Guideline 10A: Submitting Casino Disbursement Reports to FINTRAC Electronically
June 2011
This replaces the previous version of Guideline 10A: Submitting Casino Disbursement Reports to FINTRAC Electronically issued in August 2009. The changes made are indicated by a side bar to the right of the modified text in the PDF version.
Table of Contents
- General
- Casino Disbursement Reporting Requirements
- Electronic Reporting
- Instructions for Completing a Casino Disbursement Report
- Comments?
- How to Contact FINTRAC
- Field-by-Field Instructions for a Casino Disbursement Report in F2R
- Navigation Through F2R Reporting Screens for a Casino Disbursement Report
- Field-by-Field Instructions for a Casino Disbursement Report by Batch
- Examples of Reasons and Methods for Casino Disbursement Reports
1. General
The objective of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) is to help detect and deter money laundering and the financing of terrorist activities. It is also to facilitate investigations and prosecutions of money laundering and terrorist activity financing offences. This includes reporting, record keeping, client identification and compliance regime requirements for casinos.
Casinos are those authorized by a Canadian provincial, territorial or federal government to do business and that conduct their business in a permanent establishment. It only includes those where roulette or card games are played in the establishment, or where there is a slot machine. For these purposes, a slot machine does not include a video lottery terminal.
Registered charities may be authorized to carry on business temporarily as a casino for charitable purposes. If this type of business is carried out in the establishment of a casino for no more than two consecutive days at a time under the supervision of the casino, the activities are considered to be the supervising casino's. In this case, the supervising casino is responsible for the reporting requirements and other obligations related to the charity casino.
If you are a casino, this guideline has been prepared to help you submit casino disbursement reports electronically. It explains reporting timelines, how reports have to be sent to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), and what information has to be included in these reports.
This guideline uses plain language to explain the most common reporting situations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act as well as the related regulations. It is provided as general information only. It is not legal advice, and is not intended to replace the Act and Regulations. For more information about money laundering, terrorist financing or other requirements under the Act and Regulations, see the guidelines in this series:
- Guideline 1: Backgrounder explains money laundering, terrorist financing and their international nature. It also provides an outline of the legislative requirements as well as an overview of FINTRAC's mandate and responsibilities.
- Guideline 2: Suspicious Transactions explains how to report a suspicious transaction. It also provides guidance on how to identify a suspicious transaction, including general and industry-specific indicators that may help when conducting or evaluating transactions.
- Guideline 3: Submitting Suspicious Transaction Reports to FINTRAC explains when and how to submit suspicious transaction reports. There are two different versions of Guideline 3, by reporting method.
- Guideline 4: Implementation of a Compliance Regime explains the requirement for reporting entities to implement a regime to ensure compliance with their obligations under the Act and associated regulations.
- Guideline 5: Submitting Terrorist Property Reports to FINTRAC explains to reporting entities when and how to submit a terrorist property report.
- Guideline 6: Record Keeping and Client Identification explains the requirement for reporting entities to identify their clients and keep records. There are several different versions of Guideline 6, with each one applicable to a particular sector.
- Guideline 7: Submitting Large Cash Transaction Reports to FINTRAC explains when and how to submit large cash transaction reports. There are two different versions of Guideline 7, by reporting method.
- Guideline 8: Submitting Electronic Funds Transfer Reports to FINTRAC explains when and how to submit electronic funds transfer reports. There are three different versions of Guideline 8, by type of electronic funds transfer and reporting method.
- Guideline 9: Submitting Alternative to Large Cash Transaction Reports to FINTRAC explains when and how financial entities can choose the alternative to large cash transaction reports. This is only applicable to financial entities.
- Guideline 10: Submitting Casino Disbursement Reports to FINTRAC explains when and how to submit casino disbursement reports. There are two different versions of Guideline 10, by reporting method.
If you need more help after you read this or other guidelines, call FINTRAC's national toll-free enquiries line at 1-866-346-8722.
Throughout this guideline, several references are provided to additional information that may be available on external Web sites. FINTRAC is not responsible for the accuracy or reliability of the information contained on those external Web sites. The links provided are based on information available at the time of publishing of this guideline.
Throughout this guideline, any references to dollar amounts (such as $10,000) refer to the amount in Canadian dollars or its equivalent in foreign currency.
2. Casino Disbursement Reporting Requirements
2.1 Electronic reporting enrolment
You have to be enrolled with FINTRAC's electronic reporting system to report electronically. FINTRAC will provide you with an identifier number to include in your reports. For more information about FINTRAC's electronic reporting system enrolment, contact us as explained in section 6.
2.2 When does a casino disbursement report have to be made?
You have to send a casino disbursement report to FINTRAC in the following situations:
If you make a disbursement, as described below, in an amount of $10,000 or more, in the course of a single transaction. Each such transaction must be sent to FINTRAC separately, in its own report.
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If you make two or more disbursements, as described below, of less than $10,000, that total $10,000 or more under the 24-hour rule. In this case, you have to make a casino disbursement report if your employee or senior officer knows the disbursements were received within 24 consecutive hours of each other by or on behalf of the same individual or entity.
The period for the 24-hour rule is a rolling time frame. In other words, the 24-hour period begins with each new disbursement of less than $10,000, if you know they were received by or on behalf of the same individual or entity. However, if your system permits you to know of multiple disbursements only within a static 24-hour period (such as the gaming day), you are required to report the multiple disbursements of less than $10,000 each that you know of in that 24-hour period, if they add up to $10,000 or more.
Include disbursements grouped under the 24-hour rule in the same casino disbursement report.
In the context of casino disbursement reports, only disbursements that you pay out in the following types of transactions must be reported:
- redemptions of slot tickets, chips, tokens or plaques;
- front cash withdrawals;
- safekeeping withdrawals;
- advances on any form of credit, including advances by markers or counter cheques;
- payments on bets, including slot jackpots;
- payments to clients of funds received for credit to that client or any other client;
- cashing of cheques or other negotiable instruments; and
- reimbursements to clients of travel and entertainment expenses.
This includes amounts paid out in cash, by cheque, by transfer or many other methods, but it only includes amounts paid out to a casino client or patron and only if they were paid out for the types of transactions listed above. However, in this context, disbursements exclude any amounts that you pay out in casino chips, tokens or slot tickets.
A disbursement does not include the following:
- a payment for services or goods to the casino's staff, suppliers or entertainers
- an amount deposited to the casino's bank account
- an amount deposited to a front money account
- an amount applied to a casino credit account
- an advance on a client's credit card, unless the credit card was issued by the casino
- a "comp" (complimentary) payment or redemption of player points
- a cash bonus payment (rewards program)
- cash received by the casino (see Guideline 7: Submitting Large Cash Transaction Reports to FINTRAC for information about when receipts of cash are reportable)
If you pay out such an amount, it is not a reportable disbursement. However, if you conduct a single transaction in which you pay out an amount that covers both a reportable disbursement and a non-reportable payment, you will have to submit a casino disbursement report. For example, if you redeem $18,000 in chips for a client by issuing a cheque to the client for $10,000 and depositing the rest ($8,000) to the client's front money account, you would be required to report this transaction in a casino disbursement report. In this case, the reason for disbursement in the report would reflect the total amount of chips presented for redemption, but the method of disbursement would not include the deposit to the front money account.
In this example, if the disbursement cheque issued were less than $10,000, the transaction would not be reportable (unless you knew of other disbursements of less than $10,000 for the 24-hour rule to apply).
A casino disbursement report is required when both the reason and the method of a disbursement equal $10,000 or more. For examples to illustrate this, refer to Appendix 4.
You have to send a casino disbursement report to FINTRAC within 15 calendar days after the disbursement.
2.3 Disbursements in foreign currency
If a disbursement is in foreign currency, you will need to check whether it is the equivalent of 10,000 Canadian dollars or more to determine whether or not it is reportable. For this purpose only, use the last noon rate provided by the Bank of Canada available at the time of the transaction. This calculation is not based on the actual exchange rate used to process the transaction - this is only to check whether the $10,000 threshold is met for the transaction to be reportable.
For example, for a disbursement in foreign currency that happened at 9:00 a.m. on Tuesday following a holiday Monday, you would use the Bank of Canada noon rate from the previous Friday to determine whether it is reportable. You can find the noon rate applicable at the time of a transaction on the Bank of Canada Web site at http://www.bankofcanada.ca/rates/exchange/. If there is no Bank of Canada noon rate published for the currency of the transaction, use the actual exchange rate applied when you processed the disbursement to determine whether it is reportable.
Once you have determined that a disbursement in foreign currency is in fact reportable based on the Bank of Canada noon rate, you will have to send a casino disbursement report to FINTRAC. On this report, you will indicate any amounts involved in the transaction in foreign currency, and indicate the appropriate currency code. You are not required to provide information about any exchange rate applicable to the transaction in the casino disbursement report. The exchange rate is only relevant to determine whether or not the transaction is reportable.
2.4 Other requirements associated with casino disbursements
In addition to the reporting requirements explained in this guideline, consider the following relating to a casino disbursement:
Record keeping and client identification
You have to keep a copy of each casino disbursement report you send to FINTRAC. In addition, casino disbursements have client identification and other associated record keeping requirements, such as third party determination. These are explained in Guideline 6F: Record Keeping and Client Identification for Casinos.
Electronic funds transfer report
If a casino disbursement involves an electronic funds transfer, you may have to make an electronic funds transfer report to FINTRAC about the same transaction in addition to the casino disbursement report.
For more information about making electronic funds transfer reports, consult Guideline 8: Submitting Electronic Funds Transfer Reports to FINTRAC.
Suspicious transaction report
If anything about a casino disbursement gives you reasonable grounds to suspect that it could be related to a money laundering or a terrorist activity financing offence, you have to make a suspicious transaction report to FINTRAC. This would be in addition to making the casino disbursement report about the same transaction as required.
Furthermore, if a disbursement is attempted but not completed, a casino disbursement report is not required. However, if the attempted disbursement gives you reasonable grounds to suspect that it could be related to a money laundering or a terrorist activity financing offence, you have to make a suspicious transaction report to FINTRAC.
The suspicious transaction report has many similar fields to those of a casino disbursement report, although the order of some parts is different. There are other differences, such as a field in the suspicious transaction report for you to explain your suspicion about the transaction. There is also a field in that report for you to describe what action, if any, was taken by you as a result of the suspicious transaction. This would include stating that you have made a casino disbursement report for the same transaction (if that is the case).
For more information about suspicious transaction reports, consult the following:
- Guideline 1: Backgrounder
- Guideline 2: Suspicious Transactions
- Guideline 3: Submitting Suspicious Transaction Reports to FINTRAC
Transactions related to terrorist property
If you know that any proposed transaction is related to property owned or controlled by or on behalf of a terrorist or a terrorist group, you cannot complete the transaction. This is because terrorist property must be frozen under the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism as well as the Criminal Code.
For more information about this and to find out what your obligations are regarding any terrorist property in your control or possession, consult the following:
- Guideline 1: Backgrounder
- Guideline 5: Submitting Terrorist Property Reports to FINTRAC
2.5 Means of reporting to FINTRAC
Electronic reporting
See sections 3 and 4 for more information on submitting reports to FINTRAC electronically.
Paper reporting
If you do not have the technical capabilities to send reports electronically, you must submit reports on paper. See Guideline 10B: Submitting Casino Disbursement Reports to FINTRAC by Paper for more information.
2.6 Casino disbursement report records
When you have to report a casino disbursement to FINTRAC, you have to keep a copy of the report. See Guideline 6: Record Keeping and Client Identification for more information about obligations related to keeping records.
If you use F2R to submit reports, you will be given the option to print or save the report before you submit it to FINTRAC. If you submit your suspicious transaction reports by batch, your copy of your batch file will contain copies of the reports.
3. Electronic Reporting
3.1 Minimum technical capabilities
You will have to submit all casino disbursement reports to FINTRAC electronically if you have the technical capabilities to do so. The minimum technical capabilities are as follows:
- A personal computer with the following characteristics:
- 32 MB memory (64 MB or higher is preferable);
- 640 x 480 VGA video display (800 x 600 or higher is preferable)
- an operating system running a Web browser; and
- An Internet connection
3.2 Options for electronic reporting
There are two options for electronic reporting:
- FINTRAC's secure Web site (F2R); and
- Batch file transfer.
Both options provide for secure encrypted transmission to ensure data confidentiality and integrity. Reporting through batch will require more advanced technical capability than explained in subsection 3.1.
3.3 How to complete electronic reports
Reporting through F2R
F2R contains the casino disbursement reporting screens, with completion instructions. Drop-down menus appear wherever a code or specific selection is required.
See Appendix 1 for the completion instructions, including details of what each field must contain for a casino disbursement report. Also, Appendix 2 explains how to navigate through the F2R reporting screens.
Reporting through batch file transfer
To use the batch file reporting mechanism, you need a public key infrastructure (PKI) certificate and specialized software available from FINTRAC. For more information about how to get these, refer to the reporting area of FINTRAC's Web site (http://www.fintrac-canafe.gc.ca).
Consult the XML Batch Reporting Instructions and Specifications for more information about how to report casino disbursements through batch file transfer. This document is available from the technical documentation in the publications area of FINTRAC's Web site (http://www.fintrac-canafe.gc.ca). You can also refer to Appendix 3 of this guideline for instructions regarding the content of fields in a casino disbursement report.
3.4 Acknowledgement of receipt of an electronic report
FINTRAC will send you an acknowledgement message when your casino disbursement report has been received electronically.
If you send your reports by batch, you will receive two acknowledgements. The first will confirm that your batch has been received by FINTRAC. The second will confirm that it has been processed.
For each report submitted through F2R, you will receive an acknowledgement message including the date and time your report was received and the report's identification number. These acknowledgements will be stored on F2R and available for viewing or printing.
3.5 Report corrections
If you need to request a casino disbursement report for change in F2R, you will do so based on the acknowledgement for that report.
In addition, if you send a casino disbursement report that contains incomplete or inaccurate information, FINTRAC may notify you. The notification will indicate the date and time your report was received, a FINTRAC-generated identification number, along with information on the fields that must be completed or corrected.
After receiving FINTRAC's notification, you must provide the necessary information to FINTRAC within the 15-calendar-day reporting deadline. In other words, this information should be sent to FINTRAC within 15 calendar days after the disbursement. Your obligation to report will not be fulfilled until you send the complete report to FINTRAC.
If a correction is required to a report that you sent through F2R, you will have to make that correction through F2R.
If a correction is required to a casino disbursement report that you sent through batch file transfer, you will do this according to your choice of correction options upon enrolment for electronic reporting. For more information about this, refer to the XML Batch Reporting Instructions and Specification.
4. Instructions for Completing a Casino Disbursement Report
4.1 General instructions
Instructions for the fields of the Casino Disbursement Report screens in F2R are contained in Appendix 1. Additional instructions in Appendix 2 relate to navigation through the reporting screens on F2R.
If you report casino disbursements through batch, you need to refer to the XML Batch Reporting Instructions and Specifications and Appendix 3 for the field-by-field instructions.
Fields in reports are either mandatory, mandatory if applicable, or require "reasonable efforts" to complete, as follows:
- Mandatory: All fields of a report marked with an asterisk (*) have to be completed.
- Mandatory if applicable: The fields that have both an asterisk and "if applicable" next to them have to be completed if they are applicable to you or the transaction being reported.
- Reasonable efforts: For all other fields that do not have an asterisk, you have to make reasonable efforts to get the information. "Reasonable efforts" means that you tried to get the information requested on the report. If the information is available to you, you must provide it in the report. If the information was not available at the time of the transaction, and it is not contained in your files or records, the field may be left blank.
As explained in subsection 2.2, a casino disbursement report can be about multiple disbursements of less than $10,000 each conducted within 24 consecutive hours of each other that add up to $10,000 or more. Because those individual disbursements were under $10,000, the information for some mandatory fields in the report may not be available in your records or from the time of the disbursement. In this case, "reasonable efforts" applies to those otherwise mandatory fields.
4.2 Accessing the F2R reporting screens
To access F2R, reporting entities first have to be enrolled for electronic reporting with FINTRAC. For more information about this, consult the F2R Electronic Reporting User Guide, available from the technical documentation area of the Publications page of FINTRAC's main Web site (http://www.fintrac-canafe.gc.ca).
You can get to F2R from the log on link located on the Reporting page of FINTRAC's Web site (http://www.fintrac-canafe.gc.ca). If you are authorized to complete casino disbursement reports, you will be able to select this report type in F2R. You will be able to complete a new report or continue working on an incomplete report (that is, a report that was not previously submitted to FINTRAC). For more information about completing a report, see Appendices 1 and 2 of this guideline.
Also, depending on your access rights, you will be able to submit a request for change to a completed report (that is, one that was previously submitted to FINTRAC). Subsection 4.4 contains instructions for submitting a change to a previously submitted report.
4.3 Instructions for submitting a new report
There are nine parts to the casino disbursement report, but some are only to be completed if the part is applicable. In addition, certain fields will not appear when the information does not apply.
If you use F2R, see Appendix 1 for instructions about the fields in each part of the report. Appendix 2 provides additional instructions regarding navigation through the reporting screens.
If you report casino disbursements through batch, you should refer to the XML Batch Reporting Instructions and Specifications and Appendix 3.
4.4 Instructions for submitting a change to a previously submitted report
If you have to submit a change to a previously submitted casino disbursement report, you must provide any required changes to FINTRAC within the reporting deadline for the report. In other words, this information should be sent to FINTRAC within 15 calendar days of the disbursement.
If you report casino disbursements through batch, refer to the technical documentation called XML Batch Reporting Instructions and Specifications to find out how to submit changes for previously submitted casino disbursement reports by batch. If you choose to do this through F2R instead of by batch, read subsection 4.5. That choice means that you cannot submit changes by batch.
If you report through F2R, read subsection 4.5.
4.5 Submitting changes through F2R
The following explains how to make a change to a previously submitted casino disbursement report through F2R:
Report returned for further action (RRFA)
If a casino disbursement report is returned to you by FINTRAC for correction, you can access it through the queue for reports returned for further action. Select "RRFA" from the left side menu in the "Reporting" area. The entire report will be available.If nothing is displayed, there are no reports awaiting further action in this queue, or none have been assigned to you.
Change a report
If you need to change a casino disbursement report that you previously submitted to FINTRAC, you will have to request that this report be sent back to you for this purpose. Select "Acknowledgements" from the left side menu to find the FINTRAC report reference number for the report in need of correction. Once you have selected the report you need to change, select the "Request for change" button at the top of the screen. Within a few moments of your request, the screens for that report will be made available to you through the "Requested for change" queue.
Change details
Before any change to a report can be submitted to FINTRAC, you have to provide an explanation as to the change made. If it was not requested by FINTRAC, you also have to provide a reason for the change.
Remember that you must provide any required changes to FINTRAC within the reporting deadline for the report. In other words, this information should be sent to FINTRAC within 15 calendar days after the disbursement.
5. Comments?
These guidelines will be reviewed on a periodic basis. If you have any comments or suggestions to help improve them, please send your comments to the mailing address provided below or by email to guidelines-lignesdirectrices@fintrac-canafe.gc.ca.
6. How to Contact FINTRAC
For further information on FINTRAC and its activities, reporting and other obligations, please go to FINTRAC's Web site (http://www.fintrac-canafe.gc.ca) or contact FINTRAC:
Financial Transactions and Reports Analysis Centre of Canada
234 Laurier Avenue West, 24th floor
Ottawa ON K1P 1H7
Canada
Toll-free: 1-866-346-8722