Reporting suspicious transactions to FINTRAC

August 2019

August 2019

Suspicious transaction reporting requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations are applicable to all reporting entity sectors.

It is recommended that this guidance be read in conjunction with other STR guidance, including:

**Note: All references to financial transactions should be read to include attempted or completed financial transactions.

This guidance provides information on the following topics:

  1. When must a suspicious transaction be reported?
  2. Service provider agreements
  3. How to submit STRs
  4. Review and validation of reports by FINTRAC
  5. Completing the STR form
  6. Field completion instructions

Exclusions

Accountants and accounting firms

If you are an accountant or an accounting firm, the suspicious transaction reporting requirement does not apply to the receipt of professional fees.

British Columbia notaries

If you are a British Columbia notary, the suspicious transaction reporting requirement does not apply to the receipt or payment of professional fees, disbursements, expenses or bail.

Dealers in precious metals and stones

If you are a dealer in precious metals and stones, the suspicious transaction reporting requirement does not apply if you engage in a purchase or sale carried out for, in connection with, or for the purpose of manufacturing jewellery, extracting precious metals or precious stones from a mine or cutting or polishing precious stones.

Financial entities

If you are a financial entity and you have foreign subsidiaries or foreign branches, the suspicious transaction reporting requirement does not apply to the operations of these subsidiaries or branches outside Canada.

Life insurance companies, brokers and agents

If you are a life insurance company and you have foreign subsidiaries or foreign branches, the suspicious transaction reporting requirement does not apply to the operations of these subsidiaries or branches outside Canada.

Real estate brokers or sales representatives

If you are a real estate broker or sales representative, the suspicious transaction reporting requirement does not apply to your activities related to property management.

Securities dealers

If you are a securities dealer and you have foreign subsidiaries or foreign branches, the suspicious transaction reporting requirement does not apply to the operations of these subsidiaries or branches outside Canada.

1. When must a suspicious transaction be reported?

Pursuant to section 9(2) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations, “the report shall be sent to the Centre within 30 days after the day on which the person or entity or any of their employees or officers detects a fact respecting a financial transaction or an attempted financial transaction that constitutes reasonable grounds to suspect that the transaction or attempted transaction is related to the commission of a money laundering offence or a terrorist financing offence.” In other words, an STR must be submitted to FINTRAC when you detect a fact that leads you to determine that you have reasonable grounds to suspect that a transaction is related to the commission or attempted commission of a money laundering or terrorist financing offence.

You must submit an STR to FINTRAC within 30 days of reaching that determination. Unlike all other reporting obligations, there is no monetary threshold associated with the reporting of a suspicious transaction.

STRs are unique under the Canadian anti-money laundering and anti-terrorist financing (AML/ATF) regime as they may also contain transactions that must be submitted to FINTRAC in other types of reports. For example, if a completed transaction reported in an STR involved the receipt of cash from a client of 10,000 Canadian Dollars (CAD) or more, you would also be required to report this transaction to FINTRAC in a large cash transaction report.

2. Service provider agreements

A service provider can submit and correct STRs on your behalf. However, as the reporting entity, you are ultimately responsible for meeting your obligations under the PCMLTFA and associated Regulations, even if a service provider is reporting on your behalf. This legal responsibility cannot be delegated.

3. How to submit STRs

If you have a computer and an internet connection, you must submit STRs to FINTRAC electronically. You must submit by paper if you do not have the technological capacity to send an STR electronically.

There are two options for electronic reporting that provide for secure encrypted transmission that ensures your data’s confidentiality and integrity. These two electronic reporting options are listed below.

  • FINTRAC’s secure website – FINTRAC web reporting
  • Batch file transfer

For more information about FINTRAC’s electronic reporting system enrolment, see our electronic reporting page.

FINTRAC web reporting

FINTRAC web reporting is a secure application accessed through the internet that allows you to manually submit individual reports, as well as correct them if needed. It is geared towards reporting entities with lower reporting volumes. To report STRs electronically, you must be enrolled and logged in to the FINTRAC web reporting system. For more information on FINTRAC web reporting, see the following document:

  • FINTRAC web reporting: for instructions on how you can enroll in web reporting and the browser requirements

Batch reporting

Batch reporting is a secure process that allows for the submission and correction of multiple reports (up to 10,000) in ‘Batch files’ that are formatted according to FINTRAC’s specifications. To use the Batch reporting system, FINTRAC will provide you with Batch transmission software but you will also need to enroll in FINTRAC web reporting and apply for a public key infrastructure (PKI) certificate. For more information on Batch reporting, see the following links and documents.

  • How can I use Batch reporting? for instructions on how you can enroll in FINTRAC web reporting and apply for a PKI certificate.
  • Batch transmission guide: to assist you with installing and configuring the Batch transmission software and to instruct you in how to transmit Batch files to FINTRAC.
  • Batch documentation: to assist you with how to create, submit and correct Batch files.

Paper reporting

FINTRAC’s STR paper reporting form can be printed from the reporting forms webpage or you can request a form to be faxed or mailed to you by calling FINTRAC at 1-866-346-8722.

To ensure that the information provided is legible and to facilitate data entry, it would be preferable if the free-text areas of the STR (Parts G and H) were completed using word-processing equipment. For reports completed by hand, please use black ink and CAPITAL LETTERS.

There are two ways you can send a completed paper STR form to FINTRAC:

  • by fax: 1-866-226-2346; or
  • by mail to the following address:
    Financial Transactions and Reports Analysis Centre of Canada
    Section A
    234 Laurier Avenue West, 24th floor
    Ottawa, ON  K1P 1H7
    CANADA

There is no official acknowledgement of receipt when you send a completed paper STR form to FINTRAC. However, FINTRAC will contact you and request that you resubmit electronically if you have the capability to do so.

4. Review and validation of reports by FINTRAC

FINTRAC reviews each report that is submitted to ensure that mandatory information is provided as per the PCMLTFA and associated Regulations. There are three types of validation rules that FINTRAC uses to validate reports and these rules are described below.

  • Presence – is there an entry in the field?
  • Format – is the entry in the correct structure?
  • Content – is the correct information entered in the appropriate field?

FINTRAC validation rules identify possible reporting problems or information gaps but do not cover all scenarios. While FINTRAC conducts a review of report submissions to assess the quality of reports, you should have your own proactive quality assurance practices independent of FINTRAC’s review and validation of reports.

The report validation processes for FINTRAC web reporting and Batch are different. Each report validation process is described in more detail below.

FINTRAC web reporting report validation

Reports submitted through FINTRAC web reporting are immediately validated by the application. FINTRAC web reporting will indicate where information is missing, incorrect, or improperly formatted. You must correct all errors for mandatory fields before you can submit a report.

Batch report validation

Once a Batch file has been submitted, FINTRAC validates the Batch file against the validation rules. If there is an error with the structure or format of the file then you will receive a “Rejected” message and the Batch file and reports within it will not be processed any further. You must correct and resubmit the entire Batch file. Once you resubmit a Batch file, it is revalidated against all validation rules.

If there is a potential issue in a reporting field then you may also receive a “Warning” message. If you receive a “Warning” message, the report has been accepted by FINTRAC but you should review the information submitted for accuracy and completeness.

Once your Batch file has been accepted and validated, FINTRAC will send you a Batch “Acknowledgement” message that will include the validation rule number(s) for any report(s) that require further action and any warning messages.

See FINTRAC’s Standard Batch Reporting Instructions and Specifications for more information.

5. Completing the STR form

FINTRAC’s expectations for completing an STR

It is your responsibility to ensure that the information provided in an STR is complete and accurate. Your policies and procedures must include details on the process for how you identify, assess and submit STRs to FINTRAC. It is possible that your organization has an automated or triggering system that detects unusual or suspicious transactions that would require assessment by a person to determine if you must submit an STR. A person with the appropriate knowledge and training is expected to be able to determine whether a transaction is related to the commission or attempted commission of an ML/TF offence. It is also important to note that the value of the transaction is not always the most important aspect of an STR. Training employees to perform this function is considered to be part of your compliance program obligations.

Please note, an employee of a reporting entity can be considered a ‘reporting entity’ and report a completed or attempted suspicious transaction to FINTRAC when:

  • they have reasonable grounds to suspect that a transaction is related to the commission or attempted commission of an ML/TF offence; and
  • their employer did not or will not report.

This stipulation is in place to cover the rare instances where an individual suspects that the threshold to report has been reached and their employer did not or will not send an STR. No individual or entity will be prosecuted for sending an STR in good faith or for providing FINTRAC with information about suspicions of money laundering or terrorist financing. To submit an STR in this scenario, you may use the paper report form. For more information, please see field completion instructions to submit STRs by paper.

It is important to FINTRAC’s analysis process and disclosure recipients that the STRs you submit are comprehensive and of high quality. In Part G or H of the STR, it is important to avoid jargon or non-public references, such as terms and acronyms that are specific to your organization. Please consider an outside reader and use simple, clear and concise language.

A variety of information is often collected as part of an assessment to determine if you are required to submit an STR and this information is valuable to include in your report to FINTRAC. A well-completed STR should consider the following questions.

  1. Who are the parties to the transaction?
    • List the conductor, beneficiary and holders of all accounts involved in the transaction.
    • Take reasonable measures to identify the conductor of the transaction. This means that you are expected to ask the client for this information unless you think doing so will tip them off to your suspicion.
    • Provide identifying information on the parties involved in the transaction. This could include the information you recorded to identify the conductor, as well as any information you have on the other parties to the transaction or its recipients.
    • List owners, directors, officers and those with signing authority, when possible. If the transaction involves a business, you could include information on the ownership, control and structure of the business in the STR.
    • Provide clear information about each individual or entity’s role in each of the financial transactions described. It is important to know who is sending and receiving the funds and this may be relevant in Part G of the STR.
    • Explain the relationships among the individuals or entities (if known). This is very helpful to FINTRAC when trying to establish networks of individuals or entities suspected of being involved in the commission or attempted commission of an ML/TF offence.
  2. When was the transaction(s) completed/attempted? If it was not completed, why not?
  3. What are the financial instruments or mechanisms used to conduct the transaction?
  4. Where did this transaction take place?
  5. Why the transaction(s) or attempted transaction(s) are related to the commission or attempted commission of an ML/TF offence?
    • State the ML/TF indicators used to support your suspicion.
    • State the suspected criminal offence related to ML/TF, if known.
  6. How did the transaction take place?

Once you have reached reasonable grounds to suspect, you must keep reporting as long as the suspicion remains. You are expected to periodically re-assess the client to verify that the level of suspicion has not changed. This process may be part of your documented risk based approach or ongoing monitoring. If you continue to report STRs(s) on the same person or entity, you can reference a previous STR in Part G by:

  • entering the FINTRAC STR number and date of submission;
  • providing the reasonable grounds to suspect (facts, context and ML/TF indicators) that were included in the first STR submission; and
  • by providing any new additional information.

If you are reporting STRs because the assessment has changed due to new facts, context and/or ML/TF indicators, you are expected to provide them. For example, through the course of your assessment, you may have identified new ML/TF indicators or new parties transacting with your client. You may choose to include that information under a separate heading in Part G so that it is properly labeled as new information.

You must keep a copy of all STRs submitted to FINTRAC. For more information on your record keeping obligations related to STRs, see your sector specific record keeping guidance.

STR submission limitations

Each STR must include at least one transaction and may include up to 99 transactions as long as all the transactions:

  • have the same transaction status (e.g., all completed transactions or all attempted transactions); and
  • took place at the same location.

For example, someone brings a money order for $6,000 CAD and successfully sends an electronic funds transfer for $6,000 CAD (first completed transaction). Later that day, the same person returns to the same location and brings $5,000 CAD cash and receives a money order (second completed transaction). In this case, if there are reasonable grounds to suspect that the two completed transactions, conducted at the same location, are related to the commission or attempted commission of an ML/TF offence, you should provide the transaction details for the two transactions in the same STR. While the transactions may be referenced in Part G as part of the facts, context and/or ML/TF indicators, the transaction details themselves must be entered in Parts B1 through F.

In a situation where related suspicious transactions took place at different locations, an STR must be submitted for each location and only detail the transactions that occurred at that specific location. In addition, all transactions should have the same status as either completed or attempted to be included in a single report.

If you have more than 99 transactions to report at one time, you must submit the additional transaction(s) in a separate STR. You cannot insert a spreadsheet or include the additional transactions in Part G of the STR. If the information is available, you can reference related STRs in Part G by entering the FINTRAC STR number and date of submission.

Common STR deficiencies to avoid

The following are examples of deficiencies that FINTRAC has identified through its assessments and other compliance activities. FINTRAC is sharing these examples to illustrate common errors that you can avoid.

  1. Using a higher threshold as your basis for reporting: You are required to submit an STR when you have determined that there are reasonable grounds to suspect that a transaction is related to the commission or attempted commission of an ML/TF offence. In some cases, it is possible that you have determined that there are reasonable grounds to believe that the transaction is related to the commission or attempted commission of an ML/TF offence. In those cases, you should still submit an STR. However, it is important to note that you do not need to reach the threshold of reasonable grounds to believe in order to submit an STR.
  2. Failing to list all the transactions and accounts relevant to your suspicion in Parts B through F: You are required to report all the transactions and accounts in Parts B through F that led to your determination that there are reasonable grounds to suspect that the transaction is related to the commission or attempted commission of an ML/TF offence. Providing a summary of the transactions in Part G is not enough.
  3. Not listing or naming all parties to the transactions when the information is available: All parties to the transaction must be listed, including third parties. You should also specify whether the parties are known or unknown. This has been observed in transactions involving multiple parties such as wire transfers. For example, if you are reporting a wire transfer, you should include any information you have regarding both the ordering client and beneficiary. This could include (but is not limited to) their names, their account number and institution, their relationship, and any known identifiers. FINTRAC acknowledges that this information may not always be at your disposal, but when you know it, it should be provided.
  4. Part G does not elaborate on your grounds for suspicion or link them to the transactions reported in Parts B through F: You are required to articulate the reasons for your determination that there are reasonable grounds to suspect that the transaction is related to the commission or attempted commission of an ML/TF offence in an STR. This includes providing all of the relevant facts, context and ML/TF indicators related to the transactions reported in Parts B through F that support your suspicion in Part G. This deficiency has been observed when a reporting entity does not articulate the reasons for their suspicion or does not explain how or why certain information is relevant to their suspicion.

6. Field completion instructions

**Note: Unless otherwise stated, this section details specific instructions that apply to both electronic and paper reporting.

Parts of a suspicious transaction report

STRs contain eight specific parts:

  • Part A: Information about where the transaction took place

    In Part A of the STR, you must provide information about you as the reporting entity, and about the physical location where the completed or attempted suspicious transaction took place.

    When completing Part A it is important to note that:

    • Reporting entity’s full name is your entity’s full legal name. Even if you have entered into a contractual relationship with another entity to conduct transactions on your behalf, it is your name that must be entered into this field.
    • Reporting entity number is the number that was assigned to you when you enrolled in FINTRAC web reporting.
    • Reporting entity location number is the location number where the transaction took place or was attempted. If you have multiple locations, your FINTRAC web reporting administrator is responsible for adding the other locations, as well as maintaining the location information.
    • Reporting entity report reference number is a unique internal reference number generated by your entity. The recording of the internal reference number on the STR may help you to quickly identify the report if required to at a later date.
    • Activity Sector is the type of business and/or activities you undertake.
  • Part B1: Information about how the transaction was initiated

    In Part B1 of the STR, you must provide the date of the transaction, the transaction amount, the detail of the funds involved in initiating the transaction, how the transaction was conducted, as well as information on any other institution, entity or individual that was involved in the transaction.

    When completing Part B1 it is important to note that:

    • the date of transaction is the date that the transaction occurred. Whereas, the date of posting is the date on which the funds from the transaction are received in an account; and
    • you must provide (if applicable) the name of any other person or entity or the name and number of the other institution involved in the initiation of the transaction.

    If you need to report more than one transaction in an STR, a separate Part B1 will have to be completed for each transaction.

  • Part B2: Information about how the transaction was completed

    In Part B2 of the STR, you must detail:

    • how the funds were used in the completed transaction or how they were going to be used in an attempted transaction; and
    • whether the individual who conducted or attempted the suspicious transaction did so on anyone else’s behalf.

    The funds in a transaction may have been used in several ways, therefore resulting in more than one disposition having to be detailed in your STR. For example, your client may initiate a transaction in cash, then use some of the funds to send an electronic funds transfer (disposition 1), order a bank draft (disposition 2), and deposit the remaining funds (disposition 3). If there is more than one disposition, you will need to complete a separate Part B2 for each disposition.

  • Part C: Account information, if the transaction involved an account

    In Part C of the STR, you must provide the account details for each disposition that involved an account (completed transaction) or was going to involve an account (attempted transaction), if applicable. For example, if the related disposition was a “Deposit’, this part is required.

  • Part D: Information about the individual conducting the transaction

    In Part D of the STR, you must provide information about the individual who completed or attempted to complete the transaction.

    If more than one transaction is reported in an STR, a separate Part D will have to be completed for each transaction.

  • Part E: Information about the entity on whose behalf the transaction was conducted

    In Part E of the STR, if applicable, you must provide information about the entity on whose behalf the transaction was conducted or attempted.

    Part E needs to be completed if you indicated in Part B2 that the transaction was conducted “On behalf of an entity.”

    A separate Part E must be completed for each disposition that was conducted or attempted on behalf of an entity.

  • Part F: Information about the individual on whose behalf the transaction was conducted

    In Part F of the STR, if applicable, you must provide information about the individual on whose behalf the transaction was conducted or attempted.

    Part F must be completed if you indicated in Part B2 that the transaction was conducted “On behalf of another individual.”

    A separate Part F must be completed for each disposition that was conducted or attempted on behalf of another individual.

  • Part G: Description of suspicious transaction and any facts or context associated with the suspicion

    This section is the narrative that explains your grounds for suspicion and should include the results of your assessment of facts, context and ML/TF indicators that led to your decision to submit an STR to FINTRAC. The narrative should include the explanation of this assessment and should not assume that the reader will be familiar with acronyms or terminology specific to your business. Detailed and high quality STRs provide valuable and actionable intelligence for FINTRAC and this section is shared with law enforcement and intelligence agencies in FINTRAC disclosures.

    The narrative provided in this section should focus on the question: “Why do you think the transaction is suspicious of ML/TF?”

    The following are examples of the type of information that, when available, have been provided in STRs and have contributed greatly to FINTRAC analysis:

    • any client identification information not already captured in the transaction details listed in part B, i.e., known aliases or nicknames;
    • additional contact information (phone numbers, email addresses, etc.);
    • details for credit card activity including details of purchases (dates, amounts, retailer (online or in-store) and details of payments (dates, amounts, conductor and source of payment);
    • details for electronic transfers (such as e-mail money transfers, wire transfers) including IP addresses and sender/recipient email addresses;
    • location of ATM withdrawals;
    • any related STR number(s) and the date(s) previously submitted;
    • the history the client has with you;
    • links made to other people, businesses and accounts;
    • information on the ownership, control and structure of an entity that is not already captured in Part B, particularly for any business entities that have a complex structure;
    • the intended or expected use of an account versus the activity you may have observed;
    • any other information about your interactions with the client;
    • the ML/TF indicators or factors that assisted in forming the basis of your suspicion;
    • any information, including publicly available information and/or information from law enforcement, that made you suspect distinctly that the transaction might be related to terrorist financing, money laundering, or both;
    • any details surrounding why an attempted transaction was not completed; and
    • any context or clarification about the information that was reported in the structured sections (Parts B through F).

    FINTRAC has been able to identify networks of suspected money launderers and terrorist financiers through pieces of information such as email addresses and secondary identifiers (nicknames) or phone numbers. This type of information may seem insignificant but can be very important to FINTRAC, as it may identify connections among individuals, entities or crimes when compared against other FINTRAC intelligence.

    It is important that your narrative is consistent with the information in Parts B through F of the STR form.For example, if you are referring to specific account activity in this section the details of those accounts and transactions should be entered in the structured fields. It is also important that you do not refer to any internal files or documents since FINTRAC cannot have access to these internal files or documents for its analysis. It is also not possible to see graphics, underlined, italicized or bolded text included in the STR.

  • Part H: Description of action taken

    Describe any actions taken by you, in addition to reporting to FINTRAC, in response to the suspicious transaction.

    Examples of additional actions that you may take include:

    • reporting the information directly to law enforcement;
    • initiating enhanced transaction monitoring;
    • closing the account(s) in question or exiting the business relationship; and/or
    • cancelling, reversing or rejecting the transaction.

    Reporting an STR to FINTRAC does not prevent you from contacting law enforcement directly. However, even if you do contact law enforcement directly about your suspicions of money laundering or terrorist financing, you must still submit an STR to FINTRAC. Some STRs have included the law enforcement agency’s contact information in Part H of the STR when the information was reported directly to law enforcement and this information can be helpful.

Standardized field instructions

This section includes standardized instructions for the level of effort that is required for certain fields as well as standard instructions for completing fields for identification, addresses, telephone numbers and occupation.

  1. Each field within an STR is categorized as either mandatory, mandatory if applicable, or reasonable measures.
    1. Mandatory:
      • Mandatory fields require you to obtain the information to complete the STR and will be marked with an asterisk (*).
      • However, in the case of an attempted transaction, you are to take reasonable measures to obtain the information for any mandatory field.
    2. Mandatory, if applicable:
      • Mandatory if applicable fields must be completed if they are applicable to you or the transaction being reported. If applicable, you must provide the information if you obtained it at the time of the transaction, or if it is contained within your institution.
      • These fields will be indicated with both an asterisk (*) and “(if applicable)” next to them.
    3. Reasonable measures:
      • For all other fields that do not have an asterisk, you must take reasonable measures to obtain the information.
      • Reasonable measures can include asking for the information as long as you don’t think it will tip off the person that you are submitting an STR.
      • Reasonable measures also means that you must provide the information if you obtained it at the time of the transaction, or if it is contained within your institution.

      **Note: In certain circumstances a required report field may not be applicable. Do not enter “N/A” or “n/a” or substitute any other abbreviations, special characters (e.g., “x”, “-“ or “*”) or words (e.g., unknown) in these fields. They are to be left blank.

  2. Client identification

    If you used the dual process method to identify an individual, you only need to provide the details of one of the identifiers. You can use your judgement to determine which identifier would be most advantageous to FINTRAC analysis. Please note that a Social Insurance Number (SIN) must not be reported to FINTRAC.

    The record keeping requirement for the dual process method includes the source of the information, so FINTRAC expects the issuing jurisdiction and country to align with the source of the information, but would only expect, as per the validation rules, that the reporting entity include the country of issue for the dual process method.

    In addition, you cannot use a provincial health card for identification purposes where it is prohibited by provincial legislation.

    For more information on how to identify individuals and examples of acceptable photo identification documents, refer to FINTRAC’s guidance on Methods to verify the identity of an individual and confirm the existence of a corporation or an entity other than a corporation.

  3. On behalf of indicator

    Applies to Part B2 of an STR.

    You are required to take reasonable measures to determine if there is a third party instructing your client to conduct an activity or a transaction. Reasonable measures include asking your client if they are acting on someone else’s instructions or retrieving the information that may already be contained in your records.

    When determining whether an individual has conducted or attempted a suspicious transaction on anyone else’s behalf, it is not about who owns or benefits from the money, or who is carrying out the transaction or activity, but rather about who gives the instructions to handle the money or conduct the transaction or particular activity. Refer to FINTRAC’s guidance on third party determination requirements for more information including the record keeping requirements.

    If you determine that a third party was instructing your client, then you must indicate if the transaction was conducted on behalf of an entity or on behalf of another individual.

    When an individual is acting on behalf of their employer, the employer is considered to be the third party, unless the individual is conducting a cash deposit to the employer’s business account. If there is no third party, or you were not able to determine whether there is a third party, then indicate that this part is not applicable.

  4. Address fields

    Applies to the following fields of an STR:

    • A3* – A6* (mandatory)
    • D5 – D9
    • D20 – D24
    • E3 – E7
    • F4 – F8
    • F19 – F23

    The complete physical address includes the street number, street name, the city, province, and country. If there is no province or state applicable to the address, leave this field blank.

    Please note that the following are not valid addresses and should not be provided:

    • a post office box without a complete physical address (e.g., PO Box 333);
    • a general delivery address; or
    • only a suite number (e.g., Suite 256) without additional address information.

    It is possible that some of the examples above may be included in Part G of the STR because they are relevant but they are not considered a valid address in terms of the client identification.

    In cases where the individual or entity resides in an area where there is no street address, provide a detailed description which clearly describes the physical location. For example, in these unique cases you could enter “the third house to the right after the community center” as the street address where an individual lives.

    A legal land description can be acceptable so long as the legal land description is specific enough to pinpoint the physical location of where the client lives. If the legal land description refers to an area or a parcel of land on which multiple properties are located, the legal land description would not be sufficient.

    For individuals who are transient (e.g., travelling in a recreational vehicle, temporarily working in a camp, etc.) and have no fixed address, you are required to provide the following:

    • for Canadian residents, their permanent address is required, even if that is not where they are currently residing;
    • for non-Canadian residents travelling in Canada for a short period of time, their foreign residential address is required; and
    • for non-Canadian residents living in Canada for a longer period of time (e.g., a student), then the individual’s temporary Canadian address should be provided.
  5. Telephone number fields

    Applies to the following fields of an STR:

    • A10* – A10A
    • D11
    • D18 – D18A
    • D25 – D25A
    • E8 – E8A
    • F9
    • F10 – F10A
    • F24 – F24A

    If the telephone number is from Canada or the United States, enter the area code and local number (e.g., 999-999-9999).

    If the telephone number is from outside Canada or the United States, enter the country code, city code and local number using 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.

  6. Occupation fields

    Applies to the following fields of an STR:

    • D17
    • F17

    When entering an individual’s occupation information, you must be as descriptive as possible. For example:

    • If the individual is a manager, the occupation provided should reflect the area of management, such as “hotel reservations manager” or “retail clothing store manager.”
    • If the individual is a consultant, the occupation provided should reflect the type of consulting, such as “IT consultant” or “forestry consultant”.
    • If the individual is a professional, the occupation provided should reflect the type of profession, such as “petroleum engineer” or “family physician”.
    • If the individual is a labourer, the occupation provided should reflect the type of labour performed, such as “road construction worker” or “landscape labourer”.
    • If the individual is not working, the occupation provided should still be as descriptive as possible, such as "student", "unemployed" or "retired".
Coming into force on 1st June 2020

April 2020

This guidance will come into force on 1st June 2020.

Suspicious transaction reporting requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations are applicable to all reporting entity sectors.

It is recommended that this guidance be read in conjunction with other STR guidance, including:

**Note: All references to financial transactions should be read to include attempted or completed financial transactions.

This guidance provides information on the following topics:

  1. When must a suspicious transaction be reported?
  2. Service provider agreements
  3. How to submit STRs
  4. Review and validation of reports by FINTRAC
  5. Completing the STR form
  6. Field completion instructions

Exclusions

Accountants and accounting firms

If you are an accountant or an accounting firm, the suspicious transaction reporting requirement does not apply to the receipt of professional fees.

British Columbia notaries

If you are a British Columbia notary, the suspicious transaction reporting requirement does not apply to the receipt or payment of professional fees, disbursements, expenses or bail.

Dealers in precious metals and stones

If you are a dealer in precious metals and stones, the suspicious transaction reporting requirement does not apply if you engage in a purchase or sale carried out for, in connection with, or for the purpose of manufacturing jewellery, extracting precious metals or precious stones from a mine or cutting or polishing precious stones.

Financial entities

If you are a financial entity and you have foreign subsidiaries or foreign branches, the suspicious transaction reporting requirement does not apply to the operations of these subsidiaries or branches outside Canada.

Life insurance companies, brokers and agents

If you are a life insurance company and you have foreign subsidiaries or foreign branches, the suspicious transaction reporting requirement does not apply to the operations of these subsidiaries or branches outside Canada.

Real estate brokers or sales representatives

If you are a real estate broker or sales representative, the suspicious transaction reporting requirement does not apply to your activities related to property management.

Securities dealers

If you are a securities dealer and you have foreign subsidiaries or foreign branches, the suspicious transaction reporting requirement does not apply to the operations of these subsidiaries or branches outside Canada.

1. When must a suspicious transaction be reported?

Pursuant to subsection 9(2) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations, "the person or entity shall send the report to the Centre as soon as practicable after they have taken measures that enable them to establish that there are reasonable grounds to suspect that the transaction or attempted transaction is related to the commission of a money laundering offence or a terrorist activity financing offence."

These measures include:

  • screening for and identifying suspicious transactions;
  • assessing the facts and context surrounding the suspicious transaction;
  • linking ML/TF indicators to your assessment of the facts and context; and
  • explaining your grounds for suspicion in an STR, where you articulate how the facts, context and ML/TF indicators allowed you reached you grounds for suspicion.

After completing the measures that enabled you to determine that you have reasonable grounds to suspect that a financial transaction is related to the commission or attempted commission of an ML/TF offence, you must submit an STR to FINTRAC as soon as practicableFootnote 1. These measures must be described in your policies and procedures.

As soon as practicable should be interpreted to mean that you have completed the measures that have allowed you to determine that you reached the RGS threshold and as such the development and submission of that STR must be treated as a priority report. FINTRAC expects that you are not giving unreasonable priority to other transaction monitoring tasks and may question delayed reports. The greater the delay, the greater the need for a suitable explanation. STRs can be complex yet you must treat them as a priority and ensure they are timely; you must also complete the measures that enabled you to conclude that you have RGS the commission of an ML/TF offence before you submit the report to FINTRAC.  

There is no monetary threshold associated with the reporting of a suspicious transaction and under the Canadian anti-money laundering and anti-terrorist financing (AML/ATF) regime they may also contain transactions that must be submitted to FINTRAC in other types of reports. For example, if a completed transaction reported in an STR involved the receipt of cash from a client of 10,000 Canadian Dollars (CAD) or more, you would also be required to report this transaction to FINTRAC in a large cash transaction report.

2. Service provider agreements

A service provider can submit and correct STRs on your behalf. However, as the reporting entity, you are ultimately responsible for meeting your obligations under the PCMLTFA and associated Regulations, even if a service provider is reporting on your behalf. This legal responsibility cannot be delegated.

3. How to submit STRs

If you have a computer and an internet connection, you must submit STRs to FINTRAC electronically. You must submit by paper if you do not have the technological capacity to send an STR electronically.

There are two options for electronic reporting that provide for secure encrypted transmission that ensures your data's confidentiality and integrity. These two electronic reporting options are listed below.

  • FINTRAC's secure website – FINTRAC web reporting
  • Batch file transfer

For more information about FINTRAC's electronic reporting system enrolment, see our electronic reporting page.

FINTRAC web reporting FINTRAC web reporting is a secure application accessed through the internet that allows you to manually submit individual reports, as well as correct them if needed. It is geared towards reporting entities with lower reporting volumes. To report STRs electronically, you must be enrolled and logged in to the FINTRAC web reporting system. For more information on FINTRAC web reporting, see the following document:

  • FINTRAC web reporting: for instructions on how you can enroll in web reporting and the browser requirements

Batch reporting

Batch reporting is a secure process that allows for the submission and correction of multiple reports (up to 10,000) in 'Batch files' that are formatted according to FINTRAC's specifications. To use the Batch reporting system, FINTRAC will provide you with Batch transmission software but you will also need to enroll in FINTRAC web reporting and apply for a public key infrastructure (PKI) certificate. For more information on Batch reporting, see the following links and documents.

  • How can I use Batch reporting? for instructions on how you can enroll in FINTRAC web reporting and apply for a PKI certificate.
  • Batch transmission guide: to assist you with installing and configuring the Batch transmission software and to instruct you in how to transmit Batch files to FINTRAC.
  • Batch documentation: to assist you with how to create, submit and correct Batch files.

Paper reporting

FINTRAC's STR paper reporting form can be printed from the reporting forms webpage or you can request a form to be faxed or mailed to you by calling FINTRAC at 1-866-346-8722.

To ensure that the information provided is legible and to facilitate data entry, it would be preferable if the free-text areas of the STR (Parts G and H) were completed using word-processing equipment. For reports completed by hand, please use black ink and CAPITAL LETTERS.

There are two ways you can send a completed paper STR form to FINTRAC:

  • by fax: 1-866-226-2346; or
  • by mail to the following address:

    Financial Transactions and Reports Analysis Centre of Canada
    Section A
    234 Laurier Avenue West, 24th floor
    Ottawa, ON  K1P 1H7
    CANADA

There is no official acknowledgement of receipt when you send a completed paper STR form to FINTRAC. However, FINTRAC will contact you and request that you resubmit electronically if you have the capability to do so.

4. Review and validation of reports by FINTRAC

FINTRAC reviews each report that is submitted to ensure that mandatory information is provided as per the PCMLTFA and associated Regulations. There are three types of validation rules that FINTRAC uses to validate reports and these rules are described below.

  • Presence – is there an entry in the field?
  • Format – is the entry in the correct structure?
  • Content – is the correct information entered in the appropriate field?

FINTRAC validation rules identify possible reporting problems or information gaps but do not cover all scenarios. While FINTRAC conducts a review of report submissions to assess the quality of reports, you should have your own proactive quality assurance practices independent of FINTRAC's review and validation of reports.

The report validation processes for FINTRAC web reporting and Batch are different. Each report validation process is described in more detail below.

FINTRAC web reporting report validation

Reports submitted through FINTRAC web reporting are immediately validated by the application. FINTRAC web reporting will indicate where information is missing, incorrect, or improperly formatted. You must correct all errors for mandatory fields before you can submit a report.

Batch report validation

Once a Batch file has been submitted, FINTRAC validates the Batch file against the validation rules. If there is an error with the structure or format of the file then you will receive a "Rejected" message and the Batch file and reports within it will not be processed any further. You must correct and resubmit the entire Batch file. Once you resubmit a Batch file, it is revalidated against all validation rules.

If there is a potential issue in a reporting field then you may also receive a "Warning" message. If you receive a "Warning" message, the report has been accepted by FINTRAC but you should review the information submitted for accuracy and completeness.

Once your Batch file has been accepted and validated, FINTRAC will send you a Batch "Acknowledgement" message that will include the validation rule number(s) for any report(s) that require further action and any warning messages.

See FINTRAC's Standard Batch Reporting Instructions and Specifications for more information.

5. Completing the STR form

FINTRAC's expectations for completing an STR

It is your responsibility to ensure that the information provided in an STR is complete and accurate. Your policies and procedures must include details on the process for how you identify, assess and submit STRs to FINTRAC. It is possible that your organization has an automated or triggering system that detects unusual or suspicious transactions that would require assessment by a person to determine if you must submit an STR. A person with the appropriate knowledge and training is expected to be able to determine whether a transaction is related to the commission or attempted commission of an ML/TF offence. It is also important to note that the value of the transaction is not always the most important aspect of an STR. Training employees to perform this function is considered to be part of your compliance program obligations.

Please note, an employee of a reporting entity can be considered a 'reporting entity' and report a completed or attempted suspicious transaction to FINTRAC when:

  • they have reasonable grounds to suspect that a transaction is related to the commission or attempted commission of an ML/TF offence; and
  • their employer did not or will not report.

This stipulation is in place to cover the rare instances where an individual suspects that the threshold to report has been reached and their employer did not or will not send an STR. No individual or entity will be prosecuted for sending an STR in good faith or for providing FINTRAC with information about suspicions of money laundering or terrorist financing. To submit an STR in this scenario, you may use the paper report form. For more information, please see field completion instructions to submit STRs by paper.

It is important to FINTRAC's analysis process and disclosure recipients that the STRs you submit are comprehensive and of high quality. In Part G or H of the STR, it is important to avoid jargon or non-public references, such as terms and acronyms that are specific to your organization. Please consider an outside reader and use simple, clear and concise language.

A variety of information is often collected as part of an assessment to determine if you are required to submit an STR and this information is valuable to include in your report to FINTRAC. A well-completed STR should consider the following questions.

  1. Who are the parties to the transaction?
    • List the conductor, beneficiary and holders of all accounts involved in the transaction.
    • Take reasonable measures to identify the conductor of the transaction. This means that you are expected to ask the client for this information unless you think doing so will tip them off to your suspicion.
    • Provide identifying information on the parties involved in the transaction. This could include the information you recorded to identify the conductor, as well as any information you have on the other parties to the transaction or its recipients.
    • List owners, directors, officers and those with signing authority, when possible. If the transaction involves a business, you could include information on the ownership, control and structure of the business in the STR.
    • Provide clear information about each individual or entity's role in each of the financial transactions described. It is important to know who is sending and receiving the funds and this may be relevant in Part G of the STR.
    • Explain the relationships among the individuals or entities (if known). This is very helpful to FINTRAC when trying to establish networks of individuals or entities suspected of being involved in the commission or attempted commission of an ML/TF offence.
  2. When was the transaction(s) completed/attempted? If it was not completed, why not?
  3. What are the financial instruments or mechanisms used to conduct the transaction?
  4. Where did this transaction take place?
  5. Why the transaction(s) or attempted transaction(s) are related to the commission or attempted commission of an ML/TF offence?
    • State the ML/TF indicators used to support your suspicion.
    • State the suspected criminal offence related to ML/TF, if known.
  6. How did the transaction take place?

Once you have reached reasonable grounds to suspect, you must keep reporting as long as the suspicion remains. You are expected to periodically re-assess the client to verify that the level of suspicion has not changed. This process may be part of your documented risk based approach or ongoing monitoring. If you continue to report STRs(s) on the same person or entity, you can reference a previous STR in Part G by:

  • entering the FINTRAC STR number and date of submission;
  • providing the reasonable grounds to suspect (facts, context and ML/TF indicators) that were included in the first STR submission; and
  • by providing any new additional information.

If you are reporting STRs because the assessment has changed due to new facts, context and/or ML/TF indicators, you are expected to provide them. For example, through the course of your assessment, you may have identified new ML/TF indicators or new parties transacting with your client. You may choose to include that information under a separate heading in Part G so that it is properly labeled as new information.

You must keep a copy of all STRs submitted to FINTRAC. For more information on your record keeping obligations related to STRs, see your sector specific record keeping guidance.

STR submission limitations

Each STR must include at least one transaction and may include up to 99 transactions as long as all the transactions:

  • have the same transaction status (e.g., all completed transactions or all attempted transactions); and
  • took place at the same location.

For example, someone brings a money order for $6,000 CAD and successfully sends an electronic funds transfer for $6,000 CAD (first completed transaction). Later that day, the same person returns to the same location and brings $5,000 CAD cash and receives a money order (second completed transaction). In this case, if there are reasonable grounds to suspect that the two completed transactions, conducted at the same location, are related to the commission or attempted commission of an ML/TF offence, you should provide the transaction details for the two transactions in the same STR. While the transactions may be referenced in Part G as part of the facts, context and/or ML/TF indicators, the transaction details themselves must be entered in Parts B1 through F.

In a situation where related suspicious transactions took place at different locations, an STR must be submitted for each location and only detail the transactions that occurred at that specific location. In addition, all transactions should have the same status as either completed or attempted to be included in a single report.

If you have more than 99 transactions to report at one time, you must submit the additional transaction(s) in a separate STR. You cannot insert a spreadsheet or include the additional transactions in Part G of the STR. If the information is available, you can reference related STRs in Part G by entering the FINTRAC STR number and date of submission.

Common STR deficiencies to avoid

The following are examples of deficiencies that FINTRAC has identified through its assessments and other compliance activities. FINTRAC is sharing these examples to illustrate common errors that you can avoid.

  • Using a higher threshold as your basis for reporting: You are required to submit an STR when you have determined that there are reasonable grounds to suspect that a transaction is related to the commission or attempted commission of an ML/TF offence. This means that there is a possibility of an ML/TF offence and that you do not have to prove the facts or information that led to your suspicion.

    In some cases, it is possible that you have determined that there are reasonable grounds to believe that the transaction is related to the commission or attempted commission of an ML/TF offence. Reasonable grounds to believe means that there are verified facts that support the probability that an ML/TF offence has occurred. In other words, there is enough evidence to support a reasonable and trained person to believe, not just suspect, that ML/TF has occurred.

    If you identify a transaction whereby you reach reasonable grounds to believe that an ML/TF offence has occurred, you must begin an assessment of the related transactions immediately as you have surpassed the RGS threshold. If assessed by FINTRAC and there are reasonable grounds to believe that a transaction is related to the commission of an ML/TF offence, and you have not begun an assessment of the facts, context or ML/TF indicators, you may be sighted for a missed STR.

  • Failing to list all the transactions and accounts relevant to your suspicion in Parts B through F: You are required to report all the transactions and accounts in Parts B through F that led to your determination that there are reasonable grounds to suspect that the transaction is related to the commission or attempted commission of an ML/TF offence. Providing a summary of the transactions in Part G is not enough.
  • Not listing or naming all parties to the transactions when the information is available: All parties to the transaction must be listed, including third parties. You should also specify whether the parties are known or unknown. This has been observed in transactions involving multiple parties such as wire transfers. For example, if you are reporting a wire transfer, you should include any information you have regarding both the ordering client and beneficiary. This could include (but is not limited to) their names, their account number and institution, their relationship, and any known identifiers. FINTRAC acknowledges that this information may not always be at your disposal, but when you know it, it should be provided.
  • Part G does not elaborate on your grounds for suspicion or link them to the transactions reported in Parts B through F: You are required to articulate the reasons for your determination that there are reasonable grounds to suspect that the transaction is related to the commission or attempted commission of an ML/TF offence in an STR. This includes providing all of the relevant facts, context and ML/TF indicators related to the transactions reported in Parts B through F that support your suspicion in Part G. This deficiency has been observed when a reporting entity does not articulate the reasons for their suspicion or does not explain how or why certain information is relevant to their suspicion.

6. Field completion instructions

**Note: Unless otherwise stated, this section details specific instructions that apply to both electronic and paper reporting.

Parts of a suspicious transaction report

STRs contain eight specific parts:

  • Part A: Information about where the transaction took place

    In Part A of the STR, you must provide information about you as the reporting entity, and about the physical location where the completed or attempted suspicious transaction took place.

    When completing Part A it is important to note that:

    • Reporting entity's full name is your entity's full legal name. Even if you have entered into a contractual relationship with another entity to conduct transactions on your behalf, it is your name that must be entered into this field.
    • Reporting entity number is the number that was assigned to you when you enrolled in FINTRAC web reporting.
    • Reporting entity location number is the location number where the transaction took place or was attempted. If you have multiple locations, your FINTRAC web reporting administrator is responsible for adding the other locations, as well as maintaining the location information.
    • Reporting entity report reference number is a unique internal reference number generated by your entity. The recording of the internal reference number on the STR may help you to quickly identify the report if required to at a later date.
    • Activity Sector is the type of business and/or activities you undertake.
  • Part B1: Information about how the transaction was initiated

    In Part B1 of the STR, you must provide the date of the transaction, the transaction amount, the detail of the funds involved in initiating the transaction, how the transaction was conducted, as well as information on any other institution, entity or individual that was involved in the transaction.

    When completing Part B1 it is important to note that:

    • the date of transaction is the date that the transaction occurred. Whereas, the date of posting is the date on which the funds from the transaction are received in an account; and
    • you must provide (if applicable) the name of any other person or entity or the name and number of the other institution involved in the initiation of the transaction.

    If you need to report more than one transaction in an STR, a separate Part B1 will have to be completed for each transaction.

  • Part B2: Information about how the transaction was completed

    In Part B2 of the STR, you must detail:

    • how the funds were used in the completed transaction or how they were going to be used in an attempted transaction; and
    • whether the individual who conducted or attempted the suspicious transaction did so on anyone else's behalf.

    The funds in a transaction may have been used in several ways, therefore resulting in more than one disposition having to be detailed in your STR. For example, your client may initiate a transaction in cash, then use some of the funds to send an electronic funds transfer (disposition 1), order a bank draft (disposition 2), and deposit the remaining funds (disposition 3). If there is more than one disposition, you will need to complete a separate Part B2 for each disposition.

  • Part C: Account information, if the transaction involved an account

    In Part C of the STR, you must provide the account details for each disposition that involved an account (completed transaction) or was going to involve an account (attempted transaction), if applicable. For example, if the related disposition was a "Deposit', this part is required.

  • Part D: Information about the individual conducting the transaction

    In Part D of the STR, you must provide information about the individual who completed or attempted to complete the transaction.

    If more than one transaction is reported in an STR, a separate Part D will have to be completed for each transaction.

  • Part E: Information about the entity on whose behalf the transaction was conducted

    In Part E of the STR, if applicable, you must provide information about the entity on whose behalf the transaction was conducted or attempted.

    Part E needs to be completed if you indicated in Part B2 that the transaction was conducted "On behalf of an entity".

    A separate Part E must be completed for each disposition that was conducted or attempted on behalf of an entity.

  • Part F: Information about the individual on whose behalf the transaction was conducted

    In Part F of the STR, if applicable, you must provide information about the individual on whose behalf the transaction was conducted or attempted.

    Part F must be completed if you indicated in Part B2 that the transaction was conducted "On behalf of another individual."

    A separate Part F must be completed for each disposition that was conducted or attempted on behalf of another individual.

  • Part G: Description of suspicious transaction and any facts or context associated with the suspicion

    This section is the narrative that explains your grounds for suspicion and should include the results of your assessment of facts, context and ML/TF indicators that led to your decision to submit an STR to FINTRAC. The narrative should include the explanation of this assessment and should not assume that the reader will be familiar with acronyms or terminology specific to your business. Detailed and high quality STRs provide valuable and actionable intelligence for FINTRAC and this section is shared with law enforcement and intelligence agencies in FINTRAC disclosures.

    The narrative provided in this section should focus on the question: "Why do you think the transaction is suspicious of ML/TF?"

    The following are examples of the type of information that, when available, have been provided in STRs and have contributed greatly to FINTRAC analysis:

    • any client identification information not already captured in the transaction details listed in part B, i.e., known aliases or nicknames;
    • additional contact information (phone numbers, email addresses, etc.);
    • details for credit card activity including details of purchases (dates, amounts, retailer (online or in-store) and details of payments (dates, amounts, conductor and source of payment);
    • details for electronic transfers (such as e-mail money transfers, wire transfers) including IP addresses and sender/recipient email addresses;
    • location of ATM withdrawals;
    • any related STR number(s) and the date(s) previously submitted;
    • the history the client has with you;
    • links made to other people, businesses and accounts;
    • information on the ownership, control and structure of an entity that is not already captured in Part B, particularly for any business entities that have a complex structure;
    • the intended or expected use of an account versus the activity you may have observed;
    • any other information about your interactions with the client;
    • the ML/TF indicators or factors that assisted in forming the basis of your suspicion;
    • any information, including publicly available information and/or information from law enforcement, that made you suspect distinctly that the transaction might be related to terrorist financing, money laundering, or both;
    • any details surrounding why an attempted transaction was not completed; and
    • any context or clarification about the information that was reported in the structured sections (Parts B through F).

    FINTRAC has been able to identify networks of suspected money launderers and terrorist financiers through pieces of information such as email addresses and secondary identifiers (nicknames) or phone numbers. This type of information may seem insignificant but can be very important to FINTRAC, as it may identify connections among individuals, entities or crimes when compared against other FINTRAC intelligence.

    It is important that your narrative is consistent with the information in Parts B through F of the STR form. For example, if you are referring to specific account activity in this section the details of those accounts and transactions should be entered in the structured fields. It is also important that you do not refer to any internal files or documents since FINTRAC cannot have access to these internal files or documents for its analysis. It is also not possible to see graphics, underlined, italicized or bolded text included in the STR.

  • Part H: Description of action taken

    Describe any actions taken by you, in addition to reporting to FINTRAC, in response to the suspicious transaction.

    Examples of additional actions that you may take include:

    • reporting the information directly to law enforcement;
    • initiating enhanced transaction monitoring;
    • closing the account(s) in question or exiting the business relationship; and/or
    • cancelling, reversing or rejecting the transaction.

    Reporting an STR to FINTRAC does not prevent you from contacting law enforcement directly. However, even if you do contact law enforcement directly about your suspicions of money laundering or terrorist financing, you must still submit an STR to FINTRAC. Some STRs have included the law enforcement agency's contact information in Part H of the STR when the information was reported directly to law enforcement and this information can be helpful.

Standardized field instructions

This section includes standardized instructions for the level of effort that is required for certain fields as well as standard instructions for completing fields for identification, addresses, telephone numbers and occupation.

  1. Each field within an STR is categorized as either mandatory, mandatory if applicable, or reasonable measures.
    1. Mandatory:
      • Mandatory fields require you to obtain the information to complete the STR and will be marked with an asterisk (*).
      • However, in the case of an attempted transaction, you are to take reasonable measures to obtain the information for any mandatory field.
    2. Mandatory, if applicable:
      • Mandatory if applicable fields must be completed if they are applicable to you or the transaction being reported. If applicable, you must provide the information if you obtained it at the time of the transaction, or if it is contained within your institution.
      • These fields will be indicated with both an asterisk (*) and "(if applicable)" next to them.
    3. Reasonable measures:
      • For all other fields that do not have an asterisk, you must take reasonable measures to obtain the information.
      • Reasonable measures can include asking for the information as long as you don't think it will tip off the person that you are submitting an STR.
      • Reasonable measures also means that you must provide the information if you obtained it at the time of the transaction, or if it is contained within your institution.

      **Note: In certain circumstances a required report field may not be applicable. Do not enter "N/A" or "n/a" or substitute any other abbreviations, special characters (e.g., "x", "-" or "*") or words (e.g., unknown) in these fields. They are to be left blank.

  2. Client identification

    If you used the dual process method to identify an individual, you only need to provide the details of one of the identifiers. You can use your judgement to determine which identifier would be most advantageous to FINTRAC analysis. Please note that a Social Insurance Number (SIN) must not be reported to FINTRAC.

    The record keeping requirement for the dual process method includes the source of the information, so FINTRAC expects the issuing jurisdiction and country to align with the source of the information, but would only expect, as per the validation rules, that the reporting entity include the country of issue for the dual process method.

    In addition, you cannot use a provincial health card for identification purposes where it is prohibited by provincial legislation.

    For more information on how to identify individuals and examples of acceptable photo identification documents, refer to FINTRAC's guidance on Methods to verify the identity of an individual and confirm the existence of a corporation or an entity other than a corporation.

  3. On behalf of indicator

    Applies to Part B2 of an STR.

    You are required to take reasonable measures to determine if there is a third party instructing your client to conduct an activity or a transaction. Reasonable measures include asking your client if they are acting on someone else's instructions or retrieving the information that may already be contained in your records.

    When determining whether an individual has conducted or attempted a suspicious transaction on anyone else's behalf, it is not about who owns or benefits from the money, or who is carrying out the transaction or activity, but rather about who gives the instructions to handle the money or conduct the transaction or particular activity. Refer to FINTRAC's guidance on third party determination requirements for more information including the record keeping requirements.

    If you determine that a third party was instructing your client, then you must indicate if the transaction was conducted on behalf of an entity or on behalf of another individual.

    When an individual is acting on behalf of their employer, the employer is considered to be the third party, unless the individual is conducting a cash deposit to the employer's business account. If there is no third party, or you were not able to determine whether there is a third party, then indicate that this part is not applicable.

  4. Address fields

    Applies to the following fields of an STR:

    • A3* – A6* (mandatory)
    • D5 – D9
    • D20 – D24
    • E3 – E7
    • F4 – F8
    • F19 – F23

    The complete physical address includes the street number, street name, the city, province, and country. If there is no province or state applicable to the address, leave this field blank.

    Please note that the following are not valid addresses and should not be provided:

    • a post office box without a complete physical address (e.g., PO Box 333);
    • a general delivery address; or
    • only a suite number (e.g., Suite 256) without additional address information.

    It is possible that some of the examples above may be included in Part G of the STR because they are relevant but they are not considered a valid address in terms of the client identification.

    In cases where the individual or entity resides in an area where there is no street address, provide a detailed description which clearly describes the physical location. For example, in these unique cases you could enter "the third house to the right after the community center" as the street address where an individual lives.

    A legal land description can be acceptable so long as the legal land description is specific enough to pinpoint the physical location of where the client lives. If the legal land description refers to an area or a parcel of land on which multiple properties are located, the legal land description would not be sufficient.

    For individuals who are transient (e.g., travelling in a recreational vehicle, temporarily working in a camp, etc.) and have no fixed address, you are required to provide the following:

    • for Canadian residents, their permanent address is required, even if that is not where they are currently residing;
    • for non-Canadian residents travelling in Canada for a short period of time, their foreign residential address is required; and
    • for non-Canadian residents living in Canada for a longer period of time (e.g., a student), then the individual's temporary Canadian address should be provided.
  5. Telephone number fields

    Applies to the following fields of an STR:

    • A10* – A10A
    • D11
    • D18 – D18A
    • D25 – D25A
    • E8 – E8A
    • F9
    • F10 – F10A
    • F24 – F24A

    If the telephone number is from Canada or the United States, enter the area code and local number (e.g., 999-999-9999).

    If the telephone number is from outside Canada or the United States, enter the country code, city code and local number using 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.

  6. Occupation fields

    Applies to the following fields of an STR:

    • D17
    • F17

    When entering an individual's occupation information, you must be as descriptive as possible. For example:

    • If the individual is a manager, the occupation provided should reflect the area of management, such as "hotel reservations manager" or "retail clothing store manager."
    • If the individual is a consultant, the occupation provided should reflect the type of consulting, such as "IT consultant" or "forestry consultant".
    • If the individual is a professional, the occupation provided should reflect the type of profession, such as "petroleum engineer" or "family physician".
    • If the individual is a labourer, the occupation provided should reflect the type of labour performed, such as "road construction worker" or "landscape labourer".
    • If the individual is not working, the occupation provided should still be as descriptive as possible, such as "student", "unemployed" or "retired".
Date Modified: