FINTRAC interpretation notices and policy interpretations
The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) issues FINTRAC interpretation notices (FINs) and policy interpretations to provide technical interpretations and positions regarding certain provisions contained in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations. For those readers who prefer a less technical explanation of the law, FINTRAC's guidance is designed to provide a plain language explanation of the Act and associated Regulations.
FINs and policy interpretations do not have the force of law.
FINTRAC Interpretation Notices
While FINs may make reference to provisions of the law in force at the time they were written, they are not a substitute for the law.
- Criteria for "Engaged in a Money Services Business"
- Accountants – Giving Instructions Versus Providing Advice
- Opening an Account for a Person or Entity Engaged in the Business of Dealing in Securities Only Outside of Canada
- The 24-Hour Rule
- Large Cash Transactions through Automated Banking Machines
- Financial Transaction Reporting to FINTRAC by Reporting Entities that are Part of a Multiple-Entity Organizational Structure
- Insolvency Practitioners Providing Trustee in Bankruptcy Services
FINTRAC Policy Interpretations
FINTRAC has been providing policy interpretations to persons and entities with obligations under the Act and associated Regulations since 2008. Policy interpretations are based solely on the information provided to FINTRAC and may be subject to change if additional information becomes available. They are provided as general information. They are not legal advice, and are not intended to replace the Act and associated Regulations.
Each policy interpretation reflects the requirements of the PCMLTFA and associated Regulations in force at the time they were written. Legislative and regulatory amendments may have taken place since the policy interpretation was issued that may impact the determination made at the time. Therefore, please take note of the date each policy interpretation request was answered.
- Beneficial Ownership
- Business Relationship
- Compliance Program
- Correspondent banking
- Money services business / Foreign money services business
- Ongoing Monitoring
- Politically Exposed Persons or Heads of an international organization
- Record Keeping
- Third Party Determination
- Verifying Identity
- EFTs – pre-authorized debits and direct deposits
- PEP – source of cash or funds
- PEP – Members of the same board
- Real estate – life lease
- Real estate – FE as executor to the property
- Accountants – When are there requirements?
- Life insurance group plans – verifying identity
- Government-issued photo ID – valid and current according to its issuer
- Extracting precious metals or stones
- Life insurance – EFT reporting
- Foreign MSB – Representative for service considerations
- Life insurance – ongoing monitoring of low risk clients
- Date Modified: