Guideline 3A: Submitting Suspicious Transaction Reports to FINTRAC Electronically

May 2011

This replaces the previous version of Guideline 3A: Submitting Suspicious Transaction 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

  1. General
  2. Who Has to Send a Suspicious Transaction Report to FINTRAC?
  3. Suspicious Transaction Reporting Requirements
  4. Electronic Reporting
  5. Instructions for completing a suspicious transaction report
  6. Comments?
  7. How to Contact FINTRAC
  • Field-by-Field Instructions for a Suspicious Transaction Report
  • Navigation Through F2R Reporting Screens for a Suspicious Transaction Report
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Guideline 3A: Submitting Suspicious Transaction Reports to FINTRAC Electronically (PDF version, 285 KB)

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 individuals and entities described in section 2.

If you are such an individual or entity, this guideline has been prepared to help you submit suspicious transaction 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. Furthermore, all references to cash mean money in circulation in any country (bank notes or coins). In this context, cash does not include cheques, money orders or other similar negotiable instruments.

For information about what is a suspicious transaction, please refer to Guideline 2: Suspicious Transactions.

2. Who Has to Send a Suspicious Transaction Report to FINTRAC?

If you are one of the following individuals or entities (called reporting entities), you must report suspicious transactions to FINTRAC.

2.1 Financial entities

Financial entities are banks (that is, those listed in Schedule I or II of the Bank Act) or authorized foreign banks with respect to their operations in Canada, credit unions, caisses populaires, financial services cooperatives, credit union centrals (when they offer financial services to anyone other than a member entity of the credit union central), trust companies, loan companies and agents of the Crown that accept deposit liabilities.

If you are a financial entity and you have foreign subsidiaries or foreign branches, the suspicious transaction reporting requirement does not apply to their operations outside Canada.

2.2 Life insurance companies, brokers and agents

A life insurance company means one regulated by provincial legislation, or a life company or foreign life company under the Insurance Companies Act. A life insurance broker or agent means an individual or entity registered or licensed provincially to carry on the business of arranging contracts of life insurance.

If you are a life insurance company and you have foreign subsidiaries or foreign branches, the suspicious transaction reporting requirement does not apply to their operations outside Canada.

2.3 Securities dealers

A securities dealer is an individual or entity authorized under provincial legislation to engage in the business of dealing in securities or any other financial instruments or to provide portfolio management or investment advising services.

If you are a securities dealer and you have foreign subsidiaries or foreign branches, the suspicious transaction reporting requirement does not apply to their operations outside Canada.

2.4 Money services businesses

A money services business means an individual or entity engaged in the business of any of the following activities:

  • foreign exchange dealing;
  • remitting or transmitting funds by any means or through any individual, entity or electronic funds transfer network; or
  • issuing or redeeming money orders, traveller's cheques or other similar negotiable instruments. This does not include redeeming cheques payable to a named individual or entity. In other words, cashing cheques made out to a particular individual or entity is not included.

Money services businesses include alternative money remittance systems, such as Hawala, Hundi, Chitti, etc.

For more information about who is engaged in the money services business, see the FINTRAC Interpretation Notice No. 1, available under "General publications" on the Publications page of FINTRAC's Web site (http://www.fintrac-canafe.gc.ca).

2.5 Agents of the Crown

Agents of the Crown are government departments or agents of her Majesty in right of Canada or of a province. If you are an agent of the Crown that sells or redeems money orders in the course of providing financial services to the public, you are subject to the reporting requirements explained in this guideline.

If you are an agent of the Crown that accepts deposit liabilities in the course of providing financial services to the public, such as a provincial savings office, you are considered a financial entity (see subsection 2.1).

If you are an agent of the Crown that sells precious metals to the public, you are considered a dealer in precious metals and stones (see subsection 2.9).

2.6 Accountants and accounting firms

An accountant means a chartered accountant, a certified general accountant or a certified management accountant. An accounting firm means an entity that is in the business of providing accounting services to the public and that has at least one accountant who is a partner, an employee or an administrator.

If you are an accountant or an accounting firm, you are subject to the reporting requirements explained in this guideline when conducting any of the following activities on behalf of any individual or entity (other than your employer) or giving instructions in respect of those activities on behalf of any individual or entity (other than your employer):

  • receiving or paying funds;
  • purchasing or selling securities, real property or business assets or entities; or
  • transferring funds or securities by any means.

You are not subject to these obligations for the receipt of professional fees. This means that the receipt of professional fees does not trigger your obligations. However, you are subject to the reporting requirements when you engage in any of the activities mentioned above, regardless of whether or not you received any fees or have a formal letter of engagement to do so. In other words, you are subject to the obligations even if you were doing the activities on a volunteer basis.

Activities of accountants or accounting firms other than those listed above, such as audit, review or compilation engagements carried out according to the recommendations in the Canadian Institute of Chartered Accountants (CICA) Handbook, do not trigger reporting obligations.

Giving advice to a client, in the context of your accountant-client relationship, is not considered providing instructions. If you need further clarification about this, refer to FINTRAC Interpretation Notice No. 2, available under "General Publications" on the Publications page of FINTRAC's Web site (http://www.fintrac-canafe.gc.ca).

Providing bankruptcy services or acting as an insolvency practitioner does not trigger reporting obligations. If you need further clarification about this, refer to FINTRAC Interpretation Notice No. 7, available under "General Publications" on the Publications page of FINTRAC's Web site.

2.7 Real estate

Real estate brokers or sales representatives

Real estate brokers or sales representatives are individuals or entities that are registered or licensed in a province to sell or purchase real estate. They are subject to the reporting requirements explained in this guideline when they act as an agent regarding the purchase or sale of real estate. This includes the buying or selling of land, buildings, houses, etc. Such activities trigger these obligations whether or not the real estate broker or sales representative gets a commission for the real estate transaction and whether or not they have fiduciary duties regarding it.

If you are a real estate broker or sales representative, these obligations do not apply to you for activities related to property management. This means that if you only deal in property management transactions, such as leases or rental management, not purchases or sales, the obligations explained in this guideline do not apply to you.

Real estate developers

A real estate developer means an individual or an entity other than a real estate broker or sales representative, who in any calendar year after 2007 has sold one of the following to the public:

  • at least five new houses or condominium units;
  • at least one new commercial or industrial building;
  • at least one new multi-unit residential building each of which contains five or more residential units; or
  • at least two new multi-unit residential buildings that together contain five or more residential units.

If you are a real estate developer, you are subject to the reporting requirements when you sell any of the following to the public:

  • a new house;
  • a new condominium unit;
  • a new commercial or industrial building; or
  • a new multi-unit residential building.

If you are an entity that is a corporation, you are subject to this whether you sell those buildings on your own behalf or on behalf of a subsidiary or affiliate. In this context, an entity is affiliated with another entity if one of them is wholly-owned by the other or both are wholly-owned by the same entity.

2.8 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.

2.9 Dealers in precious metals and stones

A dealer in precious metals and stones (DPMS) means an individual or an entity that buys or sells precious metals, precious stones or jewellery, in the course of its business activities. Precious metals include gold, silver, palladium or platinum whether in coins, bars, ingots, granules or in any other similar form. Precious stones include diamonds, sapphires, emeralds, tanzanite, rubies or alexandrite. Jewellery means objects made of precious metals, precious stones or pearls intended for personal adornment. 

If you are a DPMS, you are subject to the reporting requirements explained in this guideline if you engage in the purchase or sale of precious metals, precious stones or jewellery in an amount of $10,000 or more in a single transaction. However, you are not subject to the reporting requirements when you engage in a purchase or sale carried out for, in connection with, or for the purpose of manufacturing jewellery, extracting precious metals or precious stones from a mine or cutting or polishing precious stones.

An agent of the Crown (that is, a government department or an agent of her Majesty in right of Canada or of a province) is considered to be a DPMS when it sells precious metals to the public in an amount of $10,000 or more in a single transaction.

2.10 British Columbia notaries

A British Columbia notary means a British Columbia notary public or a British Columbia notary corporation. In this context, a notary public means an individual who is a member of the Society of Notaries Public of British Columbia. Also in this context, a notary corporation means an entity that provides notary services to the public in British Columbia under the Notaries Act of that province.

If you are a British Columbia notary, you are subject to the reporting requirement explained in this guideline when you engage in any of the following activities on behalf of any individual or entity (other than your employer), or give instructions on behalf of any individual or entity (other than your employer):

  • receiving or paying funds (other than those received or paid for professional fees, disbursements, expenses or bail);
  • purchasing or selling securities, real property or business assets or entities; or
  • transferring funds or securities by any means.

2.11 Employees of a reporting entity

For the purposes of suspicious transactions only, an employee of any of the reporting entities described above is also a "reporting entity". This requires you to make a report to FINTRAC about a suspicious transaction unless you reported it to your superior.

If you are an employee and you have to submit a suspicious transaction report on your own behalf (that is, not on behalf of your employer), refer to Guideline 3B: Submitting Suspicious Transaction Reports to FINTRAC by Paper.

3. Suspicious Transaction Reporting Requirements

3.1 Electronic reporting enrolment

As a reporting entity, 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 7.

3.2 Suspicious transaction reporting timelines

If you are a reporting entity as described in section 2, you have to send a suspicious transaction report to FINTRAC when there are reasonable grounds to suspect that a transaction or an attempted transaction is related to the commission or the attempted commission of a money laundering offence or a terrorist financing offence.

There is no minimum threshold amount for reporting a suspicious transaction. Guideline 2: Suspicious Transactions has more information on how to identify a suspicious transaction.

You have to submit suspicious transaction reports to FINTRAC, containing specific information (see section 5). Once you have determined that there are reasonable grounds to suspect that the transaction or attempted transaction is related to a money laundering or terrorist financing offence, your report, including all required and applicable information, must be sent within 30 calendar days.

This 30–day reporting time limit begins when you or any one of your employees first detects a fact about a transaction that constitutes reasonable grounds to suspect that it is related to the commission of a money laundering or terrorist financing offence. If such a fact is detected at the time of the transaction, the reporting timeline begins at the time of the transaction. However, if the fact is not detected at the time of the transaction, the 30–day time limit could begin at some time after. For example, if the fact were detected during a review by corporate security after the transaction took place, the 30–day time limit would begin when corporate security first detected the fact.

3.3 Other reports

Information about other reporting requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act that apply to reporting entities can be found in the following guidelines:

  • Guideline 5: Submitting Terrorist Property Reports to FINTRAC
  • Guideline 7: Submitting Large Cash Transaction Reports to FINTRAC
  • Guideline 8: Submitting Electronic Funds Transfer Reports to FINTRAC
  • Guideline 10: Submitting Casino Disbursement Reports to FINTRAC

3.4 Means of reporting to FINTRAC

Electronic reporting

As a reporting entity, you have to submit all reports on suspicious transactions 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

See section 4 for more information on submitting reports to FINTRAC electronically.

Exception for employees and suspicious transaction reports

If you are an employee of a reporting entity, you are a "reporting entity" yourself, for the purposes of suspicious transactions only. This requires you to make a report to FINTRAC about a suspicious transaction unless you reported it to your superior. In this situation, if you need to make a report about a suspicious transaction that you did not report to your superior, you are considered not to have the technical capabilities to report electronically. This means you must submit this type of report by paper, as explained below.

This exception does not apply if you are submitting a suspicious transaction report on behalf of your employer or anyone else that is a reporting entity.

Paper reporting

If you do not have the technical capabilities to send reports electronically, you must submit reports on paper. See Guideline 3B: Submitting Suspicious Transaction Reports to FINTRAC by Paper.

3.5 Information to be contained in a suspicious transaction report

Your suspicion about there being a relation to a money laundering or a terrorist financing offence may be as a result of more than one transaction. In this case, include all the transactions that contributed to your suspicion in the same report.

By completing all applicable fields in your reports, you make an important contribution to FINTRAC's ability to isolate activity pointing to possible money laundering or terrorist activity financing. In the case of a suspicious transaction report, your detailed explanation of what led to the suspicion is also extremely important to FINTRAC's analysis.  

See section 5 and Appendix 1 for more information about what has to be included in a suspicious transaction report.

3.6 Suspicious transaction report records

When you have to report a suspicious transaction 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 (see subsection 4.1).

4. Electronic Reporting

4.1 Options for electronic reporting

As a reporting entity, you have to report suspicious transactions electronically to FINTRAC if you have the technical capabilities to do so (see subsection 3.4).

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 requires more advanced technical capability than explained in subsection 3.4.

4.2 How to complete electronic reports

Reporting through F2R

F2R contains the suspicious transaction 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 suspicious transaction 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 Standard Batch Reporting Instructions and Specification for more information about how to report suspicious transactions through batch file transfer. This document is available from the technical documentation area of the Publications page on FINTRAC's Web site (http://www.fintrac-canafe.gc.ca). You can also refer to Appendix 1 of this guideline for instructions regarding the content of fields in a suspicious transaction report.

4.3 Acknowledgement of receipt of an electronic report

FINTRAC will send you an acknowledgement message when your suspicious transaction 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.

4.4 Report corrections

If you need to request a suspicious transaction report for change in F2R, you will do so based on the acknowledgement for that report.

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 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 Standard Batch Reporting Instructions and Specification and the documents about FINTRAC's electronic reporting enrolment and use of F2R.

5. Instructions for Completing a Suspicious Transaction Report

5.1 General instructions

Instructions for the fields of the Suspicious Transaction Report screens are contained in Appendix 1. Additional instructions in Appendix 2 relate to navigation through the reporting screens on F2R.

The instructions in Appendices 1 and 2 are based on the reporting screens through F2R. However, the information about how to complete the fields can also be useful to those completing suspicious transaction reports through batch file transfer. If you report through batch, you need to refer to the Standard Batch Reporting Instructions and Specification in addition to Appendix 1.

As explained in subsection 3.4, if you do not have the capability to report electronically, refer to Guideline 3B: Submitting Suspicious Transactions to FINTRAC by Paper for more information.

Fields in reports are either mandatory, mandatory where applicable, or require "reasonable efforts" to complete, as follows: 

  • Mandatory: All fields of a report marked with an asterisk (*) have to be completed.
  • Mandatory where applicable: The fields that have both an asterisk and "where 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.

5.2 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 Publications page of FINTRAC's Web site (http://www.fintrac-canafe.gc.ca).

You can get to F2R from the reporting section of FINTRAC's main Web site (http://www.fintrac-canafe.gc.ca). If you are authorized to complete suspicious transaction 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 5.4 contains instructions for submitting a change to a previously submitted report.

5.3 Instructions for submitting a new report

There are nine parts on the Suspicious Transaction Report form, but some are only to be completed if the part is applicable.

See Appendix 1 for instructions about the fields in each part of the report. If you use F2R, Appendix 2 provides additional instructions regarding navigation through the reporting screens. If you report through batch, you should also refer to the Standard Batch Reporting Instructions and Specification.

5.4 Instructions for submitting a change to a previously submitted report

If you have to submit a change to a previously submitted suspicious transaction 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 30 calendar days of your having reasonable grounds to suspect, as explained in subsection 3.2.

If you report through batch, refer to the technical documentation called Standard Batch Reporting Instructions and Specification to find out how to submit changes for previously submitted reports by batch. If you choose to do this through F2R instead of by batch, read subsection 5.5. That choice means that you cannot submit changes by batch.

If you report through F2R, read subsection 5.5.

5.5 Submitting changes through F2R

If you need to change a suspicious transaction 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 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 correction made and provide a reason for the change.

Remember that you must provide any required changes to FINTRAC within the 30-calendar-day reporting deadline for the report.

6. 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.

7. 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