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

June 2011

This replaces the previous version of Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC issued in September 2008. 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 an Electronic Funds Transfer Report to FINTRAC?
  3. Electronic Funds Transfer Reporting Requirements
  4. Electronic Reporting
  5. Instructions for Completing a SWIFT Electronic Funds Transfer Report
  6. Comments?
  7. How to Contact FINTRAC

Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC (PDF version, 246 KB) PDF

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 an individual or entity described in section 2, this guideline has been prepared to help you submit electronic funds transfer (EFT) 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: 

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. Who Has to Send an Electronic Funds Transfer Report to FINTRAC?


If you are one of the following individuals or entities (called reporting entities), you must report EFTs 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 EFT reporting requirement does not apply to their operations outside Canada.

2.2 Money services businesses

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

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.

2.3 Casinos

Casinos have to report EFTs to FINTRAC. However, this guideline is about SWIFT EFTs and does not apply for casinos. If you are a casino, read Guideline 8A: Submitting non-SWIFT Electronic Funds Transfer Reports to FINTRAC Electronically.

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.

3. Electronic Funds Transfer 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 enrolment, contact us as explained in section 7.

3.2 When do you have to report electronic funds transfers?

If you are a reporting entity as described in section 2, you have to report incoming and outgoing international electronic funds transfers (EFTs) of $10,000 or more to FINTRAC no later than five working days after the day of the transmission of the instructions (see subsection 3.6). This guideline explains the reporting requirements related to SWIFT EFTs for financial entities or money services businesses. If you are a casino, or you are a financial entity or a money services business and you send EFTs other than those explained below, read Guideline 8A: Submitting non-SWIFT Electronic Funds Transfer Reports to FINTRAC Electronically.

3.3 SWIFT electronic funds transfers

The incoming and outgoing SWIFT EFT reporting requirement is only applicable to you if you are a financial entity or a money services business. Furthermore, it only applies if you send or receive EFTs by transmission of a SWIFT MT 103 message, as a SWIFT member, through the SWIFT network. SWIFT means the Society for Worldwide Interbank Financial Telecommunication. It is a co-operative owned by the international banking community that operates a global data processing system for the transmission of financial messages.

You have to send a SWIFT EFT report to FINTRAC for the following transactions:

Outgoing EFTs

These are SWIFT MT 103 messages for $10,000 or more sent outside Canada at the request of a client in the following manner:

This type of EFT requires that you send an outgoing SWIFT EFT report to FINTRAC. These reports can only be sent electronically, by batch, as explained in section 4.

It can happen that a client requests a transfer of funds and, instead of sending the EFT yourself, you order someone else that is a financial entity, a money services business or a casino in Canada to send it. In this case, you have to make the related non-SWIFT EFT report (EFTO) to FINTRAC unless you provide that other reporting entity with the client's name and address. In other words, if you give them your client's name and address, you do not have to report the EFT. See Appendix 2 for example scenarios of this type of situation.

If you send an EFT to an individual or entity in Canada, you do not have to report it, even if the final recipient of the funds is outside Canada.

Incoming EFTs

These are SWIFT MT 103 messages for $10,000 or more that you receive and that are sent from outside Canada at the request of a client in the following manner:

This type of EFT requires that you send an incoming SWIFT EFT report to FINTRAC. These reports can only be sent electronically, by batch, as explained in section 4.

If you are a financial entity, a money services business or a casino and you received instructions for a transfer of funds from outside Canada, you have to make the related incoming EFT report to FINTRAC, even if you have to forward the same instructions to another financial entity, money service business or casino in Canada. However, if you receive instructions for a transfer of funds from outside Canada from another financial entity, money services business or casino in Canada, you do not have to make an incoming EFT report, as long as the EFT contained the name and address of the beneficiary. If the EFT did not contain the name and address of the beneficiary and the original sender was outside Canada, you also have to make an incoming EFT report. This is true even if you do not get a copy of the instructions received by the other financial entity, money services business or casino.

See Appendix 2 for example scenarios of this type of situation.

Exception to the 24-hour rule for EFTs

The following exception applies if you send or receive a bundled EFT, that is an EFT with more than one beneficiary. The 24-hour-rule will not apply for any of the amounts under $10,000 included in a bundled EFT if it was sent at the request of a public body, a very large corporation, or the administrator of a federally or provincially regulated pension fund.

In this context, a public body means any of the following or their agent:

Also in this context, a very large corporation is one that has minimum net assets of $75 million on its last audited balance sheet. The corporation’s shares have to be traded on a Canadian stock exchange or on a stock exchange outside Canada that is designated by the Minister of Finance. The corporation also has to operate in a country that is a member of the Financial Action Task Force (FATF). For more information about stock exchanges outside Canada that are designated by the Minister of Finance, refer to the July 2, 2008 news release available in the News area of the Department of Finance’s Web site (http://www.fin.gc.ca).

To find out which countries are members of the FATF, refer to its Web site (http://www.fatf-gafi.org).

3.4 Electronic funds transfers in foreign currency

If you send or receive an EFT in a 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 to FINTRAC. For this purpose only, use the last noon exchange rate provided by the Bank of Canada available at the time of the transaction, instead of the actual exchange rate used to process the transaction. This calculation is only to check whether the $10,000 threshold is met for the transaction to be reportable as an EFT transaction.

For example, for an EFT that happened at 9:00 am on Tuesday following a holiday Monday, you would use the Bank of Canada noon rate from the previous working day (in this case, Friday) to determine whether the transaction is reportable. You can find the noon rate 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 transaction to determine whether it is reportable.

Once you have determined that an EFT in a foreign currency is reportable based on the Bank of Canada noon rate, you will have to send an EFT report to FINTRAC. On the EFT report in Part A, enter the amount of the transaction in the foreign currency. If you converted this amount to or from Canadian dollars when you processed the transaction (other than using the Bank of Canada noon rate to determine whether or not it was reportable), enter the actual exchange rate you used to process the EFT in Part A of the report.

3.5 Other requirements associated with electronic funds transfers

In addition to the reporting requirements explained in this guideline, consider the following relating to an EFT transaction:

Record keeping and client identification

EFTs have associated record keeping and client identification requirements. These are explained in Guideline 6: Record Keeping and Client Identification.

Originator information to include with transfers

If you send or receive an EFT of any amount, at the request of a client, there are obligations about originator information included with the transfer. For more details about this, see Guideline 6: Record Keeping and Client Identification.

Large cash transaction report

If an EFT transaction is initiated in cash, in the amount of $10,000 or more, you will likely have to make a large cash transaction report to FINTRAC in addition to making the EFT report about the transaction as required. 

For more information about making large cash transaction reports, consult Guideline 7: Submitting Large Cash Transaction Reports to FINTRAC.

Suspicious transaction report

If anything about an EFT transaction 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 about the same transaction. This would be in addition to making the EFT report about the transaction as required.

The suspicious transaction report has many fields that are different from those of an EFT report. For example, there is 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 an EFT report for the same transaction (if that is the case).

For more information about making suspicious transaction reports, consult the following guidelines:

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 should not 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 guidelines:

Casino disbursement report

If you are a casino sending an EFT that is part of a casino disbursement (in the amount of $10,000 or more), you will likely have to make a casino disbursement report to FINTRAC in addition to making the EFT report about the transaction as required. For more information about making casino disbursement reports, consult Guideline 10: Submitting Casino Disbursement Reports to FINTRAC.

3.6 Reporting timeframes for electronic funds transfer reports

You have to send EFT reports to FINTRAC no later than five working days after the day of the transfer. The day of the transfer means:

4. Electronic Reporting


4.1 SWIFT EFT reporting

SWIFT EFT reports can only be sent to FINTRAC electronically, by batch. These reports cannot be made on paper.

4.2 How to complete electronic reports

To use the Batch reporting mechanism, you need a public key infrastructure (PKI) certificate and specialized software available from FINTRAC. For more information about batch reporting SWIFT EFTs, consult the specifications document called Standard Batch Reporting Instructions and Specification.  Also refer to the Appendix 1 of this guideline for instructions and details regarding the content of a SWIFT EFT report.

4.3 Acknowledgement of receipt of an electronic report

FINTRAC will send you an acknowledgement message when your EFT report has been received electronically. This will include the date and time your report was received and the identification number for your report. Please keep this information for your records.

For SWIFT EFT reports, 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.

4.4 Report corrections

If your EFT report contains incomplete information, FINTRAC may notify you. The notification will indicate the date and time your report was received, the identification number for the report, along with information on the fields that must be completed or corrected.

After receiving FINTRAC’s notification, you should provide the necessary information to FINTRAC within the five–working–day reporting deadline. In other words, this information should be sent to FINTRAC within five working days of the transfer (see subsection 3.6). Your obligation to report will not be fulfilled until you send the complete report to FINTRAC.

For more information about this, refer to the SWIFT Batch Reporting Instructions and Specification.

5. Instructions for Completing a SWIFT Electronic Funds Transfer Report


5.1 General instructions

The contents of a SWIFT EFT report depend on whether the report is about an outgoing or incoming transfer. The required information for each type of report is listed in Appendices 1A and B, as follows:

Based on the reporting requirements for SWIFT EFT reports, information is either mandatory, mandatory where applicable, or requires "reasonable efforts", as follows:

The specifications for SWIFT EFT reports do not reflect the mandatory, mandatory where applicable and reasonable efforts fields in the same manner as your other reports to FINTRAC. The SWIFT EFT report specifications reflect "tags" according to the way information is entered to transmit the EFT message based on the SWIFT network rules. In some cases, those rules can be different from what is required in your report to FINTRAC.

Here are some examples to illustrate this point:

Example 1

If there is an intermediary institution for a SWIFT EFT, your report to FINTRAC must contain either the bank identification code (BIC) or the full name and full address of the intermediary. This information is mandatory, if applicable.

In the SWIFT network rules, intermediary information (tag :56:) is optional. Furthermore, for those messages that do involve an intermediary, the SWIFT network rules provide three options regarding information to be included. However, only two of those options (option A or D) provide the mandatory information for your report to FINTRAC. The other (option C) provides neither the BIC nor the full name and address. This means that a SWIFT EFT message with option C at tag :56: does not provide the mandatory if applicable information for your report to FINTRAC, even if it meets the SWIFT network rules.

Example 2

For your report to FINTRAC, the bank operation code is information that requires reasonable efforts. However, based on the SWIFT network rules, the bank operation code (tag :23B:) is required. This means that you should be providing this information in your report to FINTRAC, because it should be available to you.

For these reasons, tags in the SWIFT EFT report do not use asterisks to demonstrate mandatory fields. The instructions for each tag in the report explain which information is mandatory or mandatory where applicable and which requires reasonable efforts.

If information for a tag that requires reasonable efforts is not available for a particular SWIFT EFT, omit that tag from the report. If a tag with mandatory where applicable information does not apply to the EFT being reported, also omit that tag from the report. In all other cases, you have to provide the tag and the information required. Under no circumstances in a SWIFT EFT report should you indicate that a required tag in a report is not applicable.

As explained in subsection 3.3, EFT reports can be about one of multiple EFTs 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 EFTs were each under $10,000, some of the information that is mandatory for the report may not be available in your records or from the time of the transaction. In this case, "reasonable efforts" applies to this otherwise mandatory information.

You have to complete a separate EFT report for each EFT transaction, even if you are reporting multiple EFTs of less than $10,000.

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 at 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

Appendix 1: Contents of SWIFT Electronic Funds Transfer Reports

Appendix 1A: Contents of an outgoing SWIFT message EFT Report

This Appendix lists the requirements for an outgoing SWIFT message EFT report based on the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations. The mandatory information is shown by an asterisk (*).

For instructions about completing and sending these reports by batch, and for more information about the content of SWIFT tags, see the document called SWIFT format EFT Transactions - Batch Reporting Instructions and Specification.

PART A - Information about the transaction

  1. Time of processing of the transaction (see Tag :13C: in the SWIFT message)
  2. *Value date (see Tag :32A: in the SWIFT message)
  3. *Amount of the EFT (see Tags :32A: and :33B: in the SWIFT message)
  4. *Currency of the EFT (see Tags :32A: and :33B: in the SWIFT message)
  5. Exchange rate (see Tag :36: in the SWIFT message)
  6. Transaction type code (see Tag :26T: in the SWIFT message)

PART B - Information about the client ordering the EFT

  1. *Client's full name (see Tag :50: in the SWIFT message)
  2. *Client's full address (see Tag :50: in the SWIFT message)
  3. *Client's account number, if applicable (see Tag :50: in the SWIFT message)

PART C - Information about the individual or entity sending the EFT

  1. *Bank identification code (BIC) or full name and address of the individual or entity sending the payment instructions for the EFT (see Tag :51A: and the basic header in the SWIFT message as well as the FINTRAC header required for each batch report)

PART D - Information about the individual or entity ordering an EFT on behalf of a client (if applicable)

  1. *Bank identification code (BIC) or full name and address of the ordering institution (if applicable) (see Tag :52: in the SWIFT message)

PART E - Information about the sender's correspondent (if applicable)

  1. *Bank identification code (BIC) or full name and address of the individual or entity (other than the sender) acting as reimbursement bank for the sender of the EFT (if applicable) (see Tag :53: in the SWIFT message)

PART F - Information about the receiver's correspondent (if applicable)

  1. *Bank identification code (BIC) or full name and address of the individual or entity acting as reimbursement bank for the receiver of the EFT (if applicable) (see Tag :54: in the SWIFT message)

PART G - Information about the third reimbursement institution (if applicable)

  1. *Bank identification code (BIC) or full name and address of the EFT receiver's branch, if the funds are made available to the receiver's branch through a financial institution other than the sender's correspondent (if applicable) (see Tag :55: in the SWIFT message)

PART H - Information about the intermediary institution (if applicable)

  1. *Bank identification code (BIC) or full name and address of the financial institution through which the transaction must pass (the financial institution between the receiver and the financial institution where the account is held) (if applicable) (see Tag :56: in the SWIFT message)

PART I - Information about the beneficiary customer account institution (if applicable)

  1. *Bank identification code (BIC) or full name and address of the financial institution that services the account for the beneficiary customer (if this financial institution is not the receiver) (if applicable) (see Tag :57: in the SWIFT message)

PART J - Information about the individual or entity receiving the EFT

  1. *Bank identification code (BIC) or full name and address of the individual or entity receiving the payment instructions (see the application header in the SWIFT message)

PART K - Information about the client to whose benefit payment is made

  1. *Client's full name (see Tag :59: in the SWIFT message)
  2. *Client's full address (see Tag :59: in the SWIFT message)
  3. *Client's account number, if applicable (see Tag :59: in the SWIFT message)

PART L - Additional payment information

  1. Remittance information (see Tag :70: in the SWIFT message)
  2. Details of charges (see Tags :71A: and :71G: in the SWIFT message)
  3. Sender's charges (see Tag :71F: in the SWIFT message)
  4. Sender's reference (see Tag :20: in the SWIFT message)
  5. Bank operation code (see Tag :23B: in the SWIFT message)
  6. Instruction code (see Tag :23E: in the SWIFT message)
  7. Sender-to-receiver information (see Tag :72: in the SWIFT message)
  8. Regulatory reporting (see Tag :77B: in the SWIFT message)
  9. Envelope contents (see Tag :77T: in the SWIFT message)

Note: If the 24-hour rule applies to a SWIFT EFT, and, because of this, information that is mandatory (as indicated above) was not obtained at the time of the transaction (and is not available from the SWIFT message or your records), you can leave the information out of your report to FINTRAC.

Appendix 1B: Contents of an incoming SWIFT message Report

This Appendix lists the requirements for an incoming SWIFT message EFT report based on the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations. The mandatory information is shown by an asterisk (*).

For instructions about completing and sending these reports by batch, see the document called SWIFT format EFT Transactions - Batch Reporting Instructions and Specification.

PART A - Information about the transaction

  1. Time of processing of the transaction (see Tag :13C: in the SWIFT message)
  2. *Value date (see Tag :32A: in the SWIFT message)
  3. *Amount of the EFT (see Tags :32A: and :33B: in the SWIFT message)
  4. *Currency of the EFT (see Tags :32A: and :33B: in the SWIFT message)
  5. Exchange rate (see Tag :36: in the SWIFT message)
  6. Transaction type code (see Tag :26T: in the SWIFT message)

PART B - Information about the client ordering the EFT

  1. Client's full name (see Tag :50: in the SWIFT message)
  2. Client's full address (see Tag :50: in the SWIFT message)
  3. Client's account number, if applicable (see Tag :50: in the SWIFT message)

PART C - Information about the individual or entity sending the EFT

  1. Bank identification code (BIC) or full name and address of the individual or entity sending the payment instructions for the EFT (see Tag :51A: and the application header in the SWIFT message)

PART D - Information about the individual or entity ordering an EFT on behalf of a client (if applicable)

  1. Bank identification code (BIC) or full name and address of the ordering institution (if applicable) (see Tag :52: in the SWIFT message)

PART E - Information about the sender's correspondent (if applicable)

  1. Bank identification code (BIC) or full name and address of the individual or entity (other than the sender) acting as reimbursement bank for the sender of the EFT (if applicable) (see Tag :53: in the SWIFT message)

PART F - Information about the receiver's correspondent (if applicable)

  1. *Bank identification code (BIC) or full name and address of the individual or entity acting as reimbursement bank for the receiver of the EFT (if applicable) (see Tag :54: in the SWIFT message)

PART G - Information about the third reimbursement institution (if applicable)

  1. *Bank identification code (BIC) or full name and address of the EFT receiver's branch, if the funds are made available to the receiver's branch through a financial institution other than the sender's correspondent (if applicable) (see Tag :55: in the SWIFT message)

PART H - Information about the intermediary institution (if applicable)

  1. *Bank identification code (BIC) or full name and address of the financial institution through which the transaction must pass (the financial institution between the receiver and the financial institution where the account is held) (if applicable) (see Tag :56: in the SWIFT message)

PART I - Information about the beneficiary customer account institution (if applicable)

  1. *Bank identification code (BIC) or full name and address of the financial institution that services the account for the beneficiary customer (if this financial institution is not the receiver) (if applicable) (see Tag :57: in the SWIFT message)

PART J - Information about the individual or entity receiving the EFT

  1. *Bank identification code (BIC) or full name and address of the individual or entity receiving the payment instructions (see the basic header in the SWIFT message and the FINTRAC header required for each batch report)

PART K - Information about client to whose benefit payment is made

  1. Client's full name (see Tag :59: in the SWIFT message)
  2. Client's full address (see Tag :59: in the SWIFT message)
  3. Client's account number, if applicable (see Tag :59: in the SWIFT message)

PART L - Additional payment information

  1. Remittance information (see Tag :70: in the SWIFT message)
  2. Details of charges (see Tags :71A: and :71G: in the SWIFT message )
  3. Sender's charges (see Tag :71F: in the SWIFT message)
  4. Sender's reference (see Tag :20: in the SWIFT message)
  5. Bank operation code (see Tag :23B: in the SWIFT message)
  6. Instruction code (see Tag :23E: in the SWIFT message)
  7. Sender-to-receiver information (see Tag :72: in the SWIFT message)
  8. Regulatory reporting (see Tag :77B: in the SWIFT message)
  9. Envelope contents (see Tag :77T: in the SWIFT message)

Note: If the 24-hour rule applies to a SWIFT EFT, and, because of this, information that is mandatory (as indicated above) was not obtained at the time of the transaction (and is not available from the SWIFT message or your records), you can leave the information out of your report to FINTRAC.

Appendix 2: Navigation Through Non-SWIFT EFT Report Screens

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:

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.

SCENARIO 2
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.

Appendix 3: Scenarios for Incoming SWIFT EFT Reports Involving Another Reporting Entity

It can happen that a financial entity or a money services business receives a SWIFT message for a transfer of funds from outside of Canada to a beneficiary in Canada, but has to send the transfer to another reporting entity in Canada that also has to report EFTs. If the message does not include the name and address of the beneficiary, both reporting entities will have to report the EFT to FINTRAC.

EXAMPLE

A European bank, at the request of an individual client in Europe, sends an EFT of $12,000 to be paid to an individual in Canada through a particular money services business (MSB). The European bank sends it through the SWIFT network to a financial entity in Canada, with instructions for payment to a client of the MSB.

For the purposes of this example, neither the client ordering the EFT in Europe nor the beneficiary of the EFT in Canada is acting on behalf of a third party.

Even if the ultimate beneficiary is a client of the MSB, the financial entity must report to FINTRAC, as it is the first to receive the EFT in Canada. Depending on whether or not the name and address of the beneficiary was included in the EFT, the MSB may also have to report to FINTRAC, as explained in the following scenarios.

SCENARIO 1

The EFT contains the name and address of the MSB's client. In this scenario, the MSB does not report to FINTRAC. The financial entity sends an incoming SWIFT message report to FINTRAC, as follows:

SCENARIO 2

The EFT does not contain the name and address of the MSB's client. In this scenario, both the MSB and the financial entity report the incoming EFT to FINTRAC. The financial entity sends an incoming SWIFT message report and the MSB sends an incoming international non-SWIFT EFT report (EFTI) to FINTRAC.

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

SCENARIO 2
Financial entity
Incoming EFTS report
MSB
EFTI report

General information about the transaction (Tags:13C:, :32A:, :33B:, :36: and :26T: from the SWIFT message)

General information about the transaction (Part A)

The financial entity has to provide FINTRAC with the European bank's client's full name and, if applicable, the client's account number. This is provided in Tag :50: from the SWIFT message.

The MSB has to provide FINTRAC with the European bank's client's full name and, if applicable, the client's account number. In addition, if the information is available at the time of the transaction or in the MSB's records, the MSB has to provide the European bank's client's full address, telephone number, date of birth, occupation, identifier and identifier number. (Part B)

Information about the European bank sending the EFT (Tag :51A: and the application header from the SWIFT message)

Information about the European bank sending the EFT (Part C)

Information about ordering client's third party does not apply to this report because the European bank's ordering client is not acting on anyone else's behalf.

Information about ordering client's third party (Part D) does not apply to this report because the European bank's ordering client is not acting on anyone else's behalf.

Information about the financial entity, as the reporting entity (basic header from the SWIFT message and FINTRAC header required for each batch report)

Information about the MSB, as the reporting entity (Part E)

Information about the beneficiary to whose benefit the EFT is sent (Tag :59: in the SWIFT message) is required. In this scenario, as the financial entity does not have the client's name and address, the MSB's full name, full address, and, if applicable, the MSB's account number are to be included in the report.

Information about the beneficiary to whose benefit the EFT is sent (Part F) is required. In this scenario, the MSB must provide its client's full name and, if applicable, the client's account number.

Information about the beneficiary's third party does not apply to this report.

Information about the beneficiary's third party does not apply to this report because the EFT's beneficiary is not acting on anyone else's behalf (Part G).

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: The financial entity in the above scenarios has to take reasonable measures to ensure that the EFT includes originator information. For more information about this requirement for both incoming and outgoing EFTs, see Guideline 6: Record Keeping and Client Identification.

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