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Armoured cars : FINTRAC's requirements

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

This guidance is to help you determine if FINTRAC’s anti-money laundering and anti-terrorist activity financing requirements apply to you as of July 1, 2024 and to understand what you will have to do to comply.

On this page

Who must comply

As of July 1, 2024, persons or entities engaged in the business of transporting currency, money orders, traveller’s cheques or other similar negotiable instruments (referred to as armoured cars) are subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and have the obligations listed on this page.

Definition

Armoured cars are businesses that engage in transporting:

Armoured car businesses are subject to the obligations that apply to money services businesses and foreign money services businesses as applicable.

Legal references

Summary of requirements

As of July 1, 2024, you are responsible for the following requirements under the Act and its associated Regulations:

Register as a money services business

You must register as a money services business or a foreign money services business with FINTRAC.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), section 11.1
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations (SOR/2007-121)
    • section 4
    • schedule 1

Implement a compliance program

You must establish and implement a compliance program. The following elements must be included:

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), section 9.6
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184)
    • section 156
    • section 157

Report transactions

You must submit the following reports to FINTRAC:

Suspicious Transaction Report

You must submit this report when there are reasonable grounds to suspect that a financial transaction that occurs or is attempted in the course of your activities is related to the commission or attempted commission of a money laundering or a terrorist activity financing offence.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act(S.C. 2000, c. 17), section 7
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transactions Reporting Regulations (SOR/2001-317)
    • section 9
    • schedule 1

Terrorist Property Report

You must submit this report when you know there is property in your possession or control that is owned or controlled by or on behalf of a terrorist or a terrorist group.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), section 7.1
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transactions Reporting Regulations (SOR/2001-317)
    • section 10
    • schedule 2

Large Cash Transaction Report

You must submit this report when you receive $10,000 or more in cash in the course of a single transaction. This includes:

Exceptions for large cash transaction report

You do not have to report a large cash transaction if the cash is received for transportation:

  • to or from another reporting entity, if the transport is at their request and in an undeclared amount that cannot readily be determined
  • between the Bank of Canada and a person or entity in Canada, or
  • between 2 places of business of another reporting entity, at their request

Certain other exceptions exist for reporting large cash transactions. Please refer to guidance listed below (further reading) for more information.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), section 9(1)
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184)
    • sections 30(1)(a) and 30(2)
    • section 32.1
    • sections 33(1)(a) and 33(2)
    • section 35.1
    • section 126
    • sections 140(1) and 140(2)
    • schedule 1

Large Virtual Currency Transaction Report

You must submit this report when you receive virtual currency in an amount equivalent to $10,000 or more in a single transaction. This includes:

Exceptions for large virtual currency transaction report

You do not have to report a large virtual currency transaction if the virtual currency is received for transportation:

  • to or from another reporting entity, if the transport is at their request and in an undeclared amount that cannot readily be determined
  • between the Bank of Canada and a person or entity in Canada, or
  • between 2 places of business of another reporting entity, at their request

Certain other exceptions exist for reporting large virtual currency transactions. Please refer to guidance listed below (further reading) for more information.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), section 9(1)
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184)
    • section 30(1)(f)
    • section 32.1
    • section 33(1)(f)
    • section 35.1
    • section 129
    • sections 141(1) and 141(2)
    • section 151
    • schedule 4

Electronic Funds Transfer Report

You must submit this report when you initiate or finally receive an international electronic funds transfer of $10,000 or more in a single transaction (i.e. the transmission of instructions at the request of a client for a transfer of funds through any electronic, magnetic or optical means). This includes transactions that fall under the 24-hour rule.

The travel rule applies to any international electronic funds transfer you initiate or receive.

Certain exceptions exist for reporting electronic funds transfers. Please refer to guidance listed below (further reading) for more information.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17)
    • section 9(1)
    • section 9.5
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184)
    • section 30(1)(b)(c)(d)(e)
    • section 33(1)(b)(c)(d)(e)
    • section 124
    • section 127
    • section 128
    • schedule 2
    • schedule 3

Sanctions evasion

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

Further reading:

Keep records

You must keep the following records:

All records must be kept for at least 5 years.

Note: You must only keep a record of the transactions and activities in which you engage in the course of your business. The records listed above include all record types that may apply to money services businesses and foreign money services businesses. Those records may not all apply to your specific business.

Exception for large cash transaction or large virtual currency transaction records

You do not have to keep a record of a large cash transaction or large virtual currency transaction if the cash or virtual currency is received for transportation:

  • to or from another reporting entity, if the transport is at their request and in an undeclared amount that cannot readily be determined
  • between the Bank of Canada and a person or entity in Canada, or
  • between 2 places of business of another reporting entity, at their request
Exception for service agreement records

You do not have to keep any service agreement records (including information records) when you enter into a service agreement with an entity only for the transport of cash, virtual currency (such as storage of virtual currency) or money orders, traveller’s cheques or similar negotiable instruments between:

  • the Bank of Canada and a person or entity in Canada
  • 2 financial entities, or
  • 2 places of business of a reporting entity, at their request

This same exception exists when you enter into a service agreement with an entity only for the transport of coins of the currency of Canada for the purposes of delivery in accordance with the Royal Canadian Mint Act.

Exception for transport records

You do not have to keep transport records when you transport cash, virtual currency (such as storage of virtual currency), money orders, traveller’s cheques or other similar negotiable instruments between:

  • the Bank of Canada and a person or entity in Canada
  • 2 financial entities, or
  • 2 places of business of a reporting entity, at their request

The same exception exists for the transport of coins of the currency of Canada for the purposes of delivery in accordance with the Royal Canadian Mint Act.

Certain other exceptions apply to your record keeping requirements. Please refer to guidance listed below (further reading) for more information.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), section 6
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184)
    • section 31
    • sections 32 and 32.1
    • section 34
    • sections 35 and 35.1
    • section 36 (for transport, refer to sections 36(f.1)((f.2)(f.3))
    • section 36.1
    • section 37
    • section 108
    • section 109(5)
    • section 111(1)(c)
    • section 112(4)
    • section 114(1)(c)
    • section 123(2)
    • section 125
    • sections 134(2) and 134(3)
    • sections 136(2) and 136(3)
    • section 138(3)
    • section 144
    • section 145
    • section 146(1)
    • section 148
    • section 151.1

Know your client

For transport services you offer, you must verify the identity of:

You must verify the identity of the person or entity before the first transport of cash, virtual currency, or any similar negotiable instrument is carried out. To do so, you must use the methods prescribed in the Regulations.

As a money services business or foreign money services business, you are also required to verify the identity of persons or entities for other prescribed activities and transactions.

Exception for verifying identity

You do not have to verify identity when you transport cash, virtual currency (such as storage of virtual currency), money orders, traveller’s cheques or other similar negotiable instruments between:

  • the Bank of Canada and a person or entity in Canada
  • 2 financial entities, or
  • 2 places of business of a reporting entity, at their request

The same exception applies to the transport of coins of the currency of Canada for the purposes of delivery in accordance with the Royal Canadian Mint Act.

Certain other exceptions apply to your requirement to verify identity. Please refer to guidance listed below (further reading) for more information.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), section 6.1
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184)
    • section 95(1)(c.1)
    • section 95(3)(a)
    • section 95(4)(a)
    • section 95(5)
    • section 105(5)
    • section 105(7)(h.01)
    • section 109(4)(h.01)
    • section 112(3)(h.01)
    • section 151.1(2)

Business relationships and ongoing monitoring

You enter into a business relationship with a client the second time you are required to verify their identity. You also form a business relationship with a client for the purpose of these Regulations when you enter into a service agreement to provide services for which you are covered under the Act.

You must periodically conduct ongoing monitoring of your business relationship, based on a risk assessment.

If the risk is deemed high, you must also:

Exception for business relationship

You do not have to form a business relationship with an entity client, as per the Regulations, when you enter into a service agreement with that entity only for the transport of cash, virtual currency (such as storage of virtual currency), money orders, traveller’s cheques or other similar negotiable instruments between:

  • the Bank of Canada and a person or entity in Canada
  • 2 financial entities, or
  • 2 places of business of a reporting entity, at their request

The same exception exists when you enter into a service agreement with an entity only for the transport of coins of the currency of Canada for the purposes of delivery in accordance with the Royal Canadian Mint Act.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184)
    • sections 4.1(b) and (d)
    • section 123.1
    • section 151.1(1)
    • section 157(b)

Third party determination

You must take reasonable measures to determine whether a third party is involved when you:

In cases where you determine that a third party is involved, you must take reasonable measures to obtain specific information about the third party and the relationship with the conductor of the transaction or the client for which the information record is kept.

If you are not able to determine, but have reasonable grounds to suspect that a third party is involved, you must keep a record that describes whether your client indicated that they are acting on their own behalf and your reasonable grounds to suspect that the person or entity is acting on behalf of a third party.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184)
    • section 134
    • section 136

Politically exposed persons

When a person requests that you transport $100,000 or more in cash, virtual currency (such as storage of virtual currency), money orders, traveler’s cheques, or other similar negotiable instruments (except for cheques payable to a named person or entity), you must take reasonable measures to determine whether you are dealing with the following people:

When you determine that you are dealing with any of these persons, you must take reasonable measures and additional actions, as required.

Exception for politically exposed person

You do not have to make a politically exposed person (or similar prescribed person) determination when you transport cash, virtual currency (such as storage of virtual currency), money orders, traveller’s cheques or other similar negotiable instruments between:

  • the Bank of Canada and a person or entity in Canada
  • 2 financial entities, or
  • 2 places of business of a reporting entity, at their request

The same exception applies to the transport of coins of the currency of Canada for the purposes of delivery in accordance with the Royal Canadian Mint Act.

This exception applies to money services business and does not apply to foreign money services businesses.

Certain other exceptions apply to your requirement to determine politically exposed persons (or similar prescribed persons). Please refer to guidance listed below (further reading) for more information.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17)
    • section 9.3
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184)
    • section 120(1)(b.1)
    • section 120(2)(b.1)
    • section 122
    • section 122.1
    • section 151.1(2)

Apply ministerial directives

Ministerial directive requirements apply to all reporting entity sectors unless otherwise specified in the directives.

Further reading:

Legal references
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), section 11.42

FINTRAC assessment expectations

To ensure compliance with the Act and its associated Regulations, FINTRAC is authorized to conduct compliance examinations to assess whether you are meeting your requirements under the law.

Some areas of review can include:

To learn more about FINTRAC assessments, review the FINTRAC assessment manual.

Note: FINTRAC’s compliance activities will be focused on assisting armoured car businesses in understanding their obligations. FINTRAC plans on engaging with the sector and conducting outreach activities before and after the coming into force of the new obligations on July 1, 2024.

Penalties for non-compliance

FINTRAC has the legislative authority to issue administrative monetary penalties to reporting entities that are found to be non-compliant with the Act and its associated Regulations.

Glossary

FINTRAC's guidance glossary includes terminology defined in the Act and its associated Regulations, as well as terms used throughout the guidance.

Related links

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