What a FINTRAC Case Disclosure Contains

FINTRAC’s case disclosures consist of designated information that identifies individuals or entities and their transactions or attempted transactions. A disclosure can include any or all of the following:

• Name and address of the entity(ies) involved in the transaction(s);
• Name, address, electronic mail address and telephone number of each partner, director or officer of an entity involved in transactions or of an entity acting on their behalf;
• Name, address, telephone number and type of business where the transaction(s) occurred;
• Date and time of the transaction(s);
• Type and value of the transaction(s) including the amount and type of currency or monetary instruments involved;
• Transaction, transit and account number(s), as well as the type of account(s) involved;
• Name and address of all persons authorized to act in respect of the account (signing authority, power of attorney, etc.);
• Name of importer or exporter, in the case of importation or exportation of currency or monetary instruments;
• Name of any person or entity involved in importation or exportation transactions or any person or entity acting on their behalf;
• Name, address, telephone number and electronic mail address of person(s) involved in the transaction(s);
• Date of birth, citizenship, passport and record of landing or permanent resident card number of person(s) involved in the transaction(s);
• Telephone number and electronic mail address of any entities involved in transactions or any person or entity acting on their behalf;
• The fact that any persons or entities involved in transactions or a person or entity acting on their behalf have relevant criminal records or have had any relevant criminal charges laid against them;
• Relationships suspected on reasonable grounds to exist between any persons or entities suspected on reasonable grounds to be involved in transactions or persons or entities acting on their behalf and any other persons or entities;
• The fact that any persons or entities involved in transactions or persons or entities acting on their behalf have a financial interest in the entity on whose behalf the transaction was made;
• Name of the person who FINTRAC suspects on reasonable grounds of directing the suspected money laundering or terrorist financing;
• Grounds on which a person or entity made a suspicious transaction report when found relevant by FINTRAC;
• Number and types of reports on which a disclosure is based;
• Number and categories of persons or entities that made the reports;
• Indicators relied upon by FINTRAC to justify a disclosure; and
• Publicly available information.

Law enforcement or CSIS may seek to obtain FINTRAC’s full case analysis by means of a production order granted by a court. Under Bill C-25, the Canada Revenue Agency can now seek a production order as well, but only in relation to an investigation relevant to a disclosure previously made to the CRA.