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Guideline 10A: Submitting Casino Disbursement Reports to FINTRAC Electronically

As of June 1, 2021:

Overview

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 casinos.

You have legislative requirements under the PCMLTFA if you are a casino. A casino is an entity that is authorized to do business in Canada if it is:

  • located at a fixed place of business that includes games of roulette or card games; or
  • located at a fixed place of business, where there are more than 50 slot machines or similar electronic games in the establishment. This could include a place of business such as a restaurant that has these electronic gaming machines; or
  • accessible to the public through the Internet or other digital network. This does not include an entity if it is solely offering online bingo or the sale of lottery tickets.

A registered charity authorized to carry on business in a casino for a period of two consecutive days or less, under the supervision of the casino, is not considered to be a casino.

In Canada, the provincial and territorial governments delegate which entity is legally responsible, and can therefore conduct and manage the gaming activities at a casino. The reporting entity subject to the Act, is the entity that is authorized by the province to conduct and manage a casino.

If you are a casino, this guideline has been prepared to help you submit casino disbursement 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.

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 websites. FINTRAC is not responsible for the accuracy or reliability of the information contained on those external websites. 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.

Who is this guidance for

  • Casinos

In this guidance

  1. Overview
  2. Casino Disbursement Reporting Requirements
  3. Electronic Reporting
  4. Instructions for Completing a Casino Disbursement Report
  5. Comments?
  6. How to Contact FINTRAC
  7. Appendix 1: Field-by-Field Instructions for a Casino Disbursement Report by Batch
  8. Appendix 2: Examples of Reasons and Methods for Casino Disbursement Reports

Related guidance

2. Casino Disbursement Reporting Requirements

2.1 Electronic reporting enrolment

You have to be enrolled with FINTRAC's electronic reporting system to report electronically. For more information about FINTRAC's electronic reporting system enrolment, contact us as explained in section 6.

2.2 When does a casino disbursement report have to be made?

You have to send a casino disbursement report to FINTRAC in the following situations:

In the context of casino disbursement reports, only disbursements that you pay out in the following types of transactions must be reported:

This includes amounts paid out in cash, by cheque, by transfer or many other methods, but it only includes amounts paid out to a casino client or patron and only if they were paid out for the types of transactions listed above. However, in this context, disbursements exclude any amounts that you pay out in casino chips, tokens or slot tickets.

A disbursement does not include the following:

If you pay out such an amount, it is not a reportable disbursement. However, if you conduct a single transaction in which you pay out an amount that covers both a reportable disbursement and a non-reportable payment, you will have to submit a casino disbursement report. For example, if you redeem $18,000 in chips for a client by issuing a cheque to the client for $10,000 and depositing the rest ($8,000) to the client's front money account, you would be required to report this transaction in a casino disbursement report. In this case, the reason for disbursement in the report would reflect the total amount of chips presented for redemption, but the method of disbursement would not include the deposit to the front money account.

In this example, if the disbursement cheque issued were less than $10,000, the transaction would not be reportable (unless you knew of other disbursements of less than $10,000 for the 24 hour rule to apply).

A casino disbursement report is required when both the reason and the method of a disbursement equal $10,000 or more. For examples to illustrate this, refer to Appendix 2.

You have to send a casino disbursement report to FINTRAC within 15 calendar days after the disbursement.

2.3 Disbursements in foreign currency

If a disbursement is in 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. For this purpose only, use the last rate provided by the Bank of Canada available at the time of the transaction. This calculation is not based on the actual exchange rate used to process the transaction — this is only to check whether the $10,000 threshold is met for the transaction to be reportable.

For example, for a disbursement in foreign currency that happened at 9:00 a.m. on Tuesday following a holiday Monday, you would use the Bank of Canada rate from the previous Friday to determine whether it is reportable. You can find the rate applicable at the time of a transaction on the Bank of Canada website at https://www.bankofcanada.ca/rates/exchange/. If there is no Bank of Canada rate published for the currency of the transaction, use the actual exchange rate applied when you processed the disbursement to determine whether it is reportable.

Once you have determined that a disbursement in foreign currency is in fact reportable based on the Bank of Canada rate, you will have to send a casino disbursement report to FINTRAC. On this report, you will indicate any amounts involved in the transaction in foreign currency, and indicate the appropriate currency code. You are not required to provide information about any exchange rate applicable to the transaction in the casino disbursement report. The exchange rate is only relevant to determine whether or not the transaction is reportable.

2.4 Other requirements associated with casino disbursements

In addition to the reporting requirements explained in this guideline, consider the following relating to a casino disbursement:

Record keeping and client identification

You have to keep a copy of each casino disbursement report you send to FINTRAC. In addition, casino disbursements have client identification and other associated record keeping requirements, such as third party determination.

Electronic funds transfer report

If a casino disbursement involves an electronic funds transfer, you may have to make an electronic funds transfer report to FINTRAC about the same transaction in addition to the casino disbursement report.

For more information about making electronic funds transfer reports, consult Guideline 8: Submitting Electronic Funds Transfer Reports to FINTRAC.

Suspicious transaction report

If anything about a casino disbursement 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. This would be in addition to making the casino disbursement report about the same transaction as required.

Furthermore, if a disbursement is attempted but not completed, a casino disbursement report is not required. However, if the attempted disbursement 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.

The suspicious transaction report has many similar fields to those of a casino disbursement report, although the order of some parts is different. There are other differences, such as 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 a casino disbursement report for the same transaction (if that is the case).

For more information about suspicious transaction reports, consult STR guidance.

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 cannot 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:

2.5 Means of reporting to FINTRAC

Electronic reporting

See sections 3 and 4 for more information on submitting reports to FINTRAC electronically.

Paper reporting

If you do not have the technical capabilities to send reports electronically, you must submit reports on paper. See Guideline 10B: Submitting Casino Disbursement Reports to FINTRAC by Paper for more information.

2.6 Casino disbursement report records

When you have to report a casino disbursement to FINTRAC, you have to keep a copy of the report.

If you use FINTRAC web reporting 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.

3. Electronic Reporting

3.1 Minimum technical capabilities

You will have to submit all casino disbursement reports to FINTRAC electronically if you have the technical capabilities to do so. The minimum technical capabilities are as follows:

3.2 Options for electronic reporting

There are two options for electronic reporting:

Both options provide for secure encrypted transmission to ensure data confidentiality and integrity. Reporting through batch will require more advanced technical capability than explained in subsection 3.1.

3.3 How to complete electronic reports

Reporting through FINTRAC web reporting

FINTRAC web reporting contains the casino disbursement reporting screens, with completion instructions. Drop-down menus appear wherever a code or specific selection is required.

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, refer to the Batch reporting page.

Consult the XML Batch Reporting Instructions and Specification for more information about how to report casino disbursements through batch file transfer. You can also refer to Appendix 1 of this guideline for instructions regarding the content of fields in a casino disbursement report.

3.4 Acknowledgement of receipt of an electronic report

FINTRAC will send you an acknowledgement message when your casino disbursement 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 the FINTRAC web reporting system, 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 within the FINTRAC web reporting system and available for viewing or printing.

3.5 Report corrections

If you need to request a casino disbursement report for change in FINTRAC web reporting, you will do so based on the acknowledgement for that report.

In addition, if you send a casino disbursement report that contains incomplete or inaccurate information, FINTRAC may notify you. The notification will indicate the date and time your report was received, a FINTRAC-generated identification number, along with information on the fields that must be completed or corrected.

After receiving FINTRAC's notification, you must provide the necessary information to FINTRAC within the 15-calendar-day reporting deadline. In other words, this information should be sent to FINTRAC within 15 calendar days after the disbursement. Your obligation to report will not be fulfilled until you send the complete report to FINTRAC.

If a correction is required to a report that you sent through FINTRAC web reporting, you will have to make that correction through FINTRAC web reporting.

If a correction is required to a casino disbursement 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 XML Batch Reporting Instructions and Specification.

4. Instructions for Completing a Casino Disbursement Report

4.1 General instructions

Instructions for the fields of the Casino Disbursement Report screens in FINTRAC web reporting are in the system itself.

If you report casino disbursements through batch, you need to refer to the XML Batch Reporting Instructions and Specifications and Appendix 1 for the field-by-field instructions.

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

As explained in subsection 2.2, a casino disbursement report can be about multiple disbursements 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 disbursements were under $10,000, the information for some mandatory fields in the report may not be available in your records or from the time of the disbursement. In this case, "reasonable efforts" applies to those otherwise mandatory fields.

4.2 Accessing the FINTRAC web reporting screens

To access FINTRAC web reporting, reporting entities must first be enrolled in electronic reporting with FINTRAC.

If you are authorized to complete casino disbursement reports, you will be able to select this report type in the FINTRAC web reporting system. 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).

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 4.4 contains instructions for submitting a change to a previously submitted report.

4.3 Instructions for submitting a new report

There are nine parts to the casino disbursement report, but some are only to be completed if the part is applicable. In addition, certain fields will not appear when the information does not apply.

If you report casino disbursements through batch, you should refer to the XML Batch Reporting Instructions and Specifications and Appendix 1.

4.4 Instructions for submitting a change to a previously submitted report

If you have to submit a change to a previously submitted casino disbursement 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 15 calendar days of the disbursement.

If you report casino disbursements through batch, refer to the technical documentation called XML Batch Reporting Instructions and Specifications to find out how to submit changes for previously submitted casino disbursement reports by batch. If you choose to do this through FINTRAC web reporting instead of by batch, read subsection 4.5. That choice means that you cannot submit changes by batch.

If you report through FINTRAC web reporting, read subsection 4.5.

4.5 Submitting changes through FINTRAC web reporting

The following explains how to make a change to a previously submitted casino disbursement report through FINTRAC web reporting:

Change details

Before any change to a report can be submitted to FINTRAC, you have to provide an explanation as to the change made. If it was not requested by FINTRAC, you also have to provide a reason for the change.

Remember that 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 15 calendar days after the disbursement.

5. 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.

6. How to Contact FINTRAC

For further information on FINTRAC and its activities, reporting and other obligations, please go to FINTRAC's Web site (https://fintrac-canafe.canada.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

7. Appendix 1: Field-by-Field Instructions for a Casino Disbursement Report by Batch

The following are instructions regarding the content of fields in a casino disbursement report submitted by batch. For technical information about how to report casino disbursements through batch file transfer, consult the XML Batch Reporting Instructions and Specifications.

Fields in reports are either mandatory, mandatory if applicable, or require “reasonable efforts” to complete, as follows:

In certain circumstances, only as directed in the instructions for certain fields, if you need to indicate that a required field in a report is not applicable, leave the field empty. Do not enter "N/A" or "n/a" or substitute any other abbreviations, special characters (for example, “x”, “-” or “*”) or words (for example, unknown).

Part A: Information about the casino reporting the disbursement

This part is for information about the casino required to report the disbursement to FINTRAC.

Some reporting entities choose to have someone outside their entity transmit their reports to FINTRAC. In this situation, the transmitter is not the reporting entity, nor did they conduct the transaction. Therefore, information about the transmitter would not appear in Part A, unless the reporting entity chooses to have the transmitter be the contact person about the report (fields A4 to A8).

Field A1 24-hour-rule indicator

If this report is about one transaction of $10,000 or more, the code in field A1 should be “0” to indicate that the 24 hour rule does not apply. In this case, the report should only contain one transaction. This means that there should only be one Part B.

If this report is about a transaction that is part of a group of two or more transactions of less than $10,000 each made within 24 consecutive hours of each other that total $10,000 or more, the code in field A1 should be “1” to indicate that the 24 hour rule does apply. In this case, all of the transactions from that group should be included in the same casino disbursement report. This means that the report should contain a distinct Part B (Information about the transaction), with all the other applicable parts, for each transaction of the 24 hour rule group.

Field A2* Reporting entity's identifier number

This field must contain the identifier number assigned to the casino by FINTRAC at enrolment.

If you need to access this report in FINTRAC web reporting after it was submitted by batch, the reporting entity's identifier number will also display at the top right of each screen for this report, along with the full name of the casino.

Field A3 Reporting entity report reference number

A unique report reference number is required for each report submitted for the same casino.

Fields A4*, A5*, A6, A7* and A8 Contact name and telephone number

These fields are for information about the individual FINTRAC can contact for clarification about this report.

Field A4 must contain the individual's last name and field A5 must contain the individual's first name. Field A6 is for any middle initial (if applicable). If there is no middle initial, do not include field A6 or leave it empty.

Field A7 is for the business telephone number, including the area code, of the individual FINTRAC can contact. Include the extension, if applicable, in field A8. If there is no extension, do not include field A8 or leave it empty.

Part B: Information about the transaction

This part is for information about where the transaction took place, as well as how and when it was conducted.

You must make separate casino disbursement reports for each distinct transaction of $10,000 or more.

If you are reporting two or more transactions that were disbursements of less than $10,000 each received by or on behalf of the same individual or entity within 24 consecutive hours of each other that total $10,000 or more, you should group those in the same report. In this case, field A1 (the 24-hour-rule indicator) must contain the code "1" for this report.

Field B1* Reporting entity location number

This field has to contain the location number that represents information about where the transaction took place. Location numbers are maintained by the casino.

For more information about location numbers, contact the casino's FINTRAC web reporting administrator.

If you need to access this report in FINTRAC web reporting after it was submitted by batch, the location name and full address will be displayed in fields B1A to B1E, based on the location number.

Fields B2* and B3 How was the transaction conducted?

Field B2 has to include the appropriate code to show how the transaction was conducted. If the selections provided do not cover this particular transaction, use the code to indicate “Other” and provide details in field B3. In this case, information at field B3 is mandatory. Otherwise, do not include field B3.

Fields B4* and B5 When the disbursement took place

Field B4 must contain the date of the transaction.

Field B5 is for the time of the transaction, using a 24 hour format. For example, “153000” represents 3:30 p.m. Do not include field B5 (or leave it empty) if that information is not available from the moment of the transaction or in the casino's records.

Part C: Information about the individual who requested the disbursement

This part is for information about the individual who requested the disbursement.

If more than one transaction is included under the 24 hour rule, Part C is required for each one.

Fields C1 and C2 Is there a client number assigned by the reporting casino for this individual?

If there is no client number assigned, the code in field C1 should be “2”. This means information for field C2 does not apply. In this case, do not include field C2 or leave it empty.

If there is a client number assigned, the code in field C1 should be “1”. In this case, field C2 is mandatory and must contain the client number issued to the individual who requested the disbursement.

Fields C3*, C4* and C5 Individual's full name

Field C3 must contain the last name of the individual who requested the disbursement. Field C4 must contain the first name. Field C5 is for any middle initial, if applicable. If there is no middle initial, do not include field C5 or leave it empty.

If the disbursement is reportable under the 24 hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for fields C3 and C4 was not obtained at the time of the transaction and is not available from your records, leave these fields empty.

Fields C6* to C10* Individual's full address

Field C6 must contain the street address of the individual who requested the disbursement. This should be the individual's physical address, not a post office box or general delivery address.

Field C7 must contain the name of the town or city and field C8 must contain the country code.

Field C9 must contain the province or state, if one is applicable to this address. If the address country is Canada, the United States or Mexico, use the code from the appropriate code table for province or state (also available on FINTRAC's main website). Otherwise, field C9 should contain the name of the province or state. If there is no province or state applicable, leave field C9 empty.

Field C10 must contain the postal or zip code, if one is applicable to this address. If there is no postal or zip code applicable, leave field C10 empty.

If the disbursement is reportable under the 24 hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for fields C6 to C10 was not obtained at the time of the transaction and is not available from your records, leave these fields empty.

Field C11 Home telephone number

Field C11 is for the home telephone number, including the area code, of the individual who requested the disbursement.

If the number is one from Canada or the United States, provide the area code and local number. This should be in the following format: “999-999-9999”.

If the number is from outside Canada or the United States, provide the country code, city code and local number components. As each of those components can vary in length, use a dash (-) to separate each one. For example, “99-999-9999-9999” would indicate a two-digit country code, a three-digit city code and an eight digit local number.

If the home telephone number was not obtained at the time of the disbursement and is not available from your records, leave this field empty.

Fields C12 and C13 Business telephone number

Field C12 is for the business telephone number, including the area code, of the individual who requested the disbursement. Include the extension if applicable, in field C13. If there is no extension, do not include field C13 or leave it empty.

If the number is one from Canada or the United States, enter the area code and local number. This should be in the following format: “999-999-9999”.

If the number is from outside Canada or the United States, provide the country code, city code and local number components. As each of those components can vary in length, use a dash (-) to separate each one. For example, “99-999-9999-9999” would indicate a two-digit country code, a three-digit city code and an eight digit local number.

If the business telephone number was not obtained at the time of the disbursement and is not available from your records, do not include these fields, or leave them empty.

Field C14* Individual's date of birth

Field C14 must contain the date of birth of the individual who requested the disbursement.

If the disbursement is reportable under the 24 hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for field C14 was not obtained at the time of the transaction and is not available from your records, leave this field empty.

Field C15 Country of residence

Provide the country of permanent residence of the individual who requested the disbursement. Use the country code table.

If the country of residence was not obtained at the time of the disbursement and is not available from your records, leave this field empty.

Fields C16* and C17 Individual's identifier

Field C16 must contain the code to show what document was used to identify the individual who requested the disbursement. If the selections provided do not cover the identifier used, use the code to indicate “Other” and provide details in field C17. In this case, field C17 is mandatory and must be included. Otherwise, do not include field C17.

If the disbursement is reportable under the 24 hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for field C16 was not obtained at the time of the transaction and is not available from your records, leave this field empty.

Field C18* ID Number

Field C18 must contain the number of the document described in field C16 that was used to identify the individual who requested the disbursement.

If the disbursement is reportable under the 24 hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for field C18 was not obtained at the time of the transaction and is not available from your records, leave this field empty.

Fields C19* and C20* Jurisdiction of issue of individual's identifier

Field C19 must contain the country of issue for the document used to identify the individual who requested the disbursement. Use the country code table.

Field C20 must contain the province or state. If the address country is Canada, the United States or Mexico, use the code from the appropriate code table for province or state (also available on FINTRAC's main website). Otherwise, field C20 must contain the name of the province or state. If the document was issued nationally and there was no province or state included in the jurisdiction of issue, leave field C20 empty.

If the disbursement is reportable under the 24 hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for fields C19 and C20 was not obtained at the time of the transaction and is not available from your records, leave these fields empty.

Field C21* Individual's occupation

Field C21 must contain the occupation of the individual who requested the disbursement.

Be as descriptive as possible regarding occupation. Provide information that clearly describes it, rather than use a general term. For example, in the case of a consultant, the occupation should reflect the area of consulting, such as “IT consultant” or “consulting forester”. As another example, in the case of a professional, the occupation should reflect the nature of the work, such as “petroleum engineer” or “family physician”.

If the individual is not employed or engaged in any type of business or profession, provide information that best describes their situation, such as “student”, “unemployed”, “retired”, etc.

If the disbursement is reportable under the 24 hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for field C21 was not obtained at the time of the transaction and is not available from your records, do not include this field or leave it empty.

Field C22 "On behalf of" indicator

Field C22 must indicate whether the individual who received the disbursement did so on anyone else's behalf. This field should contain one of the following codes:

Part D: Information about the entity on whose behalf the disbursement was received (if applicable)

This part only applies if the disbursement was received on behalf of a third party that is an entity. Part D is required if code “2” (on behalf of an entity) is included in field C22.

If you include more than one transaction in this report under the 24 hour rule, you have to include Part D for each one that was received on behalf of an entity.

If the disbursement was not received on behalf of a third party that is an entity, do not include Part D in the report.

Field D1* Full name of entity

Field D1 must contain the full name of the business, corporation, trust or other entity on whose behalf the disbursement was received.

If the disbursement is reportable under the 24 hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for field D1 was not obtained at the time of the transaction and is not available from your records, leave this field empty.

Field D2* Type of business

Field D2 must describe the type of business of the entity on whose behalf the disbursement was received.

If the disbursement is reportable under the 24 hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for field D2 was not obtained at the time of the transaction and is not available from your records, leave this field empty.

Fields D3* to D7* Entity's full address

Field D3 must contain the street address of the business, corporation, trust or other entity on whose behalf the disbursement was received. This should be the entity's physical address, not a post office box or general delivery address.

Field D4 must contain the town or city and field D5 must contain the country. Use the country code table available.

Field D6 must contain the province or state, if one is applicable to this address. If the address country is Canada, the United States or Mexico, use the code from the appropriate code table for province or state (also available on FINTRAC's main website). Otherwise, field D6 should contain the name of the province or state. If there is no province or state applicable, leave field D6 empty.

Field D7 must contain the postal or zip code, if one is applicable to this address. If there is no postal or zip code applicable, leave field D7 empty.

If the disbursement is reportable under the 24 hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for fields D3 to D7 was not obtained at the time of the transaction and is not available from your records, leave these fields empty.

Fields D8 and D9 Business telephone number

Field D8 is for the telephone number, including the area code, of the business, corporation, trust or other entity on whose behalf the disbursement was received. Include the extension if applicable, in field D9. If there is no extension, do not include field D9 or leave it empty.

If the number is one from Canada or the United States, enter the area code and local number. This should be in the following format: “999-999-9999”.

If the number is from outside Canada or the United States, provide the country code, city code and local number components. As each of those components can vary in length, use a dash (-) to separate each one. For example, “99-999-9999-9999” would indicate a two-digit country code, a three-digit city code and an eight digit local number.

If the business telephone number was not obtained at the time of the disbursement and is not available from your records, leave field D8 empty.

Field D10 Is the entity a corporation?

If the code in field D10 is “2”, fields D11 to D13 do not apply. In this case, do not include these fields, or leave them empty.

If the code in field D10 is “1”, provide incorporation information in fields D11 to D13.

Fields D11* to D13* Incorporation information (if applicable)

If the code in field D10 is "1" (in other words, the disbursement was received on behalf of an entity that is a corporation), field D11 must contain the incorporation number. Also, field D12 must contain the country of the incorporation number's jurisdiction of issue. Use the country code table.

If the country is Canada, the United States or Mexico, field D13 must contain the code from the appropriate code table for province or state (also available on FINTRAC's main Web site). Otherwise, field D13 should contain the name of the province or state. If an incorporation number does not exist for the corporation, leave fields D11 to D13 empty. If the incorporation number was issued nationally and there was no province or state included in the jurisdiction of issue, leave field D13 empty.

If the disbursement is reportable under the 24-hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for fields D11, D12 and D13 was not obtained at the time of the transaction and is not available from your records, leave these fields empty.

Fields D14 to D16 Individual(s) authorized to bind the entity or act with respect to the casino account (up to three)

Provide the names of up to three individuals who have authority to bind the entity or conduct transactions through the casino account. For each such individual, field D14 is for the last name, field D15 is for the first name and field D16 is for any middle initial if applicable. If there is no middle initial, do not include field D16 or leave it empty.

Part E: Information about the individual on whose behalf the disbursement was received (if applicable)

This part only applies if the disbursement was received on behalf of a third party that is an individual. Part E is required if code "3" (on behalf of another individual) is included in field C22.

If the individual received the disbursement on his or her own behalf, this part does not apply and should not be included in the report.

If you include more than one transaction in this report under the 24-hour rule, you have to include Part E for each one that was received on behalf of another individual.

Fields E1*, E2* and E3 Individual's full name

Field E1 must contain the last name of the individual on whose behalf the disbursement was received. Field E2 must contain the first name. Field E3 is for any middle initial (if applicable). If there is no middle initial, do not include field E3 or leave it empty.

If the disbursement is reportable under the 24-hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for fields E1 and E2 was not obtained at the time of the transaction and is not available from your records, leave these fields empty.

Fields E4* to E8* Individual's full address

Field E4 must contain the street address of the individual on whose behalf the disbursement was received. This should be the individual's physical address, not a post office box or general delivery address.

Field E5 must contain the name of the town or city and field E6 must contain the country. Use the country code table.

Field E7 must contain the province or state, if one is applicable to this address. If the address country is Canada, the United States or Mexico, use the code from the appropriate code table for province or state (also available on FINTRAC's main Web site). Otherwise, field E7 should contain the name of the province or state. If there is no province or state applicable, leave field E7 empty.

Field E8 must contain the postal or zip code, if one is applicable to this address. If there is no postal or zip code applicable, leave field E8 empty.

If the disbursement is reportable under the 24-hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for fields E4 to E8 was not obtained at the time of the transaction and is not available from your records, leave these fields empty.

Field E9 Home telephone number

Field E9 is for the home telephone number, including the area code, of the individual on whose behalf the disbursement was received.

If the number is one from Canada or the United States, enter the area code and local number. This should be in the following format: "999-999-9999".

If the number is from outside Canada or the United States, provide the country code, city code and local number components. As each of those components can vary in length, use a dash (-) to separate each one. For example, "99-999-9999-9999" would indicate a two-digit country code, a three-digit city code and an eight digit local number.

If the home telephone number was not obtained at the time of the disbursement and is not available from your records, leave this field empty.

Fields E10 and E11 Individual's business telephone number

Field E10 is for the business telephone number, including the area code, of the individual on whose behalf the disbursement was received. Include the extension if applicable, in field E11. If there is no extension, do not include field E11 or leave it empty.

If the number is one from Canada or the United States, enter the area code and local number. This should be in the following format: "999-999-9999".

If the number is from outside Canada or the United States, provide the country code, city code and local number components. As each of those components can vary in length, use a dash (-) to separate each one. For example, "99-999-9999-9999" would indicate a two-digit country code, a three-digit city code and an eight digit local number.

If the business telephone number was not obtained at the time of the disbursement and is not available from your records, do not include these fields or leave them empty.

Field E12 Individual's date of birth

Field E12 is for the date of birth of the individual on whose behalf the disbursement was received.

If the individual's date of birth was not obtained at the time of the disbursement and is not available from your records, leave this field empty.

Field E13 Country of residence

This is for the country of permanent residence of the individual on whose behalf the disbursement was received. Use the country code table.

If the individual's country of residence was not obtained at the time of the disbursement and is not available from your records, leave this field empty.

Fields E14 and E15 Individual's identifier

Field E14 is for the code to show what document was used to identify the individual on whose behalf the disbursement was received. If the selections provided do not cover the identifier used, use the code to indicate "Other" and provide details in field E15. In this case, field E15 is required. Otherwise, do not include field E15.

If information about the individual's identifier was not obtained at the time of the disbursement and is not available from your records, leave these fields empty.

Field E16 ID number

Field E16 is for the number of the document described in field E14 that was used to identify the individual on behalf of whom the disbursement was received.

If information about the individual's identifier was not obtained at the time of the disbursement and is not available from your records, leave this field empty.

Fields E17 and E18 Jurisdiction of issue of individual's identifier

Field E17 is for the country of issue for the document used to identify the individual on whose behalf the disbursement was received. Use the country code table.

Field E18 is for the province or state. If the address country is Canada, the United States or Mexico, use the code from the appropriate code table for province or state (also available on FINTRAC's main Web site). Otherwise, field E18 should contain the name of the province or state. If the document was issued nationally and there was no province or state included in the jurisdiction of issue, leave field E18 empty.

If information about the individual's identifier was not obtained at the time of the disbursement and is not available from your records, leave these fields empty.

Field E19 Individual's occupation

Field E19 is for the occupation of the individual on whose behalf the disbursement was received.

Be as descriptive as possible regarding occupation. Provide information that clearly describes it, rather than use a general term. For example, in the case of a consultant, the occupation should reflect the area of consulting, such as "IT consultant" or "consulting forester". As another example, in the case of a professional, the occupation should reflect the nature of the work, such as "petroleum engineer" or "family physician".

If the individual is not employed or engaged in any type of business or profession, provide information that best describes their situation, such as "student", "unemployed", "retired", etc.

If information about the individual's occupation was not obtained at the time of the disbursement and is not available from your records, do not include this field or leave it empty.

Fields E20 and E21 Relationship of the individual named in Part C to the individual named above

Field E20 is for the code to indicate the relationship of the individual requesting the disbursement to the individual on whose behalf the disbursement was received. If the selections provided do not cover the relationship, use the code to indicate "Other" and provide details in field E21. In this case, field E21 is required. Otherwise, do not include field E21 or leave it empty.

Part F1: Reason for disbursement

This part is for information about why the disbursement was requested.

If you include more than one transaction in this report under the 24-hour rule, you have to include Part F1 for each transaction included the report.

Fields F1-1* and F1-2 Reason for disbursement

Field F1-1 must contain the code indicating the reason for disbursement. Some reasons require the completion of other parts of the report to provide additional information. Common occurrences of these are explained below.

The selections for this field are grouped as follows:

The codes presented for this field are the only ones that can be included in this report. In other words, there is no other category of reportable disbursement.

There could be more than one reason for a particular disbursement transaction. In that case, make sure you include the information for each reason in Part F1. For example, your client could, in the same transaction, request the redemption of slot tickets (reason 1), the reimbursement of travel expenses (reason 2) and the cashing of a traveller's cheque (reason 3). In this case you would include fields F1-1 to F1-7 for each of those three reasons for disbursement. As another example, your client could request that you cash two cheques. In this case you would include fields F1-1 to F1-7 for each cheque as a distinct reason for disbursement.

Field F1-3* Amount

Field F1-3 must contain the amount requested for each reason for disbursement. What was actually disbursed will be explained in Part F2 (Method of disbursement), according to the method (or methods) of disbursement.

The amount should be provided without thousand separators, using a period as decimal notation. For example, $9,000 should be provided as "9000.00".

If this was not in Canadian funds, do not convert it, but provide the currency information in field F1-4. If the disbursement requested was in more than one currency, include fields F1-1 to F1-7 for each currency.

Field F1-4* Currency code

Field F1-4 must contain the type of currency for each amount associated to a reason for disbursement.

Field F1-5 Did the reason for disbursement involve a casino account?

If the code in field F1-5 is "1", provide information about the casino account involved in the disbursement in Part G (Account information). This is only for a casino account held at your casino. If the disbursement involved an account at another casino, this information is required in Part H (Additional information about another individual associated to the disbursement) or Part I (Additional information about an entity associated to the disbursement), as applicable.

If the client named in Part C, the entity named in Part D or the individual named in Part E does have a casino account, but the disbursement did not involve it in any way, code "2" should be in field F1-5.

If the code in field F1-5 is "2", in other words no casino account was involved, for all reasons for disbursement in Part F1 and all methods of disbursement in Part F2, Part G does not apply for this disbursement and should not be included in the report.

Field F1-6 Was there any individual (other than those named in Part C or E of this transaction) associated to the reason for disbursement?

Field F1-6 is to show, for each reason for disbursement, whether any additional information is required other than that already provided in the rest of the report. For example, if you cash a cheque for your client that was payable to another individual who had signed it over to your client, information about that other individual, including information about the account and the financial institution on which the cheque was drawn, would be required in Part H.

If the code in field F1-6 is "1" (that is, there was an individual associated), provide information about the other individual involved in the reason for disbursement in Part H.

If the code in field F1-6 is "2" (that is, there was no individual associated) for all reasons for disbursement in Part F1 and all methods of disbursement in Part F2, Part H does not apply for this transaction and should not be included in the report.

Field F1-7 Was there any entity (other than the reporting casino or any entity named in Part D of this transaction) associated to the reason for disbursement?

Field F1-7 is to show, for each reason for disbursement, if any additional information is required other than that already provided in the rest of the report. For example, if you cash a bank draft for your client that was payable to your client, information about the financial institution where the bank draft was issued would be required in Part I.

If the code in field F1-7 is "1" (that is, there was an entity associated), provide information about the entity involved in the reason for disbursement in Part I.

If the code in field F1-7 is "2" (that is, there was no entity associated) for all reasons for disbursement in Part F1 and all methods of disbursement in Part F2, Part I does not apply for this transaction and should not be included in the report.

Part F2: Method of disbursement

This part is for information about how the disbursement was actually paid out.

If you include more than one transaction in this report under the 24-hour rule, you have to complete Part F2 for each transaction included in the report.

Fields F2-1* and F2-2 Method of disbursement

Field F2-1 must contain the code indicating the method of disbursement. Some methods require the completion of other parts of the report to provide additional information. Common occurrences of these are explained below.

If the method of disbursement was a deposit to an account at a financial institution, an international or domestic funds transfer, or a transfer to another casino, you would need to provide information in Part H (Information about an associated individual) or Part I (Information about an associated entity), as appropriate.

For example, if an amount were disbursed by a deposit to an account at a financial institution in the name of the individual requesting the disbursement or in the name of an entity, you would have to indicate at field F2-7 that an entity was involved. In the case of an account in the name of the individual requesting the disbursement, you would also have to provide the name of the financial institution where the account is held in Part I (Information about an associated entity). In the case of an account in the name of an entity, you would have to provide information about the account in addition to the name of the financial institution.

As another example, if the method of disbursement was a deposit to an account in the name of an individual other than the one requesting the disbursement, you would have to indicate at field F2-6 that another individual was involved. In this case, you would also have to complete Part H (Information about an associated individual) to provide information about the individual and the account involved.

If the selections provided do not cover the method of disbursement (for example, in the case of a car or a trip as a prize payout), use the code to indicate "Other" and provide details in field F2-2. In this case, field F2-2 is mandatory. Otherwise, do not include field F2-2.

There could be more than one method for the same transaction. For example, your client could, in the same transaction, request that part be paid out by cheque (method 1) and the rest paid out in cash (method 2). In this case, you would include fields F2-1 to F2-7 for each of those two methods.

Field F2-3* Amount

Field F2-3 must contain the amount paid out for each method of disbursement.

The amount should be provided without thousand separators, using a period as decimal notation. For example, $9,000 should be provided as either "9000.00".

If this was not in Canadian funds, do not convert it, but provide the currency information in field F2-4. If the disbursement was paid out in more than one currency, include fields F2-1 to F2-7 for each currency.

If the method of disbursement was other than money, such as a car, a trip, or other similar prize, use the cash equivalent value of that prize as the amount in field F2-3. If there was no cash equivalent, use the total amount that the casino actually paid for the prize disbursed.

Field F2-4* Currency code

Field F2-4 must contain the type of currency for each amount associated to a method of disbursement.

Field F2-5 Did the method of disbursement involve a casino account?

If the code in field F2-5 is "1", provide information about the casino account involved in the disbursement in Part G (Account information). This is only for a casino account held at your casino. If the disbursement involved an account at another casino, this information is required in Part H (Additional information about another individual associated to the disbursement) or Part I (Additional information about an entity associated to the disbursement), as applicable.

If the client named in Part C, the entity named in Part D or the individual named in Part E does have a casino account, but the disbursement did not involve it in any way, use code "2" in field F2-5.

If the code in field F2-5 is "2" for all reasons for disbursement in Part F1 and all methods of disbursement in Part F2, Part G does not apply for this disbursement and should not be included in the report.

Field F2-6 Was there any individual (other than those named in Part C or E of this transaction) associated to the method of disbursement?

Field F2-6 is to show, for each method of disbursement, whether any additional information is required other than that already provided in the rest of the report. For example, if you send a funds transfer for the disbursement to any individual other than the one for whom the disbursement was received, information about that other individual would be required in Part H.

If the code in field F2-6 is "1", provide information about the other individual involved in the method of disbursement in Part H.

If the code in field F2-6 is "2" for all reasons for disbursement in Part F1 and all methods of disbursement in Part F2, Part H does not apply for this disbursement and should not be included in the report.

Field F2-7 Was there any entity (other than the reporting casino or any entity named in Part D of this transaction) associated to the method of disbursement?

Field F2-7 is to show, for each method of disbursement, if any additional information is required other than that already provided in the rest of the report. For example, if you are a casino and you transfer the amount to another casino, information about that other casino would be required in Part I.

If the code in field F2-7 is "1", provide information about the entity involved in the method of disbursement in Part I.

If the code in field F2-7 is "2" for all reasons for disbursement in Part F1 and all methods of disbursement in Part F2, Part I does not apply for this disbursement and should not be included in the report.

Part G: Account information (if the disbursement involved a casino account)

This part is for information about the casino account involved in the disbursement, if it in fact involved a casino account. This only applies to a casino account held at your casino. If the disbursement involved an account at another casino, the information is required in Part H (Additional information about another individual associated to the disbursement) or I (Additional information about an entity associated to the disbursement), as applicable.

Part G is required if you indicated in Part F1 that the reason for disbursement (field F1-5) or in Part F2 that the method of disbursement (field F2-5) involved a casino account. If the disbursement did not involve a casino account, Part G is not required and should not be included in the report. Even if the client has a casino account, if the disbursement did not involve it in any way, do not include the account information in the report about that disbursement.

If there were two or more reasons for disbursement that involved a casino account, provide the casino account information for each one. The same is true if there were two or more methods of disbursement that involved a casino account.

Fields G1 and G2 Is there an identifier number for the casino where the account is held?

If the code in field G1 is "2", in other words, a casino identifier does not exist, field G2 does not apply and should be left empty.

If the code in field G1 is "1", in other words a casino identifier exists, enter the casino identifier number where the account is held in field G2. In this case, field G2 is mandatory.

Field G3* Account number

Field G3 must contain the number of the relevant casino account.

Fields G4* and G5 Type of account

Field G4 must contain the code indicating the type of the relevant casino account. If the selections "1" (Credit) or "2" (Front money) do not cover this particular casino account, use the code to indicate "Other" and provide details in field G5. In this case, field G5 is mandatory. Otherwise, do not include field G5.

Field G6* Account currency code

Field G6 must contain the code for the type of currency for the relevant casino account.

Field G7 Is this account held by one or more individuals or by an entity?

If the code in field G7 is "1", in other words the account is held by one or more individuals, provide the names of each individual account holder (up to three) in fields G8 to G10. In this case, field G11 does not apply and should be left empty.

If the code in field G7 is "2", in other words the account is held by an entity, provide the name of the account holder in field G11. In this case, fields G8 to G10 do not apply and should be left empty.

Fields G8, G9 and G10 Full name of individual account holder(s)

If the code in field G7 is "2", in other words the account is held by an entity, fields G8 to G10 do not apply and should be left empty.

If the code in field G7 is "1", in other words the account is held by one or more individuals, provide the names of each individual account holder (up to three). In this case, for each individual, field G8 must contain the last name and field G9 must contain the first name. Field G10 is for any middle initial, if applicable. If there is no middle initial, do not include field G10 or leave it empty.

Field G11 Full name of entity account holder

If the code in field G7 is "1", in other words the account is held by one or more individuals, field G11 does not apply and should be left empty.

If the code in field G7 is "2", in other words the account is held by an entity, field G11 must contain the full name of the entity.

The account holder might be different from the individual(s) authorized to give instructions for the account. For example, an account for a corporation will have one or more individuals authorized to give instructions for that account. In this case, it is the name of the corporation that holds the account that is required in field G11. Information about individuals authorized to bind the entity or to act with respect to the account belongs in Part D, if applicable, in fields D14 to D16.

Part H: Additional information about another individual associated to the disbursement

This part is for information about another individual associated to the reason or method of disbursement, other than an individual named in Part C or E for the disbursement. Part H should only be included in the report if you included the code "1" in field F1-6 in Part F1 or field F2-6 in Part F2.

For example, this part would apply if you cashed a cheque for your client that was payable to another individual who had signed it over to your client. You would have to provide information about that other individual in Part H, including information about the account and the financial institution on which the cheque was drawn.

Include Part H for each reason for disbursement and each method of disbursement to which another individual (other than an individual named in Part C or E) was associated. If the disbursement did not have another individual associated to it, Part H is not required and should not be included in the report.

Fields H1*, H2* and H3 Individual's full name

Field H1 must contain the last name of the other individual associated to the reason for disbursement or the method of disbursement. Field H2 must contain the first name. Field H3 is for any middle initial, if applicable. If there is no middle initial, do not include field H3 or leave it empty.

If the disbursement is reportable under the 24-hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for fields H1 and H2 was not obtained at the time of the transaction and is not available from your records, leave these fields empty.

Field H4 Was there an account for this individual (other than the account provided in Part G) associated to the disbursement?

If the code in field H4 is "2", in other words, no account was associated, fields H5 to H7 do not apply and should not be included or should be left empty.

If the code in field H4 is "1", in other words, an account was associated, fields H5 to H7 must provide information about the account.

Fields H5*, H6* and H7* (if applicable) Account information for the individual associated to the disbursement

If the code in field H4 is "1" (in other words, there was an account for the individual associated to the disbursement), field H5 is for the financial institution's name, field H6 is for the transit number and field H7 is for the account number. This would apply for example, if the disbursement involved a cheque from an individual that is neither the individual who requested the disbursement nor the individual on whose behalf the disbursement was received.

If the disbursement is reportable under the 24-hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for fields H5, H6 and H7 was not obtained at the time of the transaction and is not available from your records, leave these fields empty.

Fields H5* and H6* Financial institution name and branch or transit number will be masked once received by FINTRAC.

Part I: Additional information about an entity associated to the disbursement

This part is for information about an entity associated to the reason or method of disbursement, other than the reporting casino or any entity named in Part D. Part I should only be included in the report if you included the code "1" in field F1-7 in Part F1 or field F2-7 in Part F2.

For example, if you cash a bank draft for your client that was payable to your client, provide information about the financial institution where the bank draft was issued in Part I.

Include Part I for each reason for disbursement and each method of disbursement to which an entity (other than the reporting casino or any entity named in Part D) was associated. If the disbursement did not have an entity associated to it, Part I is not required and should not be included in the report.

Field I1* Full name of entity

Field I1 must contain the full name of the business, corporation, trust or other entity associated to the disbursement.

If the disbursement is reportable under the 24-hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for field I1 was not obtained at the time of the transaction and is not available from your records, leave this field empty.

Field I2 Was there an account for this entity (other than the account provided in Part G) associated to the disbursement?

If the code in field I2 is "2", in other words, no account was associated, fields I3 to I5 do not apply and those fields should not be included.

If the code in field I2 is "1", in other words, an account was associated, fields I3 to I5 must provide information about the account.

Fields I3*, I4* and I5* (if applicable) Account information for the entity associated to the disbursement

If the answer to field I2 was "1" (in other words there was an account for the entity associated to the disbursement), field I3 is for the name of the financial institution where the account is held, field I4 is for the transit number and in field I5 is for the account number. For example, this would apply if the disbursement involved a cheque from a financial institution, payable to the client requesting the disbursement.

If the disbursement is reportable under the 24-hour rule as one of multiple transactions of less than $10,000 each and, because of this, information for fields I3, I4 and I5 was not obtained at the time of the transaction and is not available from your records, leave these fields empty.

Fields I3* and I4* Financial institution name and branch or transit number will be masked upon receipt.

8. Appendix 2: Examples of Reasons and Methods for Casino Disbursement Reports

The following examples are to help explain when and why a casino disbursement report (CDR) is required for common casino transactions.

Examples 1 to 3 are commonly occurring transactions at a casino for which a CDR will be required. Examples 4 and 5 are likely to occur less frequently, but are provided to highlight other reportable disbursement transactions. In each case for examples 1 to 5, the disbursement is requested by one casino patron during a single transaction (for example, one visit to a cashier's station).

Examples 6 to 8 are about situations where a casino disbursement report will not be required. Example 9 is about multiple transactions involving the 24-hour rule.

For all examples, funds are in Canadian dollars unless otherwise specified. In addition, where a CDR is required, only the information required in fields F1-1 to F1-4 of Part F1 (Reason for disbursement) and fields F2-1 to F2-4 of Part F2 (Method of disbursement) is explained. Although all other applicable parts and fields of the CDR would also be required, these examples illustrate only basic reason and method information.

Example 1

A patron redeems $11,000 in slot tickets for $11,000 in cash.

A CDR is required, with one transaction including the following information about the reason and the method of disbursement.

Example 2

A patron redeems $25,000 in casino chips for a $25,000 casino cheque.

A CDR is required, with one transaction including the following information about the reason and the method of disbursement.

Example 3

A patron redeems slot tickets for $12,000 and casino chips for $5,000. In exchange, he receives a cheque for $7,000 and $10,000 in cash.

A CDR is required, with one transaction including the following information about the two reasons and the two methods of disbursement.

Example 4

A patron withdraws $24,000 from her front money account in exchange for a casino cheque for $24,000.

A CDR is required, with one transaction including the following information about the reason and the method of disbursement.

Example 5

A patron withdraws $44,000 from his front money account and requests the casino to wire the funds to his bank in the United States.

A CDR is required, with one transaction including the following information about the reason and the method of disbursement.

In this example, a casino disbursement report is required even though the funds were sent by wire transfer. This applies to any disbursement involving a wire transfer, whether domestic or international. As explained in subsection 2.4 of this guideline, if a casino disbursement involves an international wire transfer, you may have to make an electronic funds transfer report to FINTRAC about the same transaction in addition to the CDR.

Example 6

A patron cashes a $10,000 personal cheque (that is made payable to the patron) in exchange for $10,000 in chips.

A CDR is not required. Although the cashing of a $10,000 cheque could be a reportable disbursement, it is not in this example because of how it was paid out. Pay outs in casino chips are not considered to be a disbursement in this context.

Example 7

A patron cashes a casino cheque for $11,000. In exchange, she receives $6,000 in cash and $5,000 in chips.

A CDR is not required. Although the reason for disbursement (cashing of a cheque) is over $10,000, the method of disbursement is less than $10,000 because the amount paid out in casino chips is excluded. A CDR is only required when both the reason and the method of a disbursement (as explained in subsection 2.2 of this guideline) equal $10,000 or more.

If the payout in this example had been $10,000 in cash and $1,000 in chips, a CDR would have been required.

Example 8

A patron withdraws $5,000 from his casino front money account and requests a cash advance on his bank-issued credit card for $5,000. In exchange, he receives a cheque for $10,000.

A CDR is not required. Although the amount paid out is $10,000, the reason for disbursement is less than $10,000 because an advance on a bank-issued credit card is not considered a disbursement. A CDR is only required when both the reason and the method of a disbursement (as explained in subsection 2.2 of this guideline) equal $10,000 or more.

Example 9

This example has two scenarios.

Scenario 1

The following transactions occur at the following times, on the same day:

A CDR is required under the 24-hour rule for the 4:00 p.m. transaction and the 8:00 p.m. transaction, as follows.

Scenario 2

The same transactions as scenario 1, with the following change to how the payout is made at 8:00 p.m.:

A CDR is required under the 24-hour rule for the 4:00 p.m. transaction and the 8:00 p.m. transaction as follows.

In this scenario, the method reported for transaction 2 is the full amount of the casino cheque, even if it includes an amount that is a not reportable as a disbursement. The cash being exchanged is not included in the CDR as a reason for disbursement. However, the portion of that transaction that is the redemption of casino chips is included because, when added to the reason of disbursement in transaction 1, the threshold of $10,000 or more has been met.

In both scenarios of this example, in addition to a CDR, a large cash transaction report (LCTR) would also be required. The LCTR 24-hour rule applies to the 2:00 p.m. and 8:00 p.m. foreign currency exchange transactions. For more information about when LCTRs are required, see Guideline 7: Submitting Large Cash Transaction Reports to FINTRAC.

Details and history

Published: August 2019

For assistance

If you have questions about this guidance, please contact FINTRAC by email at guidelines-lignesdirectrices@fintrac-canafe.gc.ca.

Date Modified: