Message to all reporting entities in light of COVID-19 (March 25, 2020)

Due to the recent outbreak of COVID-19, FINTRAC understands that businesses (referred to as reporting entities), subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated regulations, may face challenges in meeting their obligations in situations where staff may be reduced or unavailable to do their regular work.

Reporting entities are expected to meet all of their obligations, including in relation to reporting. However, FINTRAC understands that some reporting entities may find themselves in a situation where they are required to reassign and reprioritize their internal resources in response to COVID-19, which may affect their ability to meet certain obligations.

During these challenging times, FINTRAC is committed to working constructively with reporting entities to minimize the impact of ongoing regulatory requirements in relation to the prevention, detection and deterrence of money laundering and terrorist activity financing.

Reporting

When it comes to reporting, priority should be given to submitting suspicious transaction reports (STRs). In exceptional circumstances where a reporting entity may be in possession of critical information related to terrorist activity financing but, for some reason, cannot submit the STR in the usual manner, FINTRAC asks that the report or an email be sent to emergencyreport-declarationurgente@fintrac-canafe.gc.ca, and FINTRAC will contact you.

In other instances where a reporting entity is prevented from reporting or will be reporting late for reasons beyond its control, the entity can submit a voluntary self-declaration of non-compliance to VSDONC.ADVNC@fintrac-canafe.gc.ca, when it has the opportunity to do so. This information will be taken into account in future compliance activities.

Verification of Identity

Provincial governments have to take measures to ensure the health and safety of their employees and all citizens. This may include extending the validity of various government driver, vehicle and carrier products and services that have expired on or after March 1, 2020, so that in-person visits to renewal facilities can be avoided. If a person presents a document or information affected by such a decision, an RE must continue to determine the authenticity of a government-issued photo ID document, but can, until further notice, consider the document or information as valid and current pursuant to its issuing authority, in this case the provincial government. Alternatively, you may wish to consider using another method to verify the identity of the person.

Compliance Assessment and Enforcement

FINTRAC is monitoring the public environment in relation to COVID-19 and has reprioritized its own supervisory work in the current circumstances. For the time being, we will not be contacting reporting entities to initiate new examinations. Other interactions with reporting entities will be limited to situations related to reporting issues, circumstances where reporting entities contact FINTRAC for guidance, and the completion of examinations currently underway.

In addition, FINTRAC recognizes that employees responsible for fulfilling certain obligations may be affected by COVID-19. In cases where there is an impact on a reporting entity’s ability to meet a given obligation, the entity should keep a record indicating why this is the case (for example, a memo outlining reduced staffing levels) and, where possible, include any measures being taken to mitigate the risk of non-compliance.

FINTRAC will also take these circumstances into consideration when assessing a reporting entity’s compliance with the obligations and in taking any subsequent compliance actions, once these activities resume.

Other

Given the current high level of calls related to COVID-19 on the Government of Canada telephone lines, FINTRAC will no longer be offering telephone support for inquiries about the following: compliance obligations, reporting system access issues and MSB registration obligations. For these matters or any other urgent enquiries, please contact your regional compliance officer or send an email to guidelines-lignesdirectrices@fintrac-canafe.gc.ca. For technical assistance, please contact FINTRAC’s Tech Support team at the following email: tech@fintrac-canafe.gc.ca. Note that depending on the volume of requests, you may experience a slower response than normal.

FINTRAC is working closely with regime partners and stakeholders, and is constantly assessing the situation in relation to COVID-19, to ensure that it can continue to protect Canadians and Canada’s financial system, while respecting and supporting reporting entities in these challenging times.

Please refer to this website and FINTRAC’s Twitter site for future updates on our compliance activities and priorities.

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