence include the following:

screening for and identifying suspicious transactions
assessing the facts and context surrounding the suspicious transaction
linking money laundering or terrorist activity financing indicators to your assessment of the facts and context
explaining your grounds for suspicion in a Suspicious Transaction Report, where you articulate how the facts, context and money laundering and terrorist activity financing indicators allowed you to reach your grounds for suspicion

Your measures must be described in your compliance policies and procedures.

What is a fact

A fact, for the purpose of completing a suspicious Transaction Report, is defined as an event, action, occurrence or element that exists or is known to have happened or existed. It cannot be an opinion.

For example:

Facts about a transaction could include the date, time, location, amount or type.
Facts known to a reporting entity could include account details, particular business lines, a client's financial history or information about a person or entity (for example, that the person has been convicted of a designated offence or is the subject of a production order, or that an entity is being investigated for fraud or any other indictable offence).

What is context

Context, for the purpose of completing a Suspicious Transaction Report, is defined as information that clarifies the circumstances or explains a situation or transaction. This type of information is essential to differentiate between what may be suspicious and what may be reasonable in a given scenario.

You may observe or understand the context of a transaction through:

a general awareness of the events occurring in a person or entity's business environment or community
your knowledge of the typical financial activities found within your business
regular know your client activities (for example, verifying the identity of persons and entities, their occupation or business, how they generate their wealth, their typical or expected transactional behaviours)
the information obtained through the application of your risk assessment
illustrative client details (for example, the financial background, behaviour and actions of your client)

A transaction may not appear suspicious in and of itself. However, a review of additional contextual elements surrounding the transaction may create suspicion. Conversely, the context of a particular transaction, which may have seemed unusual or suspicious from the onset, could lead you to reassess your client's current and past transactions and conclude that they are reasonable in that circumstance.

Your suspicion of money laundering or terrorist activity financing will likely materialize from your assessment of multiple elements (transactions, facts, context, and any other related information that may or may not be an indicator of money laundering or terrorist activity financing. When these elements are viewed together, they create a picture that will either support or negate your suspicion of the commission of a money laundering or terrorist activity financing offence.

Examples of how suspicion may arise

A person:
- asks several questions about your reporting obligations to FINTRAC (context)
- wants to know how they can avoid their transaction being reported to FINTRAC (context)
- structures their amounts to avoid client identification or reporting thresholds (fact)
- keeps changing their explanation for conducting a transaction or knows few details about its purpose (context)
Transactions constantly being made on behalf of another person or entity:
- a client conducts a transaction while accompanied, overseen or directed by another party (fact)
- payments to or from unrelated parties (foreign or domestic) (fact)
- client appears to be or states that they are acting on behalf of another party (context)

For reporting entity sectors that deal with accounts:

A person making a deposit to a personal account, where the person:
- has an income or job or account history that is not consistent with the deposit amounts (fact)
- keeps changing their reason for the deposit, and cannot or will not provide a reason (context)
- exhibits nervous behaviour (context)
Transactions to a business account with the following additional elements:
- deposits to the account are made by numerous parties that are not signing authorities or employees (fact)
- the account activity involves wire transfers in and out of the country (fact), which do not fit the expected pattern for that business (context)
Transactions frequently being made on behalf of another person or entity:
- multiple payments made to an account by non-account holders (fact)
- account is linked to seemingly unconnected parties (context)

What is a money laundering or terrorist activity financing indicator, or sanctions evasion characteristic

Money laundering and terrorist activity financing indicators, and sanctions evasion characteristics are potential red flags that can initiate suspicion and indicate that something may be unusual without a reasonable explanation. Red flags typically stem from one or more facts, behaviours, patterns or other contextual factors that identify irregularities related to a client's transactions. These often present inconsistencies with what is expected or considered normal based on the facts and context you know about your client and their transactional activities.

Criminal organizations often try to avoid the detection of money laundering or terrorist activity financing by using multiple concealment methods. Indicators of money laundering and terrorist activity financing can bring to light suspicious transactional activity, but it is your holistic assessment of facts, context and money laundering and terrorist activity financing indicators that will enable you to determine whether you have reached reasonable grounds to suspect that a transaction is related to the commission of a money laundering or terrorist activity financing offence. Indicators are also helpful to articulate your rationale for reaching the reasonable grounds to suspect threshold in a Suspicious Transaction Report. The explanation of how you reached your grounds for suspicion is extremely important for FINTRAC's development and disclosure of financial intelligence.

For more information and examples of money laundering and terrorist activity financing indicators applicable to your business sector:

Consult money laundering and terrorist financing indicators under All FINTRAC guidance – Transaction reporting
FINTRAC also publishes strategic intelligence products (for example, operational alerts and briefs) that focus on the identification of money laundering or terrorist activity financing related methods, techniques, and vulnerabilities

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

What is "as soon as practicable"

As soon as practicable means that you have completed the measures that have allowed you to determine that you reached the reasonable grounds to suspect threshold and as such the development and submission of that Suspicious Transaction Report must be treated as a priority. The greater the delay to submit a Suspicious Transaction Report, the greater the need for a suitable explanation. Suspicious Transaction Reports can be complex, yet you must treat them as a priority and ensure they are timely. You must also complete the measures that allowed you to conclude that you have reasonable grounds to suspect the transaction is related to the commission of a money laundering or terrorist activity financing offence before you submit the report to FINTRAC.

Failure to submit a Suspicious Transaction Report, or not submitting one in a timely manner, may impede FINTRAC's ability to carry out its mandate. FINTRAC expects that when you have completed your measures and determined that you have reasonable grounds to suspect that a transaction is related to the commission of a money laundering or terrorist activity financing offence, you will prioritize the submission of that Suspicious Transaction Report.

Note: In situations involving time-sensitive information, such as suspected terrorist financing and threats to national security, you are encouraged, as a best practice, to expedite the submission of your Suspicious Transaction Reports. We recommend that this be included in your compliance policies and procedures.

Legal references

Proceed of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations, SOR/2001-317
- section 9 (2)

5. How to submit a report to FINTRAC

You must submit a suspicious transaction report to FINTRAC electronically using the following options:

FINTRAC Web Reporting System (FWR) (geared towards reporting entities with lower reporting volumes)
FINTRAC API report submission (secure system-to-system transfer of report information)

Paper reporting

If you do not have the technical capability to submit reports electronically, you must submit reports in paper form to FINTRAC. You can access and print the Suspicious Transaction Report in paper form on the Paper reporting forms web page, or request to have one faxed or mailed to you by calling 1-866-346-8722.

You can submit a Suspicious Transaction Report in paper form to FINTRAC either by:

Fax: 1-866-226-2346
Mail:
Financial Transactions and Reports Analysis Centre of Canada
Section A
234 Laurier Avenue West, 24^th floor
Ottawa, ON K1P 1H7
Canada

Note: There is no official acknowledgement of receipt when you submit a paper form to FINTRAC.

Changes to a Suspicious Transaction Report

Once you have submitted a Suspicious Transaction Report, it is possible to modify the report, for instance to add missing information or make corrections, but you must provide an explanation for the change.

If you submitted a Suspicious Transaction Report to FINTRAC and need to make a subsequent change to the report, you must make the change and submit the revised report to FINTRAC within 20 days of the date in which you made the request for change, based on system requirements.

Legal references

Proceed of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations, SOR/2001-317
- section 12

6. The form for reporting suspicious transactions

Note

For details about submission limits (for reports submitted electronically), refer to:
- Transaction submission limits (FINTRAC API report submission)
To find out how to create subject profiles (for reports submitted through FINTRAC Web Reporting System), refer to:
- Creating subject profiles

Form structure

The form for reporting suspicious transactions has 6 sections:

General information
Transaction information
Starting action
Completing action
Details of suspicion
Action taken

Structure of the Suspicious 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	Reporting entity report reference number Information about your business including contact details Ministerial Directives
Transaction information	Transaction status (completed or attempted) Reason transaction was not completed (if applicable) Date and time of transaction Method of transaction Location where transaction was conducted or attempted Purpose of the transaction Reporting entity transaction reference number
Starting action	Direction of starting action (in or out) Amount and type of funds, assets or virtual currency (in or out) Currency or virtual currency type Information about the source of funds, assets or virtual currency Virtual currency address reference and/or account information Information about how the funds or virtual currency were obtained Conductor (person or entity that conducted or attempted the transaction and their associated information) Third party (person or entity on whose behalf the transaction is conducted or attempted and their associated information)
Completing action	Details of disposition Amount and currency or virtual currency type Virtual currency address, reference and/or account information Any other person or entity involved in the completing action and their associated information Beneficiary (any person or entity that was the beneficiary of the transaction and their associated information)
Details of suspicion	This is a free form text section where you can describe in clear, simple and concise language your grounds for suspicion of a money laundering, terrorist activity financing or sanctions evasion offence including the facts, context, and indicators that allowed you to reach reasonable grounds for suspicion. In this section, you can indicate: whether the suspicious activity is related to a money laundering, terrorist activity financing or sanctions evasion offence. the public-private partnership project name(s) whether the report includes information about an individual who has been determined to be a politically exposed person Report reference numbers of previously submitted reports that may relate to the suspicious activity mention in this report
Action taken	This is a free form text section where you can describe what action, if any, was or will be taken as a result of the suspicious transaction(s)
Note This table shows the type of information for each section but does not list every field on the form. To access most fields and their category (mandatory, mandatory for processing or reasonable efforts), refer to: Annex A: Field instructions to complete a Suspicious Transaction Report (which provides instructions on completing the form)

Form highlights

The structure of the form allows you to include 1 or more transactions in a report.

When entering multiple transactions into a report, you can enter transactions that have:
- the same or different transaction status (for example, a report can include completed transactions and attempted transactions), and
- have taken place at the same or different locations
For each completed or attempted transaction, you must provide all of these details:
- information obtained about that transaction
- the details of suspicion
- the action you have taken in the fields provided in the Suspicious Transaction Report
For example, if you know or obtained the following information, you must provide it in the Suspicious Transaction Report:
- name of the person or entity who completed or attempted to complete the transaction
- type and amount of funds, assets or virtual currency involved in the completed transaction or attempted transaction
- how the funds, assets or virtual currency were used (details of disposition) for a completed transaction or going to be used in an attempted transaction
- whether the person or entity who conducted or attempted the transaction did so on anyone else's behalf
- account details of an account involved in a completed transaction or was going to be involved in an attempted transaction
For a completed transaction, there should be at least 1 starting action and 1 completing action.
- You must also provide the name of the beneficiary to the transaction if you know or obtained this information.
  - For instance, if this transaction had also been submitted to FINTRAC in a different report (LVCTR, LCTR, EFTR, CDR), you may have obtained beneficiary name at that time.
A transaction can have multiple starting actions and/or completing actions—depending on the client's instructions.
- Within each starting action, you can include multiple conductors, account holders, sources of funds or virtual currency, and third parties.
  - If the conductor or third party is an entity, you can also include information about the entity's director(s), beneficial owner(s), trustee(s), settlor(s), and beneficiary(s) as applicable.
- Within each completing action, you can include multiple account holders, beneficiaries and other persons or entities involved in the completing action.
For each starting action, you will need to indicate the direction of the funds, asset or virtual currency used to start the transaction as either in or out.
- The direction of the starting action is in when a client physically brings in or electronically transfers in funds, assets or virtual currency to your business to start a transaction.
- The direction of the starting action is out when your client requests to start a transaction with client funds, assets or virtual currency already held by or deposited at your business.
For example:
- The direction of the starting action is in, if a client brings cash to your business to purchase a bank draft.
- The direction of the funds is out for the starting action, if a client does not bring in any funds but requests to purchase a bank draft with the client's funds already held by or deposited at your business.

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

You must complete the General Information section of the report and provide information for each transaction.
Every transaction must have at least:
- 1 starting action, and
- 1 completing action (if available)
A report can have multiple transactions and within each transaction, you can include multiple starting and completing actions.
When completing the report, you must ensure that the information you provide reflects your client's instructions and is consistent with your policies and procedures.

Example 1

On July 10, 2023, Ms. Green walks into branch 1 of Maple Credit Union and deposits $9,900 cash into her savings account.
On July 11, 2023, Ms. Green walks into branch 2 of Maple Credit Union with a cheque for $20,000 and deposits $12,000 into her savings account and $8,000 into her chequing account.
On July 12, 2023, Ms. Green walks into branch 1 of Maple Credit Union and instructs that $20,000 be withdrawn from her savings account and transferred to ABC Automotive Company's account at Hemlock Bank.

Based on a review of facts, context and indicators, as well as their procedures to assess suspicious transactions, Maple Credit Union establishes that there are reasonable grounds to suspect that the transactions are related to the commission of a money laundering or terrorist activity financing offence.

Therefore, Maple Credit Union submits a Suspicious Transaction Report. See Figure 2.

Illustration of a suspicious transaction with multiple transactions, starting actions and completing actions — Figure 2: Suspicious Transaction Report example

The Suspicious Transaction Report provides general information about Maple Credit Union and indicates that Ms. Green conducted 3 transactions:

The first transaction was conducted at branch 1 on July 10, 2023:
- 1 starting action involving $9,900 cash coming in, and
- 1 completing action where $9,900 is deposited into a savings account.
- As Ms. Green is the sole account holder, she is the beneficiary of this transaction.
The second transaction was conducted at branch 2 on July 11, 2023:
- 1 starting action involving a $20,000 cheque coming in, and
- 2 completing actions where $12,000 is deposited into a savings account and $8,000 is deposited into a chequing account.
- Ms. Green is the sole account holder for both accounts and therefore the beneficiary of this transaction.
The third transaction was conducted at branch 1 on July 12, 2023:
- 1 starting action involving $20,000 funds withdrawal out, and
- 1 completing action—an outgoing domestic funds transfer for $20,000 where ABC Automotive Company is the beneficiary.

In the Details of suspicion section of the Suspicious Transaction Report, Maple Credit Union provides the facts, context and indicators that allowed it to conclude that there are reasonable grounds to suspect that the transactions are related to the commission or attempted commission of a money laundering or terrorist activity financing offence.

In the Action taken section, Maple Credit Union describes the action it has taken.

7. Other requirements associated with suspicious transactions

In this section

Compliance program
Large cash transactions
Electronic funds transfers
Large virtual currency transactions
Casino disbursements
Terrorist property
Record keeping
Verifying the identity of persons or entities
Third party determination
Ministerial directives
Voluntary self-declaration of non-compliance

Compliance program

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

how you identify and assess Suspicious Transactions Reports
submitting reports to FINTRAC

If you have an automated or triggering system in place to detect suspicious transactions, a person may still assess the transaction(s), as a best practice, to determine whether there are reasonable grounds to suspect that a transaction is related to the commission of a money laundering or terrorist activity financing offence, and to ensure that, in these cases, the submission of a Suspicious Transaction Report.

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

You must also assess the effectiveness of your compliance program as a part of your two-year effectiveness review. This includes assessing how effective you are in detecting, assessing and submitting Suspicious Transaction Reports. The following are examples of how this can be done:

Review previously submitted Suspicious Transaction Reports to ensure that you are consistent in the detection, assessment and submission of these reports.
- If certain money laundering or terrorist activity financing indicators have supported your suspicions of money laundering or terrorist activity financing, you can assess whether these indicators apply to other situations to ensure that you are not missing suspicious transactions that should be or should have been reported to FINTRAC. This approach can help you build consistency within your organization.
Work with others in your business sector to learn how they are detecting, assessing and reaching the reasonable grounds to suspect threshold and to establish common ideas of what could be considered unusual or suspicious.

For more information, consult FINTRAC's strategic intelligence products:
- Strategic intelligence
Review a sample of your Suspicious Transaction Reports to assess the timeliness of your reporting of suspicious transactions.
- Specifically, you can review your business processes to ensure that you are submitting Suspicious Transaction Reports to FINTRAC as soon as practicable after you have completed measures that enable you to determine that there are reasonable grounds to suspect that the transaction or attempted transaction is related to the commission of a money laundering or terrorist activity financing offence.
Review a sample of your Suspicious Transaction Reports to assess the quality of information reported.
- This can include reviewing the integrity and consistency of know your client information held by your business and ensuring that all know your client information was included in the Suspicious Transaction Reports.

For more information:

Compliance program requirements

Large cash transactions

If the suspicious transaction involves a reportable large cash transaction, then you must submit a Large Cash Transaction Reports to FINTRAC in addition to a Suspicious Transaction Report.

For more information:

Reporting large cash transactions to FINTRAC

Electronic funds transfers

If the suspicious transaction involved a reportable electronic funds transfer, then you must submit an Electronic Funds Transfer Report to FINTRAC in addition to a Suspicious Transaction Report.

For more information:

Reporting electronic funds transfers to FINTRAC

Large virtual currency transactions

If the suspicious transaction involved a reportable large virtual currency transaction, then you must submit a Large Virtual Currency Transaction Report to FINTRAC in addition to a Suspicious Transaction Report.

For more information:

Reporting large virtual currency transactions to FINTRAC

Casino disbursements

If the suspicious transaction involved a reportable casino disbursement, then you must submit a Casino Disbursement Report to FINTRAC in addition to a Suspicious Transaction Report.

For more information:

Reporting casino disbursements to FINTRAC

Terrorist property

In addition to reporting a suspicious transaction, you may also be required to submit a Terrorist Property Reports to FINTRAC if you are required to make a disclosure under the Criminal Code or the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism.

For more information:

Reporting terrorist property to FINTRAC

Record keeping requirements

When you submit a Suspicious Transaction Report to FINTRAC, you must keep a copy of it for at least 5 years after the day the report is sent.

For more information:

Consult your sector-specific guidance under All FINTRAC guidance – Record Keeping

Legal references

Proceed of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations, SOR/2001-317
- section 12

Verifying the identity of persons and entities

You are required to take reasonable measures to verify the identity of every person or entity that conducts or attempts to conduct a suspicious transaction. This means that you are expected to ask the client for this information unless you think doing so will tip them off to your suspicion.

For more information:

Methods to verify the identify of the persons and entities
Consult your sector-specific guidance on when to verify the identity of persons and entities under All FINTRAC guidance- Knowing your client

Legal references

Proceed of Crime (Money Laundering) and Terrorist Financing Regulations, SOR/2002-184
- section 85(1)
- section 85(2)

Third party determination

There are requirements to determine whether a person or entity is acting on behalf of another person or entity for a financial activity or transaction.

For more information:

Third party determination requirements

Ministerial directives

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

For more information:

Ministerial directives and transaction restrictions

Voluntary self-declaration of non-compliance

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

For more information:

Voluntary self-declaration of non-compliance

8. Reporting subsequent suspicious transactions

Once you have reached the reasonable grounds to suspect threshold, you must submit a Suspicious Transaction Report. If there are subsequent transactions, you must keep reporting the transactions as long as the suspicion remains.

You are expected to periodically re-assess the client to verify that the level of suspicion has not changed. This process may be part of your documented risk assessment or ongoing monitoring.

If you continue to report Suspicious Transaction Reports on the same person or entity, you can reference a previous Suspicious Transaction Report in the Related Report(s) section by providing all of the following information:

the reporting entity report reference number and the reporting entity transaction reference number
the reasonable grounds to suspect (facts, context and money laundering and terrorist financing indicators) that were included in the first Suspicious Transaction Report submission
any new additional information

If you are reporting Suspicious Transaction Reports due to new facts, context, or money laundering or terrorist activity financing indicators revealed during your assessment of the client, you are expected to detail this new information in the Suspicious Transaction Reports.

For example, through the course of your assessment, you may have identified new money laundering or terrorist activity financing indicators, or new people or entities transacting with your client. You may choose to include that information under a separate heading in the Details of suspicion section of the Suspicious Transaction Report so that it is properly labeled as new information.

9. FINTRAC's expectations for completing a Suspicious Transaction Report

It is your responsibility to ensure that the information provided in a Suspicious Transaction Report is complete and accurate. It is also important that you submit comprehensive and high quality Suspicious Transaction Report to facilitate FINTRAC's analysis process and disclosure to recipients.

In the narrative sections of the Suspicious Transaction Report: Details of suspicion and Action taken, it is important to avoid jargon or non-public references, such as terms and acronyms that are specific to your organization. Please use clear, simple and concise language so that an outsider can easily understand the information that you provide.

A variety of information is often collected as part of an assessment to determine if you are required to submit a Suspicious Transaction Report and this information is valuable to include in your report to FINTRAC.

A well-completed Suspicious Transaction Report should consider the following questions:

Who are the parties to the transaction?
- Provide information on:
  - conductor(s)
  - third party(ies)
  - beneficiary(ies)
  - account holder(s)
  - source(s) of funds or virtual currency
  - any other person or entity involved in the transaction(s)
- Provide identifying information on the parties involved in the transaction. This could include the information you recorded to identify the conductor, as well as any information you have on the other parties to the transaction or its recipients. See the Annexes of the Methods to verify the identity of persons and entities for a summary of information that must be recorded when verifying identity.
- When possible, provide information on:
  - owner(s)
  - director(s)
  - officer(s)
  - trustee(s)
  - settlor(s)
  - those with signing authority
- If the transaction involves an entity, you can include information on the ownership, control and structure of the business in the Suspicious Transaction Report.
- Provide clear information about each person or entity's role in each of the financial transactions described. For example, it is important to know who is sending and receiving the funds and this can be elaborated in the Details of suspicion section of the Suspicious Transaction Report.
- Provide the relationships between the parties (if known). This is very helpful to FINTRAC when trying to establish networks of persons or entities suspected of being involved in the commission or attempted commission of a money laundering, terrorist activity financing or sanctions evasion offence.
When was the transaction completed/attempted? If it was not completed, why not?
- Provide the facts, context and money laundering and terrorist activity financing indicators, or sanctions evasion characteristics regarding the transaction
What are the financial instruments or mechanisms used to conduct the transaction?
Where did this transaction take place?
Why are the transaction(s) or attempted transaction(s) related to the commission or attempted commission of a money laundering, terrorist activity financing or sanctions evasion offence?
- State the money laundering or terrorist activity financing indicators, or sanctions evasion characteristics used to support your suspicion.
- State the suspected criminal offence related to money laundering, terrorist activity financing or sanctions evasion, if known.
How did the transaction take place?

Transactions and their details must be entered in the appropriate structured fields of the form.

Transactions may be referenced in the narrative section if there are additional facts or context.
Examples of structured fields where you can enter information include the following:
- a person's alias
- electronic transfers (such as email money transfers (EMTs) or wire transfers) including IP addresses and sender/recipient email addresses
- location of automated teller machine (ATM) withdrawals
- the ownership, control and structure of an entity
- the source of funds or virtual currency
- any related and previously submitted Suspicious Transaction Report report reference numbers and transaction reference numbers
- credit card activity including details of purchases (dates, amounts, retailer (online or in-store) and details of payments (dates, amounts, conductor and source of payment)

If there are transaction details for which there is no structured field for this information, you can include this information in the narrative section of the Suspicious Transaction Report.

Information provided in the narrative section of the Suspicious Transaction Report can contribute greatly to FINTRAC's analysis. This includes the following types of information:
- the history the client has with you
- links made to other people, businesses and accounts
- information on the ownership, control and structure of an entity that is not already captured in the fields provided in the Suspicious Transaction Report form, particularly for any business entities that have a complex structure
- the intended or expected use of an account versus the activity you may have observed
- any other information about your interactions with the client
- relationships between parties to the transaction
- the money laundering or terrorist activity financing indicators or factors that assisted in forming the basis of your suspicion
- any information, including publicly available information and/or information from law enforcement, that made you suspect that the transaction might be related to terrorist financing, money laundering, or both
- the location where a transaction was conducted, when this location does not belong to your business—for example, the location of a white label ATM that you do not own
- information on any politically exposed persons, including their names, role and involvement in the transactions being reported
- any details surrounding why an attempted transaction was not completed
- any context or clarification about the information that was reported in the structured sections

If there are multiple details for a field, provide the detail that is specific to the transaction.

This may occur for some fields such as the following:

email address
telephone number
URL
Username
Device identifier number
Internet protocol address

For example:

Your client Billy Bird has three email addresses (Sky@example.ca, Sky22@example.ca and BlueSky@example.ca.); and sends email money transfers (EMTs) to Oscar Ocean who is also your client. Oscar has two email addresses (Starfish@example.ca and Whaleshark@example.ca).
A recipient, who is not your client, has the email address, FastCar@example.ca and goes by an alias name, "Smitty".

The email addresses that you report in a Suspicious Transaction Report will depend on the transaction details.

The table below provides some transaction details and the expected email address that should be reported.

Transaction details	Email address to be reported in the Suspicious Transaction Report
Billy Bird sends an outgoing email money transfer (EMT) for $500 using Sky@example.ca to Oscar Ocean at Starfish@example.ca	Sky@example.ca (conductor email address field) Starfish@example.ca (beneficiary email address field).
Billy Bird sends an outgoing email money transfer (EMT) for $900 using Sky22@example.ca to Oscar Ocean at Whaleshark@example.ca.	Sky22@example.ca (conductor email address field) Whaleshark@example.ca (beneficiary email address field).
Billy Bird sends an outgoing email money transfer (EMT) for $1,000 using Sky22@example.ca to "Smitty" at FastCar@example.ca	Sky22@example.ca (conductor email address field) FastCar@example.ca (beneficiary email address field).

Any additional email addresses that you have on your client (and were not related to a specific transaction) can be reported in the Details of suspicion section of the Suspicious Transaction Report. In the example above, you can explain in this section that your client, Billy Bird, has a third email address (BlueSky@example.ca) that was not used in these transactions.

Note: If your client (conductor) is not sending an email money transfer (EMT), you should still report the client's email address that you have on file in the conductor email address field. If your client has more than one email address, the additional email addresses can be provided in the narrative section of the Suspicious Transaction Report (Details of suspicion).

FINTRAC has been able to identify networks of suspected money launderers and terrorist financiers through pieces of information such as email addresses and secondary identifiers (nicknames) or phone numbers. This type of information may seem insignificant but can be very important to FINTRAC, as it may identify connections among persons, entities or crimes when compared against other FINTRAC intelligence.

The Suspicious Transaction Report structure is intended to encourage reporting even in situations where you may not have information because the client did not provide any or asking for details might "tip off" the client to your suspicions. It is FINTRAC's expectation that if you have the information within your organization, that it be reported.

10. Common Suspicious Transaction Report deficiencies to avoid

The following are examples of deficiencies that FINTRAC has identified through its assessments and other compliance activities. FINTRAC is sharing these examples to illustrate common errors that you can avoid.

Using a higher threshold as your basis for reporting
- You are required to submit a Suspicious Transaction Report when you have completed the measures that enable you to establish that there are reasonable grounds to suspect that a transaction is related to the commission of a money laundering or terrorist activity financing offence as explained in section 3. Reasonable grounds to believe is a higher threshold than reasonable grounds to suspect and is beyond what is required to submit a Suspicious Transaction Report.
Failing to list all the transactions and accounts relevant to your suspicion in the specified fields
- You are required to report all the transactions and accounts that led to your determination that there are reasonable grounds to suspect that the transaction is related to the commission or attempted commission of a money laundering or terrorist activity financing offence in the specified fields of the report. Providing a summary of the transactions in the narrative section (Details of suspicion) is not enough.
Not providing or naming all parties to the transactions when the information is available
- All parties to the transaction, including their associated information, must be provided in their corresponding structured fields if this information is available. This includes any conductors, third parties, beneficiaries, account holders, sources of funds or virtual currency, and any other persons or entities involved in the transaction.
If an entity is involved, then owners, directors, officers, trustees, settlors and those with signing authority should be provided as applicable. You should also specify whether the parties are known or unknown.
This has been observed in transactions such as wire transfers that involve multiple parties.
- For example, if you are reporting a wire transfer, you should include any information you have on both the ordering client and beneficiary. This could include, but is not limited to, their names, their account number and institution, their relationship, and any known identifiers. FINTRAC acknowledges that this information may not always be at your disposal, but when you know it, you should provide it.
The information provided in the narrative section of the Suspicious Transaction Report (Details of suspicion) does not elaborate on your grounds for suspicion or link to the transaction(s) in the report
- You must explain the reason(s) for your determination that there are reasonable grounds to suspect that the transaction(s) is/(are) related to the commission or attempted commission of a money laundering or terrorist financing offence. This includes providing,in the narrative section of the Suspicious Transaction Report,all of the relevant facts, context and money laundering and terrorist activity financing indicators that are related to the transaction(s) in the report and support your suspicion.
- This deficiency has been observed when a reporting entity does not articulate the reasons for their suspicion or does not explain how or why certain information is relevant to their suspicion.

Annex A: Field instructions to complete a Suspicious Transaction Report

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

In this annex

Standardized field instructions
Specific field instructions

Note:

Some fields only become applicable on the completion of other fields.
Some field instructions may only apply to the electronic report submissions and not paper submissions.
Fields that are not applicable are to be left blank. When a field is not applicable:
- do not enter "Not applicable", "N/A" or "n/a", or
- do not substitute any other abbreviations, special characters ("x", "-"or "*") or words ("unknown") in the field
Failure to provide applicable reporting information will result in non-compliance and may lead to criminal or administrative penalties. To learn more about potential enforcement actions:
- Penalties for non-compliance

Standardized field instructions

This section contains instructions for:

the expected level of effort to obtain the prescribed information for the reporting fields
completing some fields that appear in multiple sections of the form.

In this section

Field categories
Name fields
Address fields
Occupation/business fields
Identification fields
Telephone number fields

Field categories

Fields are categorized as either:

mandatory
mandatory for processing
mandatory if applicable, or
reasonable measures

Instructions for field categories
Field categories	Instructions
Mandatory	These fields are indicated with an asterisk symbol *() and must be completed. However, in the case of an attempted transaction**, these fields become "reasonable measures" fields and you must take reasonable measures, as indicated in the instructions below, to obtain the information for any mandatory field. Legal references Proceed of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations, SOR/2001-317 section 11(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. For all fields, you are not required to obtain the information or take reasonable measures to obtain the information if you believe doing so will tip off the person or entity that you are submitting a Suspicious Transaction Report. Note: Fields that are not applicable are to be left blank. When a field is not applicable, do not enter "Not applicable", "N/A" or "n/a" or substitute any other abbreviations, special characters ("x", "-" or "*") or words ("unknown") in these fields. Legal references Proceed of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations, SOR/2001-317 section 11(1) section 11(3)

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:

Apartment/Room/Suite/Unit number
House/Building number
Street address
City
District
Country
Province or state (code) – For provinces or states in Canada, the United States or Mexico, select from the list of options.
Province or state (name) – For provinces or states outside Canada, the United States or Mexico, provide the name of the province or state.
Sub-province and/or sub-locality
Postal or zip code

If you have the ability to separate the information

You must report it in the structured address fields.

For example, if a person lives at #10-123 Main Street, Richmond, 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:

all the address information in the street address field
the city, province, country and postal code in their respective fields

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:

street address/city/province or state/postal code or zip code

Invalid addresses

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

a post office box without a complete physical address (for example, PO Box 333)
general delivery address
only a suite number (for example, Suite 256) without additional address information

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:

FINTRAC's guidance on Methods to verify the identity of persons and entities

Number associated with identifier type

This is the number indicated on the identifier type that was used to verify the identity of the person or entity. For example, on a driver’s licence, the licence number is the identification number and on a Certificate of Incorporation, the incorporation number is the identification number.

Jurisdiction of issue (country, province or state)

Provide the country, province, or state that issued the documentation used to identify the person or entity.

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 Suspicious Transaction Report form.

Note: For some fields, the instructions:

have not been provided and are indicated as "Instructions not specified"
refer to the Standardized field instructions section

In this section

General information
Transaction information
Starting action
Completing action
Details of suspicion
Action taken

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

Instructions for the fields under "Report information"
Fields	Instructions
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: Only one Ministerial Directive (IR2020) is available for a Suspicious Transaction report. If you select Ministerial Directive, then the report can only contain one transaction. This transaction must be a completed transaction that includes a starting and completing action. In addition, you must not complete the "Details of suspicion" and "Action taken" sections of the Suspicious Transaction Report form. If a transaction is being reported to FINTRAC under a Ministerial Directive and the transaction also meets the reasonable grounds to suspect threshold, then you must submit two reports to FINTRAC. In the first report, select Ministerial Directive and do not complete the "Details of suspicion" and "Action taken" sections of the Suspicious Transaction Report form. In the second report, do not select Ministerial Directive but complete all applicable fields of the form, including the "Details of suspicion" and "Action taken" sections.

Transaction information: Transaction 1 of X

Information about the transaction

Instructions for the fields under "Information about the transaction"
Fields	Instructions
* Was the transaction attempted?	Select yes if the transaction was attempted. Select no if the transaction was completed.
†Reason transaction was not completed	If the transaction was not completed, provide the reason.
† Date of transaction	Enter the date of the transaction or attempted transaction. It cannot be a future date and must be different from the posting date. This field is mandatory, unless you: are a financial entity, and indicate that the transaction was a night deposit or a quick drop. If you do not provide the date of transaction in this field, you must provide the date of posting if different from date of transaction. Refer to the field Date of posting for more information.
Time of transaction	Enter the time of the transaction or attempted transaction and provide the time zone (that is, UTC offset) based on the location where the transaction or attempted transaction took place (for example, the location of where the cash was received). The time must be entered in the following format: HH:MM:SS±ZZ:ZZ. For example, 1:25:06 pm in Ottawa, ON would be reported as 13:25:06-05:00. A report can contain multiple transactions that took place in different time zones. If you do not know the time of an attempted transaction, but you are aware of the approximate time frame of when the attempted transaction occurred, you can indicate this in the narrative section of the report (Details of suspicion)—for example, afternoon, morning, between 3 to 4 pm.
* Method of transaction	Select the method that describes how the transaction occurred (example, the method that describes how you received the cash, funds, or virtual currency). 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 of the method of transaction.
Date of posting (if different from date of transaction)	Enter the date the transaction is posted, if this differs from the date 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.
Time of posting (if different from the time of transaction)	Enter the time of posting, if this differs from of the time of the transaction. The time must be entered in the following format: HH:MM:SS±ZZ:ZZ. For example, 1:25:06 pm in Ottawa, ON would be reported as 13:25:06-05:00.
‡ 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. 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 purchases jewellery that will be a gift for a friend. A client exchanges Canadian dollars (CAD) to British pound sterlings (GBP) for vacation purposes. A client brings purchases 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 or attempted

Provide information about the physical location where the transaction took place or was attempted.

For example, if the transaction was conducted at:

a branch, provide the reporting entity location number of that branch
an automated teller machine (ATM), provide the reporting entity location number of that ATM

For the following situations, provide the location number of where the transaction was processed – this could be a branch location or a head office location, depending on your business process:

There is no physical location (for instance, the transaction was conducted online).
The location where the transaction occurred does not belong to your business (for instance the location of a white label ATM that you do not own).

Note:

Information about a location that does not belong to your business can be provided in the narrative section of the Suspicious Transaction Report.

Instructions for the field under "Information about where the transaction was conducted or attempted"
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. If the client conducts a transaction online, then select the location number that is associated with the location that processes the client's online instructions – this could be a branch location or head office location, depending on your business process. 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 1 of Y of transaction X"
Fields	Instructions
‡ Direction of Starting Action (In /Out)	Indicate the direction of the starting action as either in or out for the funds, assets or virtual currency involved. The direction of the starting action is in when a client physically brings in or electronically transfers in funds, assets or virtual currency to your business to start a transaction. The direction of the starting action is out when your client requests to start a transaction with funds, assets or virtual currency already held by or deposited at your business.
‡ Type of funds, assets or virtual currency (In/Out	If the direction of the starting action is in, select one of the following based on what the client brought or transferred in to start the transaction: Bank draft – To be used when the client brings in a bank draft to start a transaction. The term bank draft refers to a negotiable instrument that can be used as payment (similar to a cheque). Unlike a cheque though, a bank draft is guaranteed by the issuing bank. Cash – To be used when the client brings in coins or bank notes that are intended for circulation in Canada or coins or bank notes of countries other than Canada to start a transaction. Casino product – To be used when the client brings in chips, plaques, tokens or other casino products to start a transaction. Cheque – To be used when the client brings in a cheque, including personal, certified and casino cheques, to start a transaction. Domestic funds transfer – To be used when the starting action involves the final receipt of funds from within Canada. This includes transfers within the same organization where funds are transferred from one account to another account. Email money transfer (EMT) – To be used when the starting action involves an incoming email transfer using the recipient's email address. International funds transfer – To be used when the starting action involves the final receipt of funds from outside Canada. Investment product – To be used when the starting action involves an incoming transfer of an investment product (for example, transfer of shares from one investment account to another). Jewellery – To be used when the client brings in jewellery to start a transaction. Jewellery means objects made of precious metals, precious stones or pearls that are intended for personal adornment. Mobile money transfer – To be used when the starting action involves an incoming mobile transfer using the recipient's phone number. Money order – To be used when the client brings in a money order to start a transaction. A money order is a certificate, usually issued by a government or financial institution that allows the stated payee to receive cash on demand. Precious metals – To be used when the client brings in precious metal(s) to start a transaction. Precious metals means gold, silver, palladium and platinum in the form of coins, bars, ingots, granules or in other similar forms. Precious stones – To be used when the client brings in precious stone(s) to start a transaction. Precious stones means diamonds, sapphires, emeralds, tanzanites, rubies or alexandrites. Virtual currency – To be used when you receive virtual currency for a client as part of the starting action. Other – To be used when the type of funds, assets or virtual currency physically brought in or electronically transferred in by the client to start the transaction is not captured by any other type listed above. Upon selecting "Other," you must provide a description of the type of funds, assets or virtual currency. If the direction of the starting action is out, select one of the following based on what the client used to start the transaction: Casino product -- To be used when the client starts a transaction with chips, plaques, tokens or other casino products that are held by your business for the client. Funds withdrawal -- To be used when the client withdraws funds held or deposited at your business to start a transaction. Investment product -- To be used when the client starts a transaction with an investment product held by your business for the client. Virtual currency -- To be used when a client starts a transaction with virtual currency held in a wallet or an account at your business. Other -- To be used when the type of funds, assets or virtual currency held by your business for the client to start the transaction is not captured by any other type listed above. Upon selecting "Other," you must provide a description of the type of funds, assets or virtual currency.
† If "Other," please specify	Provide a description of the type of funds, assets for virtual currency.
* Amount	Enter the total amount of funds, assets or virtual currency involved in the starting action. If this amount was not in Canadian dollars (CAD), do not convert it to CAD but provide the currency or virtual currency type in the next field.
† Currency / † Virtual currency type	Enter the fiat currency (including if it was in Canadian dollars) or virtual currency of the starting action. If the currency or virtual currency type is not in the lists provided, you must select "Other" and provide the full name of the currency.
† If "Other," please specify	If "Other", provide the full name of the currency or virtual currency type.
Exchange rate	Provide the rate of exchange that you used for the transaction. This can be an exchange rate for fiat currency or virtual currency.
† Virtual currency transaction identifier	This is a unique identifier. It is commonly represented by a hash consisting of mixed numerical and alphabetical characters.
† Sending virtual currency address	The sending virtual currency address is made up of a number of alpha-numeric characters. The address length is determined by the type of virtual currency used in the transaction. The sending virtual currency address is associated with whoever is sending the virtual currency (typically the conductor).
† Receiving virtual currency address	The receiving virtual currency address is made up of a number of alpha-numeric characters. The address length is determined by the type of virtual currency used in the transaction. The receiving virtual currency address is associated with whoever is receiving the virtual currency (typically the beneficiary)
† 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, do not provide the account number information in this field. The account number must be provided 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	Provide the financial institution number of the account from which the transaction initiated.
† Branch number	Provide the branch number of the account from which the transaction is initiated.
† Account number	If the transaction involves an account at a financial entity, securities dealer or casino, provide the 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	Provide the account type If the account type is not in the list provided, you must select "Other" and provide the account type.
† If "Other," please specify	If "Other" is selected, you must provide the account type.
† Account currency	Provide the account currency (fiat) type code. Currencies are represented both numerically and alphabetically, using either three digits or three letters. If the account currency type code can not be found, you must select "Other" and provide the currency (fiat) type.
† Account virtual currency type	Provide the account virtual currency type. If the account virtual currency type is not in the list provided, you must select "Other" and provide the account virtual currency type.
† If "Other," please specify	If "Other" is selected, you must provide the account currency (fiat) type or account virtual currency type.
Date account opened	Provide the date the account was opened.
Date account closed	Provide the date the account was closed.
† Status of account at time of transaction	Provide the status of the account at the time of the transaction (e.g. active, inactive, dormant, closed).
How were the funds or virtual currency obtained?	This is how the conductor initially acquired the funds or virtual currency used for the transaction, not where the funds or virtual currency may have been transferred from. For example, you can obtain funds or virtual currency from activities such as: employment sale of a large asset, and gifts This information must be reported if obtained.
‡ Was information about the source (person/entity) of funds or virtual currency obtained?	This field is a "Yes/No" question. Select "Yes" if you have: the name of any person or entity that is the source of the funds or virtual currency their account number or policy number, or an identifying number if there is no account number or policy number Otherwise, select "No" to indicate that you do not have the information.

Account holder

Person

Instructions for the fields under "Person 1 of N starting action Z"
Fields	Instructions
† Surname	Refer to Name fields under "Standardized field instructions".
† Given name	Same instructions (Name fields)
Other/initial	Same instructions (Name fields)

Entity

Instructions for the fields under "Entity 1 of N starting action Z"
Fields	Instructions
† Name of entity	Refer to Name fields under "Standardized field instructions".

Source of funds or virtual currency

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

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

Person

Instructions for the fields under "Person 1 of N of starting action Y"
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 funds. 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.

Entity

Instructions for the fields under "Entity 1 of N of starting action Y"
Fields	Instructions
† Name of entity	Refer to Name fields under "Standardized field instructions".
Account number	Provide the account number for the source of funds. 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 source of funds or virtual currency fields

Although the following fields are about how the conductor obtained the funds or virtual currency, they are different:

How were the funds or virtual currency obtained?
Was information about the source (person/entity) of funds or virtual currency obtained?
Source of funds or virtual currency – person or entity

The following example demonstrates the 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 funds or virtual currency fields would be completed as follows:

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

Conductor information

Instructions for the fields under "Conductor – indicator"
Field	Instructions
‡Have you obtained any conductor information related to this transaction or attempted transaction?	This field is a "Yes/No" question. "No" should only be selected if the conductor is not your client, and after taking reasonable measures, you were not able to obtain any conductor details.

Instructions for the fields under "Person 1of A of starting action Y"
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	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
URL	Enter the uniform resource location, commonly known as the web address, for the conductor. This includes the URL for personal or business websites, blogs and any social media. If the conductor has more than one URL, provide the main URL in this field and the others in the Details of suspicion section. The URL does not include handles which can be included in the Details of suspicion section.
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.
Country of citizenship	Enter the primary country of citizenship for the person. It can be same or different from the country entered into the address section.
Occupation	Refer to Occupation/business fields under "Standardized field instructions".
Name of employer	Same instructions (Occupation/business fields)

Instructions for the fields under "Information about the employer's address"
Fields	Instructions
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	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)

Identification of the person

Instructions for the fields under "Identification of 1 of N of person conductor A"
Fields	Instructions
Identifier type	Refer to Identification fields under "Standardized field instructions".
† If "Other", please specify	If "Other" identifier type is selected, you must specify the identifier type.
Number associated with identifier type	Same instructions (Identification fields)
Jurisdiction of issue (country)	Same instructions (Identification fields)
Jurisdiction of issue (province or state)	Same instructions (Identification fields)

Instructions for the fields under "Information about conducting or attempting to conduct the transaction online"
Fields	Instructions
Type of device used	Provide the type of device used. If "Other" type of device used is selected, you must specify the type of device used.
† If "Other", please specify	If "Other" type of device used is selected, you must specify the type of device used.
Username	A username is how a person or an entity refers to themselves online.
Device identifier number	The device identifier number is a number assigned to the device, such as a Media Access Control (MAC) address or International Mobile Equipment Identity (IMEI) number.
Internet protocol address	Provide the Internet Protocol (IP) address. It is the unique identifying number assigned to every device connected to the internet.
Date and time of online session in which request was made	This is the date and time the conductor accessed the online environment where the transaction was requested.

Conductor – Entity

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

Instructions for the fields under "Entity 1 of A starting action Y"
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	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 "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
URL	Enter the uniform resource location, commonly known as the web address, for the conductor. This includes the URL for personal or business websites, blogs and any social media. If the conductor has more than one URL, provide the main URL in this field and the others in the Details of suspicion section. The URL does not include handles which can be included in the Details of suspicion section.

Information respecting the structure of Entity 1 of N of entity conductor A
Fields	Instructions
Entity structure / type	Provide the entity ownership structure type: Corporation Trust Widely held or publicly traded trust, or Entity other than a corporation or trust
If "Entity other than a corporation or trust" is selected, please specify	If "Entity other than a corporation or trust" is selected, provide specification.
Nature of entity's principal business	Refer to Occupation/business fields under "Standardized field instructions".
Is the entity registered or incorporated?	This field is a "Yes/No" question. Indicate whether entity is registered or incorporated

Incorporation of the entity

Information under Incorporation 1 of N of entity conductor A
Fields	Instructions
Incorporation number	Provide the incorporation number of the entity conducting the transaction for each jurisdiction where the entity is incorporated.
Jurisdiction of issue (country) of incorporation	Provide the country that issued the documentation used to identify the entity for each jurisdiction where the entity is incorporated.
Jurisdiction of issue (province or state) of incorporation	Provide the jurisdiction of issue (province or state) of incorporation 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. If the jurisdiction is outside Canada, the United States or Mexico, provide the name of the province or state.

Registration of the entity

Registration 1 of N of entity conductor A
Fields	Instructions
Registration number	Provide the registration number of the entity conducting the transaction for each jurisdiction where the entity is registered. For Canadian entities, a registration number can include the 9-digit business number assigned to that entity by the Canadian Revenue Agency (CRA)
Jurisdiction of issue (country) of registration	Provide the country that issued the documentation for each jurisdiction where the entity is registered.
Jurisdiction of issue (province or state) of registration	Provide the jurisdiction of issue (province or state) 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. If the jurisdiction is outside Canada, the United States or Mexico, provide the name of the province or state.

Identification of the entity

Provide the following information that was used to verify the identity of the entity. For some entities, this information may be the same as the registration or incorporation information.

Instructions for the fields under "Identification 1 of N of entity conductor A"
Fields	Instructions
Identifier type	Refer to Identification fields under "Standardized field instructions".
† If "Other", please specify	If "Other" identifier type is selected, you must specify the identifier type.
Number associated with identifier type	Same instructions (Identification fields)
Jurisdiction of issue (country)	Same instructions (Identification fields)
Jurisdiction of issue (province or state)	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:

bind the entity, or
act with respect to the account

Instructions for the fields under "Person 1 of N (max 3)"
Fields	Instructions
Surname	Refer to Name fields under "Standardized field instructions".
Given name	Same instructions (Name fields)
Other/Initial	Same instructions (Name fields)

Entity Structure/Type:

Corporate Information

Director(s) of a corporation

Instructions for the fields under "Director 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Name fields under "Standardized field instructions".
Given name	Same instructions (Name fields)
Other/Initial	Same instructions (Name fields)
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	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)

Person who directly or indirectly owns or controls 25% or more shares of the corporation

Instructions for the fields under "Person 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Name fields under "Standardized field instructions".
Given name	Same instructions (Name fields)
Other/Initial	Same instructions (Name fields)

Trust Information

Trustee(s) of a trust

Instructions for the fields under "Trustee 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Name fields under "Standardized field instructions".
Given name	Same instructions (Name fields)
Other/Initial	Same instructions (Name fields)
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	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)

Settlor(s) of a trust

Instructions for the fields under "Settlor 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Name fields under "Standardized field instructions".
Given name	Same instructions (Name fields)
Other/Initial	Same instructions (Name fields)
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	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)

Widely held or publicly traded trust information

Person who directly or indirectly owns or controls 25% or more units of a widely held or publicly traded trust

Instructions for the fields under "Person 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Name fields under "Standardized field instructions".
Given name	Same instructions (Name fields)
Other/Initial	Same instructions (Name fields)
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	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)

Beneficiary(ies) of a trust, other than a widely held or publicly traded trust

Instructions for the fields under "Beneficiary 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Name fields under "Standardized field instructions".
Given name	Same instructions (Name fields)
Other/Initial	Same instructions (Name fields)
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	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)

Entity other than a corporation or trust information

Person who directly or indirectly owns or controls 25% or more of an entity other than a corporation or trust

Instructions for the fields under "Person 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Name fields under "Standardized field instructions".
Given name	Same instructions (Name fields)
Other/Initial	Same instructions (Name fields)

Instructions for the fields under "Information about conducting or attempting to conduct the transaction online"
Fields	Instructions
Type of device used	Provide the type of device used. If "Other" type of device used is selected, you must specify the type of device used.
† If "Other", please specify	If "Other" type of device used is selected, you must specify the type of device used.
Username	A username is how a person or an entity refers to themselves online.
Device identifier number	The device identifier number is a number assigned to the device, such as a Media Access Control (MAC) address or International Mobile Equipment Identity (IMEI) number.
Internet protocol address	Provide the Internet Protocol (IP) address. It is the unique identifying number assigned to every device connected to the internet.
Date and time of online session in which request was made	This is the date and time the conductor accessed the online environment where the transaction was requested.

On behalf of

On behalf of indicator

Instructions for the field under "On behalf of indicator"
Field	Instructions
‡ Was this transaction conducted or attempted on behalf of another person or entity?	This field is a "Yes/No" question. Select "Yes" if the transaction was conducted on behalf of another person or entity. The "on behalf of" party is also known as: the "third party", or the party providing instructions for the transaction If the transaction was conducted on behalf of another person, you must include the relevant information below.

Instructions for the fields under "Person 1 of B of conductor A"
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	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)
URL	Enter the uniform resource location, commonly known as the web address, for the conductor. This includes the URL for personal or business websites, blogs and any social media. If the conductor has more than one URL, provide the main URL in this field and the others in the Details of suspicion section. The URL does not include handles which can be included in the Details of suspicion section.
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.
Country of citizenship	Enter the primary country of citizenship for the person. It can be same or different from the country entered into the address section.
Occupation	Refer to Occupation/business fields under "Standardized field instructions".
Name of employer	Same instructions (Occupation/business fields)

Instructions for the fields under "Information about the employer's address"
Fields	Instructions
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	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)

Identification of person on whose behalf the transaction was conducted

Instructions for the fields under "Identification 1 of N on behalf of person B"
Fields	Instructions
Identifier type	Refer to Identification fields under "Standardized field instructions".
† If "Other", please specify	If "Other" identifier type is selected, you must specify the identifier type.
Number associated with identifier type	Same instructions (Identification fields)
Jurisdiction of issue (country)	Same instructions (Identification fields)
Jurisdiction of issue (province or state)	Same instructions (Identification fields)

Instructions for the fields under "Information about conducting or attempting to conduct the transaction online"
Fields	Instructions
Type of device used	Provide the type of device used. If "Other" type of device used is selected, you must specify the type of device used.
† If "Other". Please specify	If "Other" is selected, specify the type of device used.
Username	A username is how a person or an entity refers to themselves online.
Device identifier number	The device identifier number is a number assigned to the device, such as a Media Access Control (MAC) address or International Mobile Equipment Identity (IMEI) number.
Internet protocol address	Provide the Internet Protocol (IP) address. It is the unique identifying number assigned to every device connected to the internet.
Date and time of online session in which request was made	This is the date and time the conductor accessed the online environment where the transaction was requested.

Instructions for the fields under "Relationship of the person named above to the person or entity conducting or attempting to conduct 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	If "Other" is selected, specify the relationship of the "on behalf of" party to the person or entity conducting the transaction.

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

Instructions for the fields under "Entity 1 of B of conductor A"
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	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
URL	Enter the uniform resource location, commonly known as the web address, for the conductor. This includes the URL for personal or business websites, blogs and any social media. If the conductor has more than one URL, provide the main URL in this field and the others in the Details of suspicion section. The URL does not include handles which can be included in the Details of suspicion section.

Instructions for the fields under "Information respecting the structure of Entity 1 of B"
Fields	Instructions
Entity structure / type	Provide the entity ownership structure type: Corporation Trust Widely held or publicly traded trust, or Entity other than a corporation or trust
If "Entity other than a corporation or trust" is selected, please specify	If "Entity other than a corporation or trust" is selected, provide specification.
Nature of entity's principal business	Refer to Occupation/business fields under "Standardized field instructions".
‡Do you have incorporation or registration information?	This field is a "Yes/No" question. Select "Yes" if you have the information. Select 'No' if you do not have the information.
Incorporated or registered?	Provide the incorporation or registration type: Incorporated Registered Incorporated and registered, or Unknown

Incorporation of the entity

Instructions for fields under "Incorporation 1 of N of entity B"
Fields	Instructions
Incorporation number	Provide the incorporation number of the entity conducting the transaction for each jurisdiction where the entity is incorporated.
Jurisdiction of issue (country) of incorporation	Provide the country that issued the documentation used to identify the entity for each jurisdiction where the entity is incorporated.
Jurisdiction of issue (province or state) of incorporation	Provide the jurisdiction of issue (province or state) of incorporation 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. If the jurisdiction is outside Canada, the United States or Mexico, provide the name of the province or state.

Registration of the entity

Instructions for fields under "Registration 1 of N of entity B"
Fields	Instructions
Registration number	Provide the registration of the entity conducting the transaction For Canadian entities, a registration number can include the 9-digit business number assigned to that entity by the Canada Revenue Agency (CRA).
Jurisdiction of issue (country) of registration	Provide the country that issued the documentation for each jurisdiction where the entity is registered.
Jurisdiction of issue (province or state) of registration	Provide the jurisdiction of issue (province or state) 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. If the jurisdiction is outside Canada, the United States or Mexico, provide the name of the province or state.

Identification of the 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 1 of N on behalf of entity B"
Fields	Instructions
Identifier type	Refer to Identification fields under "Standardized field instructions".
† If "Other", please specify	If "Other" identifier type is selected, you must specify the identifier type.
Number associated with identifier type	Same instructions (Identification fields)
Jurisdiction of issue (country)	Same instructions (Identification fields)
Jurisdiction of issue (province or state)	Same instructions (Identification fields)

Person authorized to bind the entity or act with respect to the account (maximum 3)

Instructions for the fields under "Person 1 of N (max.3)"
Fields	Instructions
Surname	Refer to Name fields under "Standardized field instructions".
Given name	Same instructions (Name fields)
Other/Initial	Same instructions (Name fields)

Beneficial Ownership information (Entity structure / type)

Corporate information: Directors of a corporation

Instructions for the fields under "Director 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Identification fields under "Standardized field instructions".
Given Name	Same instructions (Identification fields)
Other/Initial	Same instructions (Identification fields)
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	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)

Person who directly or indirectly owns or controls 25% or more shares of the corporation

Instructions for the fields under "Person 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Identification fields under "Standardized field instructions".
Given Name	Same instructions (Identification fields)
Other/Initial	Same instructions (Identification fields)

Trust Information

Trustee(s) of a trust

Instructions for the fields under "Trustee 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Identification fields under "Standardized field instructions".
Given Name	Same instructions (Identification fields)
Other/Initial	Same instructions (Identification fields)
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	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)

Settlor(s) of a trust

Instructions for the fields under "Settlor 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Identification fields under "Standardized field instructions".
Given Name	Same instructions (Identification fields)
Other/Initial	Same instructions (Identification fields)
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	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)

Widely held or publicly traded trust information

Person who directly or indirectly owns or controls 25% or more units of a widely held or publicly traded trust.

Instructions for the fields under "Person 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Identification fields under "Standardized field instructions".
Given Name	Same instructions (Identification fields)
Other/Initial	Same instructions (Identification fields)
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	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)

Beneficiary(s) of a trust, other than a widely held or publicly traded trust

Instructions for the fields under "Beneficiary 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Identification fields under "Standardized field instructions".
Given Name	Same instructions (Identification fields)
Other/Initial	Same instructions (Identification fields)
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	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)

Entity other than a corporation or trust information

Person who directly or indirectly owns or controls 25% or more of an entity other than a corporation or trust

Instructions for the fields under "Person 1 of N of starting action Y"
Fields	Instructions
Surname	Refer to Identification fields under "Standardized field instructions".
Given Name	Same instructions (Identification fields)
Other/Initial	Same instructions (Identification fields)

Instructions for the fields under "Information about conducting or attempting to conduct the transaction online"
Fields	Instructions
Type of device used	Provide the type of device used. If "Other" type of device used is selected, you must specify the type of device used.
† If "Other". Please specify	If "Other" type of device used is selected, you must specify the type of device used.
Username	A username is how a person or an entity refers to themselves online.
Device identifier number	The device identifier number is a number assigned to the device, such as a Media Access Control (MAC) address or International Mobile Equipment Identity (IMEI) number.
Internet protocol address	Provide the Internet Protocol (IP) address. It is the unique identifying number assigned to every device connected to the internet.
Date and time of online session in which request was made	This is the date and time the conductor accessed the online environment where the transaction was requested.

Instructions for the fields under "Relationship of the entity named above to the person or entity conducting or attempting to conduct the transaction"
Fields	Instructions
Relationship	Select the relationship of the "on behalf of" party to the person or entity conducting or attempting to conduct the transaction. The "on behalf of" party is understood to be the person or entity that instructs the person or entity conducting or attempting to conduct the transaction
† If "Other". Please specify	If "Other" is selected, specify the relationship of the "on behalf of" party to the person or entity conducting the transaction.

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).
Cash out	Select when cash is paid out by a non-account based reporting entity, such as a money services business.
Cash withdrawal (account based)	Select when cash is withdrawn from an account-based reporting entity, such as a bank or credit union.
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, Canadian dollars to US dollars), or a virtual currency-to-fiat exchange (for example, bitcoin to Canadian dollars) 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, Canadian dollars to bitcoin), or a virtual currency-to-virtual currency exchange (for example, bitcoin to ethereum (ETH))
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, receipt of funds to 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 or 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 (EMT)	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.
Payment to account	Select when funds or virtual currency are used to pay down a loan, mortgage, line of credit or credit card account balance.
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, 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, a 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

Instructions for the "Completing action fields"
Fields	Instructions
† If 'Other', please specify	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".
* Amount	Enter the amount involved in the completing action. For example, this may be the amount of: virtual currency after an exchange to virtual currency funds being initiated for an outgoing international funds transfer funds indicated on the bank draft
† Currency	If the disposition involves a fiat currency, enter the currency even if it was in Canadian dollars. If the currency type is not in the list provided, you must select "Other" and provide the name of the currency.
† Virtual currency type	If the disposition involves virtual currency, select the virtual currency. If the currency type is not in the list provided, you must select "Other" and provide the name of the virtual currency.
† If "Other", please specify	If "Other" is selected, you must provide the name of the type of currency or virtual currency
† Exchange rate	Provide the rate of exchange that you used for the transaction. This can be an exchange rate for fiat currency or virtual currency.
† Value in Canadian dollars	Provide the Canadian dollar value of the disposition if not in fiat or virtual currency. For example, provide the Canadian dollar value of the jewellery, precious metals or precious stones that were purchased. This may be the market, retail or other value that you would use in the ordinary course of your business at the time of transaction, and as detailed by and in accordance with your policies and procedures.
† Virtual currency transaction identifier	This is a unique identifier. It is commonly represented by a hash consisting of mixed numerical and alphabetical characters.
† Sending virtual currency address	The sending virtual currency address is made up of a number of alpha-numeric characters. The address length is determined by the type of virtual currency used in the transaction. The sending virtual currency address is associated with whoever is sending the virtual currency (typically the conductor).
† Receiving virtual currency address	The receiving virtual currency address is made up of a number of alpha-numeric characters. The address length is determined by the type of virtual currency used in the transaction. The receiving virtual currency address is associated with whoever is receiving the virtual currency (typically the beneficiary)
† 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, provide the 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	Provide the account type. If the account type is not in the list provided, you must select "Other" and provide the account type.
† If "Other", please specify	If "Other" account type is selected, you must specify the account type.
† Account currency	Provide the account currency (fiat) type code. Currencies are represented both numerically and alphabetically, using either three digits or three letters. If the account currency type code can not be found, you must select "Other" and provide the currency (fiat) type.
† Account virtual currency type	Provide the account virtual currency type. If the account virtual currency type is not in the list provided, you must select "Other" and provide the account virtual currency type.
† If "Other", please specify	If "Other", provide the full name of the currency or virtual currency type.
Date account opened	Provide the date the account was opened.
Date account closed	Provide the date the account was closed.
† Status of account at the time of transaction	Provide the status of the account at the time of the transaction (for example: active, inactive, dormant, closed).
‡ Was there any other person or entity involved in the completing action?	This field is a "Yes/No" question. See Involved in the completing action, below.

Account holder – person

Instructions for the fields under "Person 1 of N completing action Z"
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 "Entity 1 of N completing action Z"
Field	Instructions
† Name of entity	Refer to Name fields under "Standardized field instructions".

Involved in the completing action

Person involved in the completing action

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

Note: These persons cannot be:

the conductor
on behalf of party, or
beneficiary of the transaction

Instructions for the fields under "Person 1 of N of completing action Z"
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. If the transaction involves an account at a financial entity, securities dealer or casino, provide the 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. 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:

the conductor
on behalf of party, or
beneficiary of the transaction

Instructions for the fields under "Entity 1 of N of completing action Z"
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. If the transaction involves an account at a financial entity, securities dealer or casino, provide the 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. 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

Instructions for the fields under "Beneficiary Indicator"
Fields	Instructions
‡ Have you obtained any beneficiary information related to this transaction or attempted transaction? (Only select No if the beneficiary is not your client and, after taking reasonable measures, you were not able to obtain any beneficiary details.)	This field is a "Yes/No" question. Only select No if the beneficiary is not your client and, after taking reasonable measures, you were not able to obtain any beneficiary details.

Provide beneficiary information for each completing action.

A beneficiary, for example, can be:

the person who receives the virtual currency
the person named on a money order, or
the person who receives the jewellery

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

The beneficiary cannot be the reporting entity.

Person beneficiary

Instructions for the fields under "Person 1 of C completing action Z"
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 or 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	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 1 of N of the person beneficiary C"
Fields	Instructions
Identifier type	Refer to Identification fields under "Standardized field instructions".
† If "Other", please specify	If "Other" identifier type is selected, you must specify the identifier type.
Number associated with identifier type	Same instructions (Identification fields)
Jurisdiction of issue (country)	Same instructions (Identification fields)
Jurisdiction of issue (province or state)	Same instructions (Identification fields)

Identification of the entity beneficiary

Instructions for the fields under "Entity 1 of C of completing action Z"
Fields	Instructions
† Name of entity	Refer to Identification fields under "Standardized field instructions".
Username	A username is how a person or 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	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 incorporated or registered?	This field is a "Yes/No" question.

Incorporation of the entity

Instructions for the fields under "Incorporation 1 of N of entity beneficiary A"
Fields	Instructions
Incorporation number	Provide the incorporation number of the entity conducting the transaction for each jurisdiction where the entity is incorporated.
Jurisdiction of issue (country) of incorporation	Provide the jurisdiction of issue (country) of incorporation for each jurisdiction where the entity is incorporated
Jurisdiction of issue (province or state) of incorporation	Provide the jurisdiction of issue (province or state) of incorporation 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. If the jurisdiction is outside Canada, the United States or Mexico, provide the name of the province or state.

Registration of the entity

Instructions for the fields under "Registration 1 of N of entity beneficiary A"
Fields	Instructions
Registration number	Provide the registration number of the entity conducting the transaction for each jurisdiction where the entity is registered For Canadian entities, a registration number can include the 9-digit business number assigned to that entity by the Canada Revenue Agency (CRA).
Jurisdiction of issue (country) of registration	Provide the country that issued the documentation used to identify the entity for each jurisdiction where the entity is registered.
Jurisdiction of issue (province or state) of registration	Provide the jurisdiction of issue (province or state) 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. If the jurisdiction is outside Canada, the United States or Mexico, provide the name of the province or state.

Identification of the entity

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 1 of N of entity beneficiary C"
Fields	Instructions
Identifier type	Refer to Identification fields under "Standardized field instructions".
† If "Other", please specify	If "Other" is selected, you must specify the identifier type.
Number associated with identifier type	Same instructions (Identification fields)
Jurisdiction of issue (country)	Same instructions (Identification fields)
Jurisdiction of issue (province or state)	Same instructions (Identification fields)

Instructions for the fields under "Person authorized to bind the entity beneficiary or act with respect to the account (maximum 3)"
Fields	Instructions
Surname	Refer to Name fields under "Standardized field instructions".
Given name	Same instructions (Name fields)
Other/Initial	Same instructions (Name fields)

Details of suspicion

Note: The "Details of suspicion" section of the Suspicious Transaction Report form must not be completed if the transaction is being reported to FINTRAC under a Ministerial Directive.

*Description of suspicious activity

This section is the narrative that explains your grounds for suspicion that led to your decision to submit a Suspicious Transaction Report to FINTRAC.

You must describe in clear, simple and concise language your grounds for suspicion of a money laundering or terrorist financing offence – including the facts, context, and indicators that allowed you to reach reasonable grounds for suspicion.

The narrative should:

not assume that the reader will be familiar with acronyms or terminology specific to your business.
focus on the question: "Why do you think the transaction is suspicious of money laundering or terrorist financing?"
not refer to any internal files or documents since FINTRAC cannot have access to these internal files or documents for its analysis.
not include graphics, underlined, italicized or bolded text since they cannot be viewed in the Suspicious Transaction Report form
be consistent with the information in the structured fields of the Suspicious Transaction Report form
- For example, if you are referring to specific account activity in this section, the details of those accounts and transactions should be entered in the structured fields.

Detailed and high quality Suspicious Transaction Reports provide valuable and actionable intelligence for FINTRAC and this section is shared with law enforcement and intelligence agencies in FINTRAC disclosures.

Instructions for the fields under "details of suspicion"

Fields	Instructions
Suspicion type	Select: money laundering terrorist financing money laundering and terrorist financing sanctions evasion money laundering and sanctions evasion terrorist financing and sanctions evasion money laundering, terrorist financing and sanctions evasion If your primary suspicion type is sanctions evasion, and you do not have the system capability at this time to select the new sanctions evasion option, you must select “money laundering” as suspicion type from the drop down list and add #SANCTIONS as part of the grounds for suspicion in the Description of suspicious activity section.
Public-Private partnership name	Select the public-private partnership project name that the Suspicious Transaction Report is associated with, if applicable.
Does this report include information about an individual you have determined to be a politically exposed person (PEP)?	This field is a "Yes/No" question.

Related Reports

Are there previously submitted reports that may relate to the suspicious activity mentioned in this report?

Instructions for the fields under "Report 1 of X"
Fields	Instructions
Reporting entity report reference number (1 of N)	Provide the reporting entity report reference number(s) of the previously submitted report(s) that may relate to the suspicious activity mentioned in this Suspicious Transaction Report.
Reporting entity transaction reference number (1 of Z of report N)	Provide the reporting entity transaction reference number(s) of the previously submitted report(s) that may relate to the suspicious activity mentioned in this Suspicious Transaction Report.

Action taken

Note: The "Action taken" section of the Suspicious Transaction Report form must not be completed if the transaction is being reported to FINTRAC under a Ministerial Directive.

* Description of action taken

Describe the action(s) that you have taken or will be taking as a result of the suspicious transaction(s).

The following are examples of actions taken:

reporting the information directly to law enforcement;
initiating enhanced transaction monitoring;
closing the account(s) in question or exiting the business relationship; and/or
cancelling, reversing or rejecting the transaction.

Reporting a Suspicious Transaction Report to FINTRAC does not prevent you from contacting law enforcement directly.

However, even if you do contact law enforcement directly about your suspicions of money laundering or terrorist financing, you must still submit a Suspicious Transaction Report to FINTRAC.

Some Suspicious Transaction Reports have included the law enforcement agency's contact information in this part of the Suspicious Transaction Report when the suspicion was also reported directly to law enforcement and this information can be helpful.

Annex B - Scenarios

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

Notes about these scenarios

Specific money laundering and terrorist financing indicators and a full narrative of the reasonable grounds to suspect has not been provided.
- For information on reasonable grounds to suspect and indicators for your sector, refer to 4. When to submit a Suspicious Transaction Report above, and the money laundering and terrorist financing indicators under All FINTRAC guidance – Transaction reporting.
- Not all fields of the Suspicious Transaction Report form are displayed—only fields with completed information are displayed.
Not all fields of the Suspicious Transaction Report form are displayed.
Only fields with completed information are displayed.
Some fields have been combined for the purpose of brevity. For example, conductor name, address, telephone number and other conductor fields have been combined as conductor information.
Because some fields are mandatory and some are not, it has been assumed that the reporting entity had the information if a field has been completed.

In this annex

Scenario B.1: Person deposits cheque and sends an email money transfer (EMT)
Scenario B.2: Entity exchanges cash to virtual currency and transfers to wallet
Scenario B.3: Person deposits on behalf of another person who later purchases casino chips and then redeems these chips
Scenario B.4: Person transfers funds between accounts and pays utility bill and credit card

Scenario B.1: Person deposits cheque and sends an email money transfer (EMT)

On July 6, 2022, Gordie Gold deposited a $1,500 cheque from Iron Construction Ltd. into a joint account (with Gemma Gold) at Moon Rays Financial by using his access card at an automated teller machine (ATM).
- The cheque, which was payable to Gordie Gold, included the following memo line: Pay cheque—Job # 5.
On the same evening, Gordie logged into online banking using his access card and sent an email money transfer (EMT) in the amount of $2,500 from his joint account with Gemma to Sunny Silver's account at Solar Bank.
- Sunny is not a client of Moon Rays Financial.
- The EMT message indicates the following: July 2022 rent.
Moon Rays Financial is submitting the following Suspicious Transaction Report as it identified multiple indicators and determined that there are reasonable grounds to suspect the transactions are related to the commission of a money laundering offence.

Expected field information in the report

General information – Scenario B.1

General information about Moon Rays Financial
Fields	Information provided by Moon Rays Financial
Reporting entity number	The reporting entity number assigned to Moon Rays Financial when it enrolled with FINTRAC Web Reporting System (FWR)
Reporting entity report reference number	The unique number for this report that was assigned by: Moon Rays Financial, or its service provider
Activity sector	Bank
Contact information for this report	Information about the person at Moon Rays Financial that FINTRAC can liaise with in the event that a follow up is required

Transaction information – Scenario B.1

"Transaction information" provided by Moon Rays Financial
Fields	Information provided for transaction 1 of 2	Information provided for transaction 2 of 2
Transaction Status	Completed	Completed
Date of transaction	The date the cheque was deposited at Moon Rays Financial (July, 6, 2022)	The date the online transaction was conducted (July 6, 2022)
Time of transaction	The time the cheque was deposited at Moon Rays Financial	The time the online transaction was conducted on July 6, 2022
Method of transaction	Automated teller machine (ATM)	Online
Reporting entity transaction reference number	The unique number for this transaction that was assigned by: Moon Rays Financial Bank, or its service provider	The unique number for this transaction that was assigned by: Moon Rays Financial, or its service provider
Reporting entity location number	Information about where the transaction took place (ATM location)	Information about where the transaction took place -specifically, the location number that is associated with the location that receives and initiates the client’s online instructions

Starting action – Scenario B.1

"Starting action" information provided by Moon Rays Financial
Fields	Information provided for starting action 1 of transaction 1	Information provided for starting action 1 of transaction 2
Direction of starting action	In	Out
Type of funds, assets or virtual currency (in/out)	Cheque	Funds withdrawal
Amount	1,500	2,500
Currency	CAD	CAD
Financial Institution and branch number	The financial institution and branch number which issued the cheque	The financial institution and branch number for Moon Rays Financial
Account number	The account number indicated on the cheque	The account number for the joint account of Gordie and Gemma Gold at Moon Rays Financial
Was information about the source (person/entity) of funds or virtual currency obtained?	No	No
Account holder	Iron Construction Ltd. (as indicated on the cheque)	Gordie and Gemma Gold
Conductor information	Information that Moon Rays Financial has on Gordie Gold which may include: name alias client number address telephone number email address URL date of birth country of residence country of citizenship occupation name and address of employer, and identification details	Information that Moon Rays Financial has on Gordie Gold which may include: name alias client number address telephone number email address URL date of birth country of residence country of citizenship occupation name and address of employer, and identification details
Information about conducting or attempting to conduct the transaction online	[Field left blank because not applicable]	Information including: type of device used username device identifier number internet protocol address date and time of online session in which request was made
Was this transaction conducted or attempted on behalf of another person or entity?	No	No

Completing action – Scenario B.1

"Completing action" information provided by Moon Rays Financial
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	Outgoing email money transfer (EMT)
Amount	1,500	2,500
Currency	CAD	CAD
Financial institution number and branch number (if available for EMT)	The financial institution and branch number for Moon Rays Financial	The financial institution and branch number for Solar Bank
Account number (if available for EMT)	The account number for the joint account of Gordie and Gemma Gold at Moon Rays Financial	The account number of Sunny Silver at Solar Bank
Account holder (if available for EMT)	Gordie and Gemma Gold	Sunny Silver
Was there any other person or entity involved in the completing action?	No	No
Beneficiary information	Information that Moon Rays Financial has on Gordie and Gemma Gold as they are the account holders on the joint account in which the cheque was deposited. This may include; name alias username client number address telephone number email address date of birth country of residence occupation name of employer, and identification details	Sunny Silver’s name Also, if obtained, information about Sunny Silver including: name alias client number address telephone number email address date of birth country of residence occupation name of employer, and identification details

Details of suspicion – Scenario B.1

"Details of Suspicion" information provided by Moon Rays Financial
Details of Suspicion
The description of the facts, context and indicators that allowed Moon Rays Financial to establish that there are reasonable grounds to suspect that the transaction(s) are related to the commission of a money laundering offence. In this scenario, this could include the information from the cheque memo line (Pay cheque—Job # 5) and the EMT message (July 2022 rent).

Details of action taken – Scenario B.1

"Details of Action Taken" information provided by Moon Rays Financial
Action Taken
The action that Moon Rays Financial has taken as a result of the suspicious transaction(s).

Note:

If the conductor (Gordie Gold) has multiple email addresses, provide the email address that the conductor used to send the EMT in the email address field for the conductor.
Gordie’s other email addresses can be provided in the narrative section of the report (Details of suspicion).
The beneficiary email address field should be the email address that was used by the beneficiary to receive the email money transfer (EMT).

Scenario B.2: Entity exchanges cash to virtual currency and transfers to wallet

On July 7, 2022, Gordie Gold walked into Cosmic Virtual Currency Money Service Business (Cosmic VC MSB) with $9,997 CAD cash.
- Gordie advised Cosmic VC MSB that he is representing Gordie’s Painting Inc. A company in which he is the CEO and sole director and shareholder.
- Gordie also advised Cosmic VC MSB that the cash was payment from a recently sold painting to a client, Sunny Silver.
- Gordie requested that the cash be exchanged to Ethereum (ETH) so that it could be added to Cosmic VC MSB’s custodial virtual currency wallet. The virtual currency exchange rate was 0.0007.
- Gordie then requested the ETH be transferred to his personal external virtual currency wallet.

Cosmic VC MSB is submitting this Suspicious Transaction Report as it identified multiple indicators and determined that there are reasonable grounds to suspect the transaction is related to the commission of a money laundering offence.

Expected field information in the report

General information – Scenario B.2

General information about Cosmic VC MSB
Fields	Information provided by Cosmic VC MSB
Reporting entity number	The reporting entity number assigned to Cosmic VC MSB when it enrolled with FINTRAC Web Reporting System (FWR)
Reporting entity report reference number	The unique number for this report that was assigned by: Cosmic VC MSB, or its service provider
Activity sector	Money services business
Contact information for this report	Information about the person at Cosmic VC MSB that FINTRAC can liaise with in the event that a follow up is required

Transaction information – Scenario B.2

"Transaction information" provided by Cosmic VC MSB
Fields	Information provided for transaction 1 of 1
Transaction Status	Completed
Date of transaction	The date the cash was received by Cosmic VC MSB (July, 7, 2022)
Time of transaction	The time the cash was received by Cosmic VC MSB on July 7, 2022
Method of transaction	In person
Reporting entity transaction reference number	The unique number for this transaction that was assigned by: Cosmic VC MSB, or its service provider
Reporting entity location number	Information about where the transaction took place

Starting action – Scenario B.2

"Starting action" information provided by Cosmic VC MSB
Fields	Information provided for starting action 1 of transaction 1
Direction of starting action	In
Type of funds, assets or virtual currency (in/out)	Cash
Amount	9,997
Currency	CAD
How were the funds or virtual currency obtained?	Gordie Gold advised that he received the cash when he sold a painting to his client, Sunny Silver
Was information about the source (person/entity) of funds or virtual currency obtained?	Yes
Source of funds or virtual currency	Sunny Silver
Conductor information	Information that Cosmic VC MSB has on Gordie’s Painting Inc. which may include: name alias client number address telephone number email address URL, and identification details
Additional information about the conductor if it is an entity	Person(s) authorized to bind the entity (Gordie Gold), Type of entity (corporation) Nature of entity’s principal business (painting/contracting) Incorporation and/or registration information Director(s) of the corporation (Gordie Gold) Person(s) who directly or indirectly owns or controls 25% or more shares of the corporation (Gordie Gold)
Was this transaction conducted or attempted on behalf of another person or entity?	No

Completing action – Scenario B.2

"Completing action" information provided by Cosmic VC MSB
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	Exchange to virtual currency	Added to virtual currency wallet	Outgoing virtual currency transfer
Amount	7	7	7
Virtual Currency type	ETH	ETH	ETH
Exchange rate	.0007	[Field left blank because not applicable]	[Field left blank because not applicable]
Virtual Currency transaction identifier	[Field left blank because not applicable]	The unique identifier for this transaction (completing action 2) that is commonly represented by a hash consisting of mixed numerical and alphabetical characters	The unique identifier for this transaction (completing action 3) that is commonly represented by a hash consisting of mixed numerical and alphabetical characters
Receiving Virtual currency address	[Field left blank because not applicable]	The virtual currency address for Cosmic VC MSB as it received the virtual currency	The virtual currency address for Gordie Gold as he received the virtual currency in his personal wallet
Was there any other person or entity involved in the completing action?	No	No	No
Beneficiary information	Information that Cosmic VC MSB has on Gordie’s Painting Inc. which may include: name username client number address telephone number email address nature of entity’s principal business (painting/ contracting) incorporation and/or registration information identification details, and person(s) authorized to bind the entity (Gordie Gold)	Information that Cosmic VC MSB has on Gordie’s Painting which may include: name username client number address telephone number email address nature of entity’s principal business (painting/ contracting) incorporation and/or registration information identification details, and person(s) authorized to bind the entity (Gordie Gold)	Information that Cosmic VC MSB has on Gordie Gold which may include: name alias username client number address telephone number email address date of birth country of residence occupation, name of employer, and identification details

Details of suspicion – Scenario B.2

"Details of Suspicion" information provided by Cosmic VC MSB
Details of Suspicion
The description of the facts, context and indicators that allowed Cosmic VC MSB to establish that there are reasonable grounds to suspect that the transaction(s) is/are related to the commission of a money laundering offence.

Details of action taken – Scenario B.2

"Details of Action Taken" information provided by Cosmic VC MSB
Action Taken
The action that Cosmic VC MSB has taken because of the suspicious transaction(s).

Scenario B.3: Person deposits on behalf of another person who later purchases casino chips and then redeems these chips

On July 8th, 2022, Gordie Gold came into Vega Casino to deposit $9,000 cash on behalf of Sunny Silver.
- The cash was deposited into Sunny’s account and Gordie advised the casino that he and Sunny were friends.
- The casino was not able to obtain information about the purpose of the transaction or the source of funds.
On July 9th, 2022, Sunny purchased casino chips at Vega Casino using funds in her casino account totaling $9,000.
- After leaving the front desk, Sunny was seen passing the chips to Chuck who is an individual known to the casino.
- Within an hour, Sunny returned to the front desk to redeem the remaining casino chips and requested a cheque payable to herself totaling $5,000.
Vega Casino is submitting this Suspicious Transaction Report as it identified multiple indicators and determined that there are reasonable grounds to suspect the transactions are related to the commission of a money laundering offence.

Expected field information in the report

General information – Scenario B.3

General information about Vega Casino
Fields	Information provided by Vega Casino
Reporting entity number	The reporting entity number assigned to Vega Casino when it enrolled with FINTRAC Web Reporting System (FWR)
Reporting entity report reference number	The unique number for this report that was assigned by: Vega Casino, or its service provider
Activity sector	Casino
Contact information for this report	Information about the person at Vega Casino that FINTRAC can liaise with in the event that a follow up is required

Transaction information – Scenario B.3

Fields	Information provided for transaction 1 of 3	Information provided for transaction 2 of 3	Information provided for transaction 3 of 3
Transaction Status	Completed	Completed	Completed
Date of transaction	The date Vega Casino received the cash from Gordie Gold (July 8, 2022)	The date casino chips were purchased (July 9, 2022)	The date casino chips were redeemed (July 9, 2022)
Time of transaction	The time Vega Casino received the cash on July 8, 2022	The time the casino chips were purchased on July 9, 2022	The time the casino chips were redeemed on July 9, 2022
Method of transaction	In person	In person	In person
Reporting entity transaction reference number	The unique number for this transaction that was assigned by: Vega Casino, or its service provider	The unique number for this transaction that was assigned by: Vega Casino, or its service provider	The unique number for this transaction that was assigned by: Vega Casino, or its service provider
Reporting entity location number	Information about where the transaction took place	Information about where the transaction took place	Information about where the transaction took place

Starting action – Scenario B.3

Fields	Information provided for starting action 1 of transaction 1	Information provided for starting action 1 of transaction 2	Information provided for starting action 1 of transaction 3
Direction of starting action	In	Out	In
Type of funds, assets or virtual currency (in/out)	Cash	Funds withdrawal	Casino product
Amount	9,000	9,000	5,000
Currency	CAD	CAD	CAD
Account number	[Field left blank because not applicable]	Sunny Silver’s account number at Vega Casino	[Field left blank because not applicable]
Was information about the source (person /entity) of funds or virtual currency obtained?	No	No	No
Account holder	[Field left blank because not applicable]	Sunny Silver	[Field left blank because not applicable]
Conductor information	Information that Vega Casino has on Gordie Gold which may include: name alias client number address telephone number email address URL date of birth country of residence country of citizenship occupation name and address of employer, and identification details	Information that Vega Casino has on Sunny Silver which may include: name alias client number address telephone number email address URL date of birth country of residence country of citizenship occupation name and address of employer, and identification details	Information that Vega Casino has on Sunny Silver which may include: name alias client number address telephone number email address URL date of birth country of residence country of citizenship occupation name and address of employer, and identification details
Was this transaction conducted or attempted on behalf of another person or entity?	Yes	No	No
Relationship of the person named above to the person or entity conducting or attempting to conduct the transaction	Friend	[Field left blank because not applicable]	[Field left blank because not applicable]

Scenario B.4: Person transfers funds between accounts and pays utility bill and credit card

On July 9th, 2022, Gordie Gold logged into online banking at Moon Rays Financial using his access card and does the following:
- transfers $1,500 from his joint account with Gemma Gold to his own personal account—and both accounts are held at Moon Rays Financial
- pays an electric bill to ABC Electric Company (billing account reference number 12345-678) for $500 using funds from his own personal account, and
- pays a credit card account balance of $1,000 to ABC Credit Card Company (credit card number 1234-5678-1234-5678) using funds from his personal account.
Moon Rays Financial is submitting this Suspicious Transaction Report as it identified multiple indicators and determined that there are reasonable grounds to suspect the transactions are related to the commission of a money laundering offence.

Expected field information in the report

General information – Scenario B.4

General information about Moon Rays Financial
Fields	Information provided by Moon Rays Financial
Reporting entity number	The reporting entity number assigned to Moon Rays Financial when it enrolled with FINTRAC Web Reporting System (FWR)
Reporting entity report reference number	The unique number for this report that was assigned by: Moon Rays Financial, or its service provider
Activity sector	Bank
Contact information for this report	Information about the person at Moon Rays Financial that FINTRAC can liaise with in the event that a follow up is required

Transaction information – Scenario B.4

Fields	Information provided for transaction 1 of 3	Information provided for transaction 2 of 3	Information provided for transaction 3 of 3
Transaction Status	Completed	Completed	Completed
Date of transaction	The date the online transaction was conducted (July 9, 2022)	The date the online transaction was conducted (July 9, 2022)	The date the online transaction was conducted (July 9, 2022)
Time of transaction	The time the online transaction was conducted on July 9, 2022	The time the online transaction was conducted on July 9, 2022	The time the online transaction was conducted on July 9, 2022
Method of transaction	Online	Online	Online
Reporting entity transaction reference number	The unique number for this transaction that was assigned by: Moon Rays Financial, or its service provider	The unique number for this transaction that was assigned by: Moon Rays Financial, or its service provider	The unique number for this transaction that was assigned by: Moon Rays Financial, or its service provider
Reporting entity location number	Information about where the transaction took place – specifically the location number that is associated with the location that receives and initiates the client’s online instructions	Information about where the transaction took place – specifically the location number that is associated with the location that receives and initiates the client’s online instructions	Information about where the transaction took place – specifically the location number that is associated with the location that receives and initiates the client’s online instructions

Starting action – Scenario B.4

Fields	Information provided for starting action 1 of transaction 1	Information provided for starting action 1 of transaction 2	Information provided for starting action 1 of transaction 3
Direction of starting action	Out	Out	Out
Type of funds, assets or virtual currency (in/out)	Funds withdrawal	Funds withdrawal	Funds withdrawal
Amount	1,500	500	1,000
Currency	CAD	CAD	CAD
Financial institution and branch number	The financial institution and branch number for Moon Rays Financial	The financial institution and branch number for Moon Rays Financial	The financial institution and branch number for Moon Rays Financial
Account number	The account number for the joint account of Gordie and Gemma Gold at Moon Rays Financial	The account number for Gordie Gold’s personal account at Moon Rays Financial	The account number for Gordie Gold’s personal account at Moon Rays Financial
Was information about the source (person /entity) of funds or virtual currency obtained?	No	No	No
Account holder	Gordie and Gemma Gold	Gordie Gold	Gordie Gold
Conductor information	Information that Moon Rays Financial has on Gordie Gold which may include: name alias client number address telephone number email address URL date of birth country of residence country of citizenship occupation name and address of employer, and identification details	Information that Moon Rays Financial has on Gordie Gold which may include: name alias client number address telephone number email address URL date of birth country of residence country of citizenship occupation name and address of employer, and identification details	Information that Moon Rays Financial has on Gordie Gold which may include: name alias client number address telephone number email address URL date of birth country of residence country of citizenship occupation name and address of employer, and identification details
Information about conducting or attempting to conduct the transaction online	Information including: type of device used username device identifier number internet protocol address date and time of online session	Information including: type of device used username device identifier number internet protocol address date and time of online session	Information including: type of device used username device identifier number internet protocol address date and time of online session in which the request was made
Was this transaction conducted or attempted on behalf of another person or entity?	No	No	No

Completing action – Scenario B.4

"Completing action" information provided by Moon Rays Financial
Fields	Information provided for completing action 1 of transaction 1	Information provided for completing action 1 of transaction 2	Information provided for completing action 1 of transaction 2
Details of disposition	Outgoing domestic funds transfer	Purchase of /Payment of services	Payment to account
Amount	1,500	500	1,000
Currency	CAD	CAD	CAD
Reference number	[Field left blank because not applicable]	12345-678 (the reference number associated with the bill payment)	[Field left blank because not applicable]
Financial institution and branch number	The financial institution and branch number which sent the outgoing domestic funds transfer	[Field left blank because not applicable]	[Field left blank because not applicable]
Account number	The account number for the personal account of Gordie Gold at Moon Rays Financial	[Field left blank because not applicable]	1234-5678-1234-5678 (the credit card account in which payment was made)
Account holder	Gordie Gold	[Field left blank because not applicable]	[Field left blank because not applicable]
Was there any other person or entity involved in the completing action?	No	No	No
Beneficiary information	Information that Moon Rays Financial has on Gordie Gold. This may include; name alias username client number address telephone number email address date of birth country of residence occupation name of employer, and identification details	Information that Moon Rays Financial has on ABC Electric Company. This may include: name username client number address telephone number email address nature of entity’s principal business (utility) incorporation and/or registration information identification details, and person(s) authorized to bind the entity	Information that Moon Rays Financial has on ABC Credit Card Company. This may include: name username client number address telephone number email address nature of entity’s principal business (credit card company) incorporation and/or registration information identification details, and person(s) authorized to bind the entity

Details of suspicion – Scenario B.4

"Details of Suspicion" information provided by Moon Rays Financial
Details of Suspicion
The description of the facts, context and indicators that allowed Moon Rays Financial to establish that there are reasonable grounds to suspect that the transaction(s) are related to the commission of a money laundering offence.

Details of action taken – Scenario B.4

"Details of Action Taken" information provided by Moon Rays Financial
Action Taken
The action that Moon Rays Financial has taken as a result of the suspicious transaction(s).

For Assistance

If you have questions on your suspicious transaction reporting requirements, please contact FINTRAC by email at guidelines-lignesdirectrices@fintrac-canafe.gc.ca

Definitions

Accountant

A chartered accountant, a certified general accountant, a certified management accountant or, if applicable, a chartered professional accountant. (comptable)

Reference:
Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), SOR/2002-184, s. 1(2).

Accounting firm

An entity that is engaged in the business of providing accounting services to the public and has at least one partner, employee or administrator that is an accountant. (cabinet d'expertise comptable)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Act

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). (la Loi)

Reference:
Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations (PCMLTFAMPR), SOR/2007-292, s. 1, Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations (PCMLTFRR), SOR/2007-121, s. 1, PCMLTFR, SOR/2002-184, s. 1(2), and Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations (PCMLTFSTRR), SOR/2001-317, s. 1(2).

Administrative monetary penalties (AMPs)

Civil penalties that may be issued to reporting entities by FINTRAC for non-compliance with the PCMLTFA and associated Regulations. (pénalité administrative pécuniaire [PAP])

Affiliate

An entity is affiliated with another entity if one of them is wholly owned by the other, if both are wholly owned by the same entity or if their financial statements are consolidated. (entité du même groupe)

Reference:
PCMLTFR, SOR/2002-184, s. 4.

Annuity

Has the same meaning as in subsection 248(1) of the Income Tax Act. (rente)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Armoured cars

Persons or entities that are engaged in the business of transporting currency, money orders, traveller’s cheques or other similar negotiable instruments. (Véhicules blindés)

As soon as practicable

A time period that falls in-between immediately and as soon as possible, within which a suspicious transaction report (STR) must be submitted to FINTRAC. The completion and submission of the STR should take priority over other tasks. In this context, the report must be completed promptly, taking into account the facts and circumstances of the situation. While some delay is permitted, it must have a reasonable explanation. (aussitôt que possible)

Attempted transaction

Occurs when an individual or entity starts to conduct a transaction that is not completed. For example, a client or a potential client walks away from conducting a $10,000 cash deposit. (opération tentée)

Authentic

In respect of verifying identity, means genuine and having the character of an original, credible, and reliable document or record. (authentique)

Authorized person

A person who is authorized under subsection 45(2). (personne autorisée)

Reference:
Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), S.C. 2000, c 17, s. 2(1).

Authorized user

A person who is authorized by a holder of a prepaid payment product account to have electronic access to funds or virtual currency available in the account by means of a prepaid payment product that is connected to it. (utilisateur autorisé)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Beneficial owner(s)

Beneficial owners are the individuals who are the trustees, and known beneficiaries and settlors of a trust, or who directly or indirectly own or control 25% or more of i) the shares of a corporation or ii) an entity other than a corporation or trust, such as a partnership. The ultimate beneficial owner(s) cannot be another corporation or entity; it must be the actual individual(s) who owns or controls the entity. (bénéficiaire effectif)

Beneficiary

A beneficiary is the individual or entity that will benefit from a transaction or to which the final remittance is made. (bénéficiaire)

Branch

A branch is a part of your business at a distinct location other than your main office. (succursale)

British Columbia notary corporation

An entity that carries on the business of providing notary services to the public in British Columbia in accordance with the Notaries Act, R.S.B.C. 1996, c. 334. (société de notaires de la Colombie-Britannique)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

British Columbia notary public

A person who is a member of the Society of Notaries Public of British Columbia. (notaire public de la Colombie-Britannique)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Cash

Coins referred to in section 7 of the Currency Act, notes issued by the Bank of Canada under the Bank of Canada Act that are intended for circulation in Canada or coins or bank notes of countries other than Canada. (espèces)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2).

Casino

A government, organization, board or operator that is referred to in any of paragraphs 5(k) to (k.3) of the Act. (casino)

Reference:
PCMLTFR, SOR/2002-184, s 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2).

Certified translator

An individual that holds the title of professional certified translator granted by a Canadian provincial or territorial association or body that is competent under Canadian provincial or territorial law to issue such certification. (traducteur agréé)

Clarification request

A clarification request is a method used to communicate with money services businesses (MSBs) or foreign money services businesses (FMSBs) when FINTRAC needs more information about their registration form. This request is usually sent by email. (demande de précisions)

Client

A person or entity that engages in a financial transaction with another person or entity. (client)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Client identification information

The identifying information that you have obtained on your clients, such as name, address, telephone number, occupation or nature of principal business, and date of birth for an individual. (renseignements d'identification du client)

Competent authority

For the purpose of the criminal record check submitted with an application for registration, a competent authority is any person or organization that has the legally delegated or invested authority, capacity, or power to issue criminal record checks. (autorité compétente)

Completed transaction

Is a transaction conducted by a person or entity, that is completed and results in the movement of funds, virtual currency, or the purchase or sale of an asset. (opération effectuée)

Completing action

With respect to a reportable transaction, information related to the instructions provided by the person or entity making the request to the reporting entity to complete a transaction. For example, an individual arrives at a bank and requests to purchase a bank draft. The completing action is the details of how the reporting entity fulfilled the person or entity’s instructions which led to the transaction being completed. This includes what the funds or virtual currency initially brought to the reporting entity was used for (see “disposition”). A transaction may have one or more completing actions depending on the instructions provided by the person or entity. (action d’achèvement)

Compliance officer

The individual, with the necessary authority, that you appoint to be responsible for the implementation of your compliance program. (agent de conformité)

Compliance policies and procedures

Written methodology outlining the obligations applicable to your business under the PCMLTFA and its associated Regulations and the corresponding processes and controls you put in place to address your obligations. (politiques et procédures de conformité)

Compliance program

All elements (compliance officer, policies and procedures, risk assessment, training program, effectiveness review) that you, as a reporting entity, are legally required to have under the PCMLTFA and its associated Regulations to ensure that you meet all your obligations. (programme de conformité)

Context

Clarifies a set of circumstances or provides an explanation of a situation or financial transaction that can be understood and assessed. (contexte)

Correspondent banking relationship

A relationship created by an agreement or arrangement under which an entity referred to in any of paragraphs 5(a), (b), (d),(e) and (e.1) or an entity that is referred to in section 5 and that is prescribed undertakes to provide to a prescribed foreign entity prescribed services or international electronic funds transfers, cash management or cheque clearing services. (relation de correspondant bancaire)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 9.4(3) and PCMLTFR, SOR/2002-184, s. 16(1)(b).

Country of residence

The country where an individual has lived continuously for 12 months or more. The individual must have a dwelling in the country concerned. For greater certainty, a person only has one country of residence no matter how many dwelling places they may have, inside or outside of that country. (pays de résidence)

Credit card acquiring business

A credit card acquiring business is a financial entity that has an agreement with a merchant to provide the following services:

enabling a merchant to accept credit card payments by cardholders for goods and services and to receive payments for credit card purchases;
processing services, payment settlements and providing point-of-sale equipment (such as computer terminals); and
providing other ancillary services to the merchant.

(entreprise d'acquisition de cartes de crédit)

Credit union central

A central cooperative credit society, as defined in section 2 of the Cooperative Credit Associations Act, or a credit union central or a federation of credit unions or caisses populaires that is regulated by a provincial Act other than one enacted by the legislature of Quebec. (centrale de caisses de crédit)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Crowdfunding platform

A website or an application or other software that is used to raise funds or virtual currency through donations. (plateforme de sociofinancement)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Crowdfunding platform services

The provision and maintenance of a crowdfunding platform for use by other persons or entities to raise funds or virtual currency for themselves or for persons or entities specified by them. (services de plateforme de sociofinancement)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Current

In respect of a document or source of information that is used to verify identity, is up to date, and, in the case of a government-issued photo identification document, must not have been expired when the ID was verified. (à jour)

Dealer in precious metals and stones

A person or entity that, in the course of their business activities, buys or sells precious metals, precious stones or jewellery. It includes a department or an agent of His Majesty in right of Canada or an agent or mandatary of His Majesty in right of a province when the department or the agent or mandatary carries out the activity, referred to in subsection 65(1), of selling precious metals to the public. (négociant en métaux précieux et pierres précieuses)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Deferred profit sharing plan

Has the same meaning as in subsection 248(1) of the Income Tax Act. (régime de participation différée aux bénéfices)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Deposit slip

A record that sets out:

(a) the date of the deposit;
(b) the name of the person or entity that makes the deposit;
(c) the amount of the deposit and of any part of it that is made in cash;
(d) the method by which the deposit is made; and
(e) the number of the account into which the deposit is made and the name of each account holder.

(relevé de dépôt)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Directing services

A business is directing services at persons or entities in Canada if at least one of the following applies:

The business's marketing or advertising is directed at persons or entities located in Canada;
The business operates a ".ca" domain name; or,
The business is listed in a Canadian business directory.

Additional criteria may be considered, such as if the business describes its services being offered in Canada or actively seeks feedback from persons or entities in Canada. (diriger des services)

Distributed ledger

For the purpose of section 151 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), a digital ledger that is maintained by multiple persons or entities and that can only be modified by a consensus of those persons or entities. (registres distribués)

Reference:
PCMLTFR, SOR/2002-184, s. 151(2).

Disposition

With respect to a reportable transaction, the disposition is what the funds or virtual currency was used for. For example, an individual arrives at a bank with cash and purchases a bank draft. The disposition is the purchase of the bank draft. (répartition)

Electronic funds transfer

The transmission—by any electronic, magnetic or optical means—of instructions for the transfer of funds, including a transmission of instructions that is initiated and finally received by the same person or entity. In the case of SWIFT messages, only SWIFT MT-103 messages and their equivalent are included. It does not include a transmission or instructions for the transfer of funds:

(a) that involves the beneficiary withdrawing cash from their account;
(b) that is carried out by means of a direct deposit or pre-authorized debit;
(c) that is carried out by cheque imaging and presentment
(d) that is both initiated and finally received by persons or entities that are acting to clear or settle payment obligations between themselves; or
(e) that is initiated or finally received by a person or entity referred to in paragraphs 5(a) to (h.1) of the Act for the purpose of internal treasury management, including the management of their financial assets and liabilities, if one of the parties to the transaction is a subsidiary of the other or if they are subsidiaries of the same corporation.

(télévirement)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Employees profit sharing plan

Has the same meaning as in subsection 248(1) of the Income Tax Act. (régime de participation des employés aux bénéfices)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Entity

A body corporate, a trust, a partnership, a fund or an unincorporated association or organization. (entité)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Facts

Actual events, actions, occurrences or elements that exist or are known to have happened or existed. Facts are not opinions. For example, facts surrounding a transaction or multiple transactions could include the date, time, location, amount or type of transaction or could include the account details, particular business lines, or the client's financial history. (faits)

Family member

For the purposes of subsection 9.3(1) of the Act, a prescribed family member of a politically exposed foreign person, a politically exposed domestic person or a head of an international organization is:

(a) their spouse or common-law partner;
(b) their child;
(c) their mother or father;
(d) the mother or father of their spouse or common-law partner; or
(e) a child of their mother or father.

(membre de la famille)

Reference:
PCMLTFR, SOR/2002-184, s. 2(1).

Fiat currency

A currency that is issued by a country and is designated as legal tender in that country. (monnaie fiduciaire)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2).

Final receipt

In respect of an electronic funds transfer, means the receipt of the instructions by the person or entity that is to make the remittance to a beneficiary. (destinataire)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Financial entity

Means:

(a) an entity that is referred to in any of paragraphs 5(a), (b) and (d) to (f) of the Act;
(b) a financial services cooperative;
(c) a life insurance company, or an entity that is a life insurance broker or agent, in respect of loans or prepaid payment products that it offers to the public and accounts that it maintains with respect to those loans or prepaid payment products, other than:
1. (i) loans that are made by the insurer to a policy holder if the insured person has a terminal illness that significantly reduces their life expectancy and the loan is secured by the value of an insurance policy;
2. (ii) loans that are made by the insurer to the policy holder for the sole purpose of funding the life insurance policy; and
3. (iii) advance payments to which the policy holder is entitles that are made to them by the insurer;
(d) a credit union central when it offers financial services to a person, or to an entity that is not a member of that credit union central; and
(e) a department, or an entity that is an agent of His Majesty in right of Canada or an agent or mandatary of His Majesty in right of a province, when it carries out an activity referred to in section 76.

(entité financière)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Financial Action Task Force

The Financial Action Task Force on Money Laundering established in 1989. (Groupe d'action financière)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Financial services cooperative

A financial services cooperative that is regulated by an Act respecting financial services cooperatives, CQLR, c. C-67.3 or the Act respecting the Mouvement Desjardins, S.Q. 2000, c. 77, other than a caisse populaire. (coopérative de services financiers)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Foreign currency

A fiat currency that is issued by a country other than Canada. (devise)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Foreign currency exchange transaction

An exchange, at the request of another person or entity, of one fiat currency for another. (opération de change en devise)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Foreign currency exchange transaction ticket

A record respecting a foreign currency exchange transaction—including an entry in a transaction register—that sets out:

(a) the date of the transaction;
(b) in the case of a transaction of $3,000 or more, the name and address of the person or entity that requests the exchange, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
(c) the type and amount of each of the fiat currencies involved in the payment made and received by the person or entity that requests the exchange;
(d) the method by which the payment is made and received;
(e) the exchange rates used and their source;
(f) the number of every account that is affected by the transaction, the type of account and the name of each account holder; and
(g) every reference number that is connected to the transaction and has a function equivalent to that of an account number.

(fiche d'opération de change en devise)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Foreign money services business

Persons and entities that do not have a place of business in Canada, that are engaged in the business of providing at least one of the following services that is directed at persons or entities in Canada, and that provide those services to their clients in Canada:

(i) foreign exchange dealing,
(ii) remitting funds or transmitting funds by any means or through any person, entity or electronic funds transfer network,
(iii) issuing or redeeming money orders, traveller's cheques or other similar negotiable instruments except for cheques payable to a named person or entity,
(iv) dealing in virtual currencies, or
(v) any prescribed service.

(entreprise de services monétaires étrangère)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 5(h.1), PCMLTFRR, SOR/2007-121, s. 1 and PCMLTFR, SOR/2002-184, s. 1(2).

Foreign state

Except for the purposes of Part 2, means a country other than Canada and includes any political subdivision or territory of a foreign state. (État étranger)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Funds

Means:

(a) cash and other fiat currencies, and securities, negotiable instruments or other financial instruments that indicate a title or right to or interest in them; or
(b) a private key of a cryptographic system that enables a person or entity to have access to a fiat currency other than cash.

For greater certainty, it does not include virtual currency. (fonds)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2).

Head of an international organization

A person who, at a given time, holds—or has held within a prescribed period before that time—the office or position of head of

a) an international organization that is established by the governments of states;
b) an institution of an organization referred to in paragraph (a); or
c) an international sports organization.

(dirigeant d'une organisation internationale)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 9.3(3).

Immediately

In respect of submitting a Terrorist Property Report (TPR), the time period within which a TPR must be submitted, which does not allow for any delay prior to submission. (immédiatement)

Information record

A record that sets out the name and address of a person or entity and:

(a) in the case of a person, their date of birth and the nature of their principal business or their occupation; and
(b) in the case of an entity, the nature of its principal business.

(dossier de renseignements)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Initiation

In respect of an electronic funds transfer, means the first transmission of the instructions for the transfer of funds. (amorcer)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Institutional trust

For the purpose of section 15 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), means a trust that is established by a corporation or other entity for a particular business purpose and includes a pension plan trust, a pension master trust, a supplemental pension plan trust, a mutual fund trust, a pooled fund trust, a registered retirement savings plan trust, a registered retirement income fund trust, a registered education savings plan trust, a group registered retirement savings plan trust, a deferred profit sharing plan trust, an employee profit sharing plan trust, a retirement compensation arrangement trust, an employee savings plan trust, a health and welfare trust, an unemployment benefit plan trust, a foreign insurance company trust, a foreign reinsurance trust, a reinsurance trust, a real estate investment trust, an environmental trust and a trust established in respect of endowment, a foundation or a registered charity. (fiducie institutionnelle)

Reference:
PCMLTFR, SOR/2002-184, s. 15(2).

International electronic funds transfer

An electronic funds transfer other than for the transfer of funds within Canada. (télévirement international)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Inter vivos trust

A personal trust, other than a trust created by will. (fiducie entre vifs)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Jewellery

Objects that are made of gold, silver, palladium, platinum, pearls or precious stones and that are intended to be worn as a personal adornment. (bijou)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Large cash transaction record

A record that indicates the receipt of an amount of $10,000 or more in cash in a single transaction and that contains the following information:

(a) the date of the receipt;
(b) if the amount is received for deposit into an account, the number of the account, the name of each account holder and the time of the deposit or an indication that the deposit is made in a night deposit box outside the recipient's normal business hours;
(c) the name and address of every other person or entity that is involved in the transaction, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
(d) the type and amount of each fiat currency involved in the receipt;
(e) the method by which the cash is received;
(f) if applicable, the exchange rates used and their source;
(g) the number of every other account that is affected by the transaction, the type of account and the name of each account holder
(h) every reference number that is connected to the transaction and has a function equivalent to that of an account number;
(i) the purpose of the transaction;
(j) the following details of the remittance of, or in exchange for, the cash received:
1. (i) the method of remittance;
2. (ii) if the remittance is in funds, the type and amount of each type of funds involved;
3. (iii) if the remittance is not in funds, the type of remittance and its value, if different from the amount of cash received; and
4. (iv) the name of every person or entity involved in the remittance and their account number or policy number or, if they have no account number or policy number, their identifying number; and
(k) if the amount is received by a dealer in precious metals and precious stones for the sale of precious metals, precious stones or jewellery:
1. (i) the type of precious metals, precious stones or jewellery;
2. (ii) the value of the precious metals, precious stones or jewellery, if different from the amount of cash received, and
3. (iii) the wholesale value of the precious metals, precious stones or jewellery.

(relevé d'opération importante en espèces)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Large virtual currency transaction record

A record that indicates the receipt of an amount of $10,000 or more in virtual currency in a single transaction and that contains the following information:

(a) the date of the receipt;
(b) if the amount is received for deposit into an account, the name of each account holder;
(c) the name and address of every other person or entity that is involved in the transaction, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
(d) the type and amount of each virtual currency involved in the receipt;
(e) the exchange rates used and their source;
(f) the number of every other account that is affected by the transaction, the type of account and the name of each account holder;
(g) every reference number that is connected to the transaction and has a function equivalent to that of an account number;
(h) every transaction identifier, including the sending and receiving addresses; and
(i) if the amount is received by a dealer in precious metals and precious stones for the sale of precious metals, precious stones or jewellery:
1. (i) the type of precious metals, precious stones or jewellery;
2. (ii) the value of the precious metals, precious stones or jewellery, if different from the amount of virtual currency received; and
3. (iii) the wholesale value of the precious metals, precious stones or jewellery.

(relevé d'opération importante en monnaie virtuelle)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Life insurance broker or agent

A person or entity that is authorized under provincial legislation to carry on the business of arranging contracts of life insurance. (représentant d'assurance-vie)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Life insurance company

A life company or foreign life company to which the Insurance Companies Act applies or a life insurance company regulated by a provincial Act. (société d'assurance-vie)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Listed person

Has the same meaning as in section 1 of the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism. (personne inscrite)

Reference:
PCMLTFSTRR, SOR/2001-317, s. 1(2).

Managing general agents (MGAs)

Life insurance brokers or agents that act as facilitators between other life insurance brokers or agents and life insurance companies. MGAs typically offer services to assist with insurance agents contracting and commission payments, facilitate the flow of information between insurer and agent, and provide training to, and compliance oversight of, insurance agents. (agent général de gestion)

Mandatary

A person who acts, under a mandate or agreement, for another person or entity. (mandataire)

Marketing or advertising

When a person or entity uses promotional materials such as advertisements, graphics for websites or billboards, etc., with the intent to promote money services business (MSB) services and to acquire business from persons or entities in Canada. (marketing ou publicité)

Minister

In relation to sections 24.1 to 39, the Minister of Public Safety and Emergency Preparedness and, in relation to any other provision of this Act, the Minister of Finance. (ministre)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Money laundering offence

An offence under subsection 462.31(1) of the Criminal Code. The United Nations defines money laundering as "any act or attempted act to disguise the source of money or assets derived from criminal activity." Essentially, money laundering is the process whereby "dirty money"—produced through criminal activity—is transformed into "clean money," the criminal origin of which is difficult to trace. (infraction de recyclage des produits de la criminalité)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Money laundering and terrorist financing indicators (ML/TF indicators)

Potential red flags that could initiate suspicion or indicate that something may be unusual in the absence of a reasonable explanation. [Indicateurs de blanchiment d'argent (BA) et de financement du terrorisme (FT) (indicateurs de BA/FT)]

Money services business

A person or entity that has a place of business in Canada and that is engaged in the business of providing at least one of the following services:

(i) foreign exchange dealing,
(ii) remitting funds or transmitting funds by any means or through any person, entity or electronic funds transfer network,
(iii) issuing or redeeming money orders, traveller's cheques or other similar negotiable instruments except for cheques payable to a named person or entity,
(iv) dealing in virtual currencies, or
(v) any prescribed service.

(entreprise de services monétaires)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 5(h), PCMLTFRR, SOR/2007-121, s. 1 and PCMLTFR, SOR/2002-184, s. 1(2).

Money services business agent

An individual or entity authorized to deliver services on behalf of a money services business (MSB). It is not an MSB branch. (mandataire d'une entreprise de services monétaires)

Mortgage administrator

A person or entity, other than a financial entity, that is engaged in the business of servicing mortgage agreements on real property or hypothec agreements on immovables on behalf of a lender. (administrateur hypothécaire)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 5(i), PCMLTFRR,SOR/2002-184, subsection 1(2)

Mortgage broker

A person or entity that is authorized under provincial legislation to act as an intermediary between a lender and a borrower with respect to loans secured by mortgages on real property or hypothecs on immovables. (courtier hypothécaire)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 5(i), PCMLTFRR,SOR/2002-184, subsection 1(2)

Mortgage lender

A person or entity, other than a financial entity, that is engaged in the business of providing loans secured by mortgages on real property or hypothecs on immovables. (prêteur hypothécaire)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 5(i), PCMLTFRR,SOR/2002-184, subsection 1(2)

Nature of principal business

An entity's type or field of business. Also applies to an individual in the case of a sole proprietorship. (nature de l'entreprise principale)

New developments

Changes to the structure or operations of a business when new services, activities, or locations are put in place. For example, changes to a business model or business restructuring. (nouveaux développements)

New technologies

The adoption of a technology that is new to a business. For example, when a business adopts new systems or software such as transaction monitoring systems or client onboarding and identification tools. (nouvelles technologies)

No apparent reason

There is no clear explanation to account for suspicious behaviour or information. (sans raison apparente)

Occupation

The job or profession of an individual. (profession ou métier)

Person

An individual. (personne)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Person authorized to give instructions

In respect of an account, means a person who is authorized to instruct on the account or make changes to the account, such as modifying the account type, updating the account contact details, and in the case of a credit card account, requesting a limit increase or decrease, or adding or removing card holders. A person who is only able to conduct transactions on the account is not considered a person authorized to give instructions. (personne habilitée à donner des instructions)

Politically exposed domestic person

A person who, at a given time, holds—or has held within a prescribed period before that time—one of the offices or positions referred to in any of paragraphs (a) and (c) to (j) in or on behalf of the federal government or a provincial government or any of the offices or positions referred to in paragraphs (b) and (k):

(a) Governor General, lieutenant governor or head of government;
(b) member of the Senate or House of Commons or member of a legislature of a province;
(c) deputy minister or equivalent rank;
(d) ambassador, or attaché or counsellor of an ambassador;
(e) military officer with a rank of general or above;
(f) president of a corporation that is wholly owned directly by His Majesty in right of Canada or a province;
(g) head of a government agency;
(h) judge of an appellate court in a province, the Federal Court of Appeal or the Supreme Court of Canada;
(i) leader or president of a political party represented in a legislature;
(j) holder of any prescribed office or position; or
(k) mayor, reeve or other similar chief officer of a municipal or local government.

(national politiquement vulnérable)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 9.3(3).

Politically exposed foreign person

A person who holds or has held one of the following offices or positions in or on behalf of a foreign state:

(a) head of state or head of government;
(b) member of the executive council of government or member of a legislature;
(c) deputy minister or equivalent rank;
(d) ambassador, or attaché or counsellor of an ambassador;
(e) military officer with a rank of general or above;
(f) president of a state-owned company or a state-owned bank;
(g) head of a government agency;
(h) judge of a supreme court, constitutional court or other court of last resort;
(i) leader or president of a political party represented in a legislature; or
(j) holder of any prescribed office or position.

(étranger politiquement vulnérable)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Possibility

In regards to completing a suspicious transaction report (STR), the likelihood that a transaction may be related to a money laundering/terrorist financing (ML/TF) offence. For example, based on your assessment of facts, context and ML/TF indicators you have reasonable grounds to suspect that a transaction is related to the commission or attempted commission of an ML/TF offence. (possibilité)

Precious metal

Gold, silver, palladium or platinum in the form of coins, bars, ingots or granules or in any other similar form. (métal précieux)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Precious stones

Diamonds, sapphires, emeralds, tanzanite, rubies or alexandrite. (pierre précieuse)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Prepaid payment product

A product that is issued by a financial entity and that enables a person or entity to engage in a transaction by giving them electronic access to funds or virtual currency paid to a prepaid payment product account held with the financial entity in advance of the transaction. It excludes a product that:

(a) enables a person or entity to access a credit or debit account or one that is issued for use only with particular merchants; or
(b) is issued for single use for the purposes of a retail rebate program.

(produit de paiement prépayé)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Prepaid payment product account

An account – other than an account to which only a public body or, if doing so for the purposes of humanitarian aid, a registered charity as defined in subsection 248(1) of the Income Tax Act, can add funds or virtual currency – that is connected to a prepaid payment product and that permits:

(a) funds or virtual currency that total $1,000 or more to be added to the account within a 24-hour period; or
(b) a balance of funds or virtual currency of $1,000 or more to be maintained.

(compte de produit de paiement prépayé)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Prescribed

Prescribed by regulations made by the Governor in Council. (Version anglaise seulement)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Probability

The likelihood in regards to completing a suspicious transaction report (STR) that a financial transaction is related to a money laundering/terrorist financing (ML/TF) offence. For example, based on facts, having reasonable grounds to believe that a transaction is probably related to the commission or attempted commission of an ML/TF offence. (probabilité)

Production order

A judicial order that compels a person or entity to disclose records to peace officers or public officers. (ordonnance de communication)

Public body

Means

(a) a department or an agent of His Majesty in right of Canada or an agent or mandatary of His Majesty in right of a province;
(b) an incorporated city or town, village, metropolitan authority, township, district, county, rural municipality or other incorporated municipal body in Canada or an agent or mandatary in Canada of any of them; and
(c) an organization that operates a public hospital and that is designated by the Minister of National Revenue as a hospital authority under the Excise Tax Act, or an agent or mandatary of such an organization.

(organisme public)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Real estate broker or sales representative

A person or entity that is authorized under provincial legislation to act as an agent or mandatary for purchasers or vendors in respect of the purchase or sale of real property or immovables. (courtier ou agent immobilier)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Real estate developer

A person or entity that, in any calendar year after 2007, has sold to the public, other than in the capacity of a real estate broker or sales representative:

(a) five or more new houses or condominium units;
(b) one or more new commercial or industrial buildings; or
(c) one or more new multi-unit residential buildings each of which contains five or more residential units, or two or more new multi-unit residential buildings that together contain five or more residential units.

(promoteur immobilier)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Reasonable measures

Steps taken to achieve a desired outcome, even if they do not result in the desired outcome. For example, this can include doing one or more of the following:

asking the client,
conducting open source searches,
retrieving information already available, including information held in non-digital formats, or
consulting commercially available information.

(mesures raisonnables)

Receipt of funds record

A record that indicates the receipt of an amount of funds and that contains the following information:

(a) the date of the receipt;
(b) if the amount is received from a person, their name, address and date of birth and the nature of their principal business or their occupation;
(c) if the amount is received from or on behalf of an entity, the entity's name and address and the nature of their principal business;
(d) the amount of the funds received and of any part of the funds that is received in cash;
(e) the method by which the amount is received;
(f) the type and amount of each fiat currency involved in the receipt;
(g) if applicable, the exchange rates used and their source;
(h) the number of every account that is affected by the transaction in which the receipt occurs, the type of account and the name of each account holder;
(i) the name and address of every other person or entity that is involved in the transaction, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
(j) every reference number that is connected to the transaction and has a function equivalent to that of an account number; and
(k) the purpose of the transaction.

(relevé de réception de fonds)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Registered pension plan

Has the same meaning as in subsection 248(1) of the Income Tax Act. (régime de pension agréé)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Registered retirement income fund

Has the same meaning as in subsection 248(1) of the Income Tax Act. (fonds enregistré de revenu de retraite)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Reliable

In respect of information that is used to verify identity, means that the source is well known, reputable, and is considered one that you trust to verify the identity of the client. (fiable)

Representative for service

An individual in Canada that has been appointed by a person or entity that is a foreign money services business (FMSB), pursuant to the PCMLTFA, to receive notices and documents on behalf of the FMSB. (représentant du service)

Risk assessment

The review and documentation of potential money laundering/terrorist financing risks in order to help a business establish policies, procedures and controls to detect and mitigate these risks and their impact. (évaluation des risques)

Sanctions evasion

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). (contournement des sanctions)

Securities dealer

A person or entity that is referred to in paragraph 5(g) of the Act. (courtier en valeurs mobilières)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Senior officer

In respect of an entity, means:

(a) a director of the entity who is one of its full-time employees;
(b) the entity's chief executive officer, chief operating officer, president, secretary, treasurer, controller, chief financial officer, chief accountant, chief auditor or chief actuary, or any person who performs any of those functions; or
(c) any other officer who reports directly to the entity's board of directors, chief executive officer or chief operating officer.

(cadre dirigeant)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Service agreement

An agreement between a money services business (MSB) and an organization according to which the MSB will provide any of the following MSB services on an ongoing basis:

money transfers;
foreign currency exchange;
issuing or redeeming money orders, traveller's cheques or anything similar; or
dealing in virtual currencies.
Crowdfunding
Armoured Cars

(accord de relation commerciale)

Settlor

A settlor is an individual or entity that creates a trust with a written trust declaration. The settlor ensures that legal responsibility for the trust is given to a trustee and that the trustee is provided with a trust instrument document that explains how the trust is to be used for the beneficiaries. A settlor includes any individual or entity that contributes financially to that trust, either directly or indirectly. (constituant)

Shell bank

A foreign financial institution that:

(a) does not have a place of business that:
1. (i) is located at a fixed address—where it employs one or more persons on a full-time basis and maintains operating records related to its banking activities—in a country in which it is authorized to conduct banking activities; and
2. (ii) is subject to inspection by the regulatory authority that licensed it to conduct banking activities; and
(b) is not controlled by, or under common control with, a depository institution, credit union or foreign financial institution that maintains a place of business referred to in paragraph (a) in Canada or in a foreign country.

(banque fictive)

Reference:
PCMLTFR, SOR/2002-184, s. 1(1).

Signature

Includes an electronic signature or other information in electronic form that is created or adopted by a client of a person or entity referred to in section 5 of the Act and that is accepted by the person or entity as being unique to that client. (signature)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Signature card

In respect of an account, means a document that is signed by a person who is authorized to give instructions in respect of the account, or electronic data that constitutes the signature of such a person. (fiche-signature)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Source

The issuer or provider of information or documents for verifying identification. (source)

Source of funds or of virtual currency (VC)

The origin of the particular funds or VC used to carry out a specific transaction or to attempt to carry out a transaction. It is how the funds were acquired, not where the funds may have been transferred from. For example, the source of funds could originate from activities or occurrences such as employment income, gifts, the sale of a large asset, criminal activity, etc. (origine des fonds ou de la monnaie virtuelle (MV))

Source of wealth

The origin of a person's total assets that can be reasonably explained, rather than what might be expected. For example, a person's wealth could originate from an accumulation of activities and occurrences such as business undertakings, family estates, previous and current employment income, investments, real estate, inheritance, lottery winnings, etc. (origine de la richesse)

Starting action

With respect to a reportable transaction, information related to the instructions provided by the person or entity making the request to the reporting entity to start a transaction. For example, an individual arrives at a bank and requests to purchase a bank draft. The starting action is the details of the instructions for the purchase which includes the funds or virtual currency that the requesting person or entity brought to the reporting entity. A transaction must have at least one starting action. (action d’amorce)

SWIFT

The Society for Worldwide Interbank Financial Telecommunication. (SWIFT)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Terrorist activity

Has the same meaning as in subsection 83.01(1) of the Criminal Code. (activité terroriste)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Terrorist activity financing offence

An offence under section 83.02, 83.03 or 83.04 of the Criminal Code or an offence under section 83.12 of the Criminal Code arising out of a contravention of section 83.08 of that Act.

A terrorist financing offence is knowingly collecting or giving property (such as money) to carry out terrorist activities. This includes the use and possession of any property to help carry out the terrorist activities. The money earned for terrorist financing can be from legal sources, such as personal donations and profits from a business or charitable organization or from criminal sources, such as the drug trade, the smuggling of weapons and other goods, fraud, kidnapping and extortion. (infraction de financement des activités terroristes)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Third party

Any individual or entity that instructs another individual or entity to act on their behalf for a financial activity or transaction. (tiers)

Threats to the security of Canada

Has the same meaning as in section 2 of the Canadian Security Intelligence Service Act. (menaces envers la sécurité du Canada)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Training program

A written and implemented program outlining the ongoing training for your employees, agents or other individuals authorized to act on your behalf. It should contain information about all your obligations and requirements to be fulfilled under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its associated Regulations. (programme de formation)

Trust

A right of property held by one individual or entity (a trustee) for the benefit of another individual or entity (a beneficiary). (fiducie)

Trust company

A company that is referred to in any of paragraphs 5(d) to (e.1) of the Act. (société de fiducie)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Trustee

A trustee is the individual or entity authorized to hold or administer the assets of a trust. (fiduciaire)

Tutor

In the context of civil law, a person who has been lawfully appointed to the care of the person and property of a minor. (tuteur)

Two year effectiveness review

A review, conducted every two years (at a minimum), by an internal or external auditor to test the effectiveness of your policies and procedures, risk assessment, and training program. (examen bisannuel de l'efficacité)

Valid

In respect of a document or information that is used to verify identity, appears legitimate or authentic and does not appear to have been altered or had any information redacted. The information must also be valid according to the issuer, for example if a passport is invalid because of a name change, it is not valid for FINTRAC purposes. (valide)

Verify identity

To refer to certain information or documentation, in accordance with the prescribed methods, to identify a person or entity (client). (vérifier l'identité)

Very large corporation or trust

A corporation or trust that has minimum net assets of $75 million CAD on its last audited balance sheet. The corporation's shares or units have to be traded on a Canadian stock exchange or on a stock exchange designated under subsection 262(1) of the Income Tax Act. The corporation or trust also has to operate in a country that is a member of the Financial Action Task Force (FATF). (personne morale ou fiducie dont l'actif est très important)

Violation

A contravention of the Act or the regulations that is designated as a violation by regulations made under subsection 73.1(1). (violation)

Reference:
PCMLTFA, S.C. 2000, c 17, s. 2(1).

Virtual currency

Means:

(a) a digital representation of value that can be used for payment or investment purposes that is not a fiat currency and that can be readily exchanged for funds or for another virtual currency that can be readily exchanged for funds; or
(b) a private key of a cryptographic system that enables a person or entity to have access to a digital representation of value referred to in paragraph (a).

(monnaie virtuelle)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2).

Virtual currency exchange transaction

An exchange, at the request of another person or entity, of virtual currency for funds, funds for virtual currency or one virtual currency for another. (opération de change en monnaie virtuelle)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Virtual currency exchange transaction ticket

A record respecting a virtual currency exchange transaction—including an entry in a transaction register—that sets out:

(a) the date of the transaction;
(b) in the case of a transaction of $1,000 or more, the name and address of the person or entity that requests the exchange, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
(c) the type and amount of each type of funds and each of the virtual currencies involved in the payment made and received by the person or entity that requests the exchange;
(d) the method by which the payment is made and received;
(e) the exchange rates used and their source;
(f) the number of every account that is affected by the transaction, the type of account and the name of each account holder;
(g) every reference number that is connected to the transaction and has a function equivalent to that of an account number; and
(h) every transaction identifier, including the sending and receiving addresses.

(fiche d'opération de change en monnaie virtuelle)

Reference:
PCMLTFR, SOR/2002-184, s. 1(2).

Working days

In respect of an electronic funds transfer (EFT) report or a large virtual currency transaction report, a working day is a day between and including Monday to Friday. It excludes Saturday, Sunday, and a public holiday. (jour ouvrable)

Date Modified:: 2024-08-19

Reporting suspicious transactions to FINTRAC : FINTRAC's compliance guidance

In this guidance

Related links

1. Who must comply

2. What is a Suspicious Transaction Report

3. What are reasonable grounds to suspect

4. When to submit a Suspicious Transaction Report

Measures you can take to establish the reasonable grounds to suspect threshold

What is a fact

What is context

What is a money laundering or terrorist activity financing indicator, or sanctions evasion characteristic

What is "as soon as practicable"

5. How to submit a report to FINTRAC

Paper reporting

Changes to a Suspicious Transaction Report

6. The form for reporting suspicious transactions

In this section

Form structure

Form highlights

7. Other requirements associated with suspicious transactions

In this section

Compliance program

Large cash transactions

Electronic funds transfers

Large virtual currency transactions

Casino disbursements

Terrorist property

Record keeping requirements

Verifying the identity of persons and entities

Third party determination

Ministerial directives

Voluntary self-declaration of non-compliance

8. Reporting subsequent suspicious transactions

9. FINTRAC's expectations for completing a Suspicious Transaction Report

10. Common Suspicious Transaction Report deficiencies to avoid

Annex A: Field instructions to complete a Suspicious Transaction Report

In this annex

Standardized field instructions

In this section

Field categories

Name fields

Address fields

Structured address fields

If you have the ability to separate the information

If you are unable to separate the address information into the structured address fields

If there is no civic address

Unstructured address field

Invalid addresses

Persons who are transient or have no fixed address

Occupation/business fields

Identification fields

Telephone number fields

Specific field instructions

In this section

General information

Which one of the following types of reporting entities best describes you?

Whom can FINTRAC contact about this report?

Report information

Transaction information: Transaction 1 of X

Information about the transaction

Information about where the transaction was conducted or attempted

Starting action

Account holder

Person

Entity

Source of funds or virtual currency

Person

Entity

Note about source of funds or virtual currency fields

Conductor information

Identification of the person

Conductor – Entity

Incorporation of the entity

Registration of the entity

Identification of the entity

Person authorized to bind the entity or act with respect to the account (maximum 3)

Entity Structure/Type:

Corporate Information

Person who directly or indirectly owns or controls 25% or more shares of the corporation

Trust Information