Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC

Appendix 2: Scenarios for Outgoing SWIFT EFT Reports Involving Another Reporting Entity

It can happen that a client requests a financial entity, a money services business or a casino to transfer funds outside of Canada, and, instead of sending the EFT themselves, they order you to send it. If you send it as a SWIFT message, you have to make a SWIFT related EFT report to FINTRAC.

The entity that orders you to send the EFT will also have to make a non-SWIFT EFT report (EFTO) to FINTRAC, unless they provide you with the client's name and address. The following example provides two different scenarios to explain how the required reports are to be completed in such cases.

EXAMPLE

A client requests a money services business to send an international electronic funds transfer (EFT) of $12,000 from Canada. The money services business does not send the EFT itself, but orders a financial entity to do so. For the purposes of this example, the financial entity sends the EFT as a SWIFT member on the SWIFT network. Also for the purposes of this example, neither the client ordering the EFT from the money services business nor the beneficiary of the EFT is acting on behalf of a third party. Finally, for the purposes of this example, there is no correspondent, no reimbursement or intermediary institution, and no beneficiary customer account institution.

SCENARIO 1

The money services business provides the client's name and address to the financial entity. In this scenario, the money services business does not send an EFTO report to FINTRAC. Only the financial entity must send an outgoing SWIFT EFT report to FINTRAC, as follows:

Part A is for general information about the transaction. This is provided in Tags:13C:, :32A:, :33B:, :36: and :26T: from the SWIFT message.
In Part B, the financial entity has to provide FINTRAC with the information about the money services business' client, as provided by the money services business. This is provided in Tag :50: from the SWIFT message.
Part C is for information about the financial entity, as the reporting entity. This is provided in Tag :51A: and the basic header from the SWIFT message as well as in the FINTRAC header required for each batch report.
Part D applies to this report because the money services business is ordering the EFT on a client's behalf. The financial entity will provide information about the money services business, in Tag :52: from the SWIFT message.
Parts E to I do not apply, as there are no correspondents, no reimbursement or intermediary institutions, and no beneficiary customer account institution.
Part J is for information about the individual or entity outside Canada who will be receiving the EFT instructions. It is about the bank or other type of financial service provider who will receive the EFT instructions to provide payment to the beneficiary. This is provided in the application header from the SWIFT message.
Part K is for information about the beneficiary to whose benefit the EFT is sent. This is provided in Tag :59: from the SWIFT message.
Part L is for additional payment information provided in Tags :20:, :23B:, :23E:, :70:, :71A:, :71F:, :71G:, :72:, :77B:, and :77T: from the SWIFT message.

SCENARIO 2

The money services business does not provide the client's name and address to the financial entity. In this scenario, the money services business and the financial entity must both report the EFT to FINTRAC. The money services business must send an outgoing non-SWIFT EFT report (EFTO), and the financial entity must send an outgoing SWIFT EFT report.

The following table shows the similarities and differences for the two reports.

Money services business' EFTO report (non-SWIFT)	Financial entity's outgoing SWIFT EFT report
General information about the transaction (Part A)	General information about the transaction (Tags :13C:,:32A:, :33B:, :36: and :26T)
The money services business has to provide FINTRAC with the client's full name and full address, along with the rest of the information about their client (Part B).	The financial entity has to provide FINTRAC with information about the money services business, as the money services business is the client ordering the EFT from the financial entity in this context (Tag :50:).
Information about the money services business, as the reporting entity (Part C)	Information about the financial entity, as the reporting entity (Tag :51A: and the basic header in the SWIFT message as well as the FINTRAC header required for each batch report)
Information about ordering client's third party (Part D) does not apply to this report because the money services business' client is not ordering the EFT on anyone else's behalf.	Information about ordering client's third party does not apply to this report because the money services business is not providing information about their client to the financial entity and the money services business is required to provide that information in their own report to FINTRAC.
Information about the individual or entity outside Canada who will be receiving the EFT instructions (Part E). This is not about the financial entity that is being ordered to send the EFT. It is about the bank or other type of financial service provider outside Canada who will receive the EFT instructions to provide payment to the beneficiary.	Information about the individual or entity outside Canada who will be receiving the EFT instructions is required. This is about the bank or other type of financial service provider outside Canada who will receive the EFT instructions to provide payment to the beneficiary (application header in the SWIFT message).
Information about the beneficiary to whose benefit the EFT is sent (Part F)	Information about the beneficiary to whose benefit the EFT is sent (Tag :59:)
Information about the beneficiary's third party does not apply to this report because the beneficiary is not acting on anyone else's behalf (Part G)	Information about the beneficiary's third party does not apply to this report
	Other SWIFT tags may apply according to additional payment information in the SWIFT message for which there is no equivalent in a non-SWIFT report.

Note: For information about the contents of the financial entity's report if the EFT were sent as other than a SWIFT message, refer to the scenarios explained in Guideline 8A: Submitting non-SWIFT Electronic Funds Transfer Reports to FINTRAC Electronically.