Reporting suspicious transactions to FINTRAC
This guidance came 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:
- What is a suspicious transaction report?
- Money laundering (ML) and terrorist financing (TF) indicators (ML/TF indicators)
**Note: All references to financial transactions should be read to include attempted or completed financial transactions.
This guidance provides information on the following topics:
- When must a suspicious transaction be reported?
- Service provider agreements
- How to submit STRs
- Review and validation of reports by FINTRAC
- Completing the STR form
- Field completion instructions
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.
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.
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 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.
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
234 Laurier Avenue West, 24th floor
Ottawa, ON K1P 1H7
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.
- 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.
- When was the transaction(s) completed/attempted? If it was not completed, why not?
- What are the financial instruments or mechanisms used to conduct the transaction?
- Where did this transaction take place?
- 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.
- 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.
- Each field within an STR is categorized as either mandatory, mandatory if applicable, or reasonable measures.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- Telephone number fields
Applies to the following fields of an STR:
- A10* – A10A
- D18 – D18A
- D25 – D25A
- E8 – E8A
- 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.
- Occupation fields
Applies to the following fields of an STR:
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".
A chartered accountant, a certified general accountant, a certified management accountant or, if applicable, a chartered professional accountant.Footnote 1 (comptable)
- Accounting firm
An entity that is engaged in the business of providing accounting services to the public and has at least one partner, employee or administrator that is an accountant.Footnote 2 (cabinet d'expertise comptable)
The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).Footnote 3 (la Loi)
- Administrative monetary penalties (AMPs)
Civil penalties that may be issued to reporting entities by FINTRAC for non-compliance with the PCMLTFA and associated Regulations. (pénalité administrative pécuniaire [PAP])
An entity is affiliated with another entity if one of them is wholly owned by the other, if both are wholly owned by the same entity or if their financial statements are consolidated.Footnote 4 (entité du même groupe)
- As soon as practicable
A time period that falls in-between immediately and as soon as possible, within which a suspicious transaction report (STR) must be submitted to FINTRAC. The completion and submission of the STR should take priority over other tasks. In this context, the report must be completed promptly, taking into account the facts and circumstances of the situation. While some delay is permitted, it must have a reasonable explanation. (aussitôt que possible)
- Attempted transaction
Occurs when an individual or entity starts to conduct a transaction that is not completed. For example, a client or a potential client walks away from conducting a $10,000 cash deposit. (opération tentée)
In respect of a government-issued photo identification document that is used to verify identity, is genuine and has the character of an original, credible, and reliable document issued by the competent authority (such as federal, provincial, or territorial governments). (authentique)
- Authorized person
A person who is authorized under subsection 45(2).Footnote 6 (personne autorisée)
- Authorized user
A person who is authorized by a holder of a prepaid payment product account to have electronic access to funds or virtual currency available in the account by means of a prepaid payment product that is connected to it.Footnote 7 (utilisateur autorisé)
- Beneficial Owner(s)
Beneficial owners are the individuals who are the trustees, and known beneficiaries and settlors of a trust, or who directly or indirectly own or control 25% or more of i) the shares of a corporation or ii) an entity other than a corporation or trust, such as a partnership. The ultimate beneficial owner(s) cannot be another corporation or entity; it must be the actual individual(s) who owns or controls the entity. (bénéficiaire effectif)
A beneficiary is the individual or entity that will benefit from a transaction or to which the final remittance is made. (bénéficiaire)
A branch is a part of your business at a distinct location other than your main office. (succursale)
- British Columbia notary corporation
An entity that carries on the business of providing notary services to the public in British Columbia in accordance with the Notaries Act, R.S.B.C. 1996, c. 334.Footnote 8 (société de notaires de la Colombie-Britannique)
- British Columbia notary public
A person who is a member of the Society of Notaries Public of British Columbia.Footnote 9 (notaire public de la Colombie-Britannique)
Coins referred to in section 7 of the Currency Act, notes issued by the Bank of Canada under the Bank of Canada Act that are intended for circulation in Canada or coins or bank notes of countries other than Canada.Footnote 10 (espèces)
A government, organization, board or operator that is referred to in any of paragraphs 5(k) to (k.3) of the Act.Footnote 11 (casino)
- Certified translator
An individual that holds the title of professional certified translator granted by a Canadian provincial or territorial association or body that is competent under Canadian provincial or territorial law to issue such certification. (traducteur agréé)
- Clarification request
A clarification request is a method used to communicate with money services businesses (MSBs) or foreign money services businesses (FMSBs) when FINTRAC needs more information about their registration form. This request is usually sent by email. (demande de précisions)
A person or entity that engages in a financial transaction with another person or entity.Footnote 12 (client)
- Client identification information
The identifying information that you have obtained on your clients, such as name, address, telephone number, occupation or nature of principal business, and date of birth for an individual. (renseignements d'identification du client)
- Competent authority
For the purpose of the criminal record check submitted with an application for registration, a competent authority is any person or organization that has the legally delegated or invested authority, capacity, or power to issue criminal record checks. (autorité compétente)
- Completed transaction
Is a transaction conducted by a person or entity, that is completed and results in the movement of funds, virtual currency, or the purchase or sale of an asset. (opération effectuée)
- Compliance officer
The individual, with the necessary authority, that you appoint to be responsible for the implementation of your compliance program. (agent de conformité)
- Compliance policies and procedures
Written methodology outlining the obligations applicable to your business under the PCMLTFA and its associated Regulations and the corresponding processes and controls you put in place to address your obligations. (politiques et procédures de conformité)
- Compliance program
All elements (compliance officer, policies and procedures, risk assessment, training program, effectiveness review) that you, as a reporting entity, are legally required to have under the PCMLTFA and its associated Regulations to ensure that you meet all your obligations. (programme de conformité)
Clarifies a set of circumstances or provides an explanation of a situation or financial transaction that can be understood and assessed. (contexte)
- Correspondent banking relationship
A relationship created by an agreement or arrangement under which an entity referred to in any of paragraphs 5(a), (b), (d) and (e) or an entity that is referred to in section 5 of the Act and that is prescribed undertakes to provide to a foreign financial institution services such as international electronic funds transfers, cash management, cheque clearing and any prescribed services.Footnote 13 (relation de correspondant bancaire)
- Country of residence
The country where an individual has lived continuously for 12 months or more. The individual must have a dwelling in the country concerned. For greater certainty, a person only has one country of residence no matter how many dwelling places they may have, inside or outside of that country. (pays de résidence)
- Credit card acquiring business
A credit card acquiring business is a financial entity that has an agreement with a merchant to provide the following services:
- enabling a merchant to accept credit card payments by cardholders for goods and services and to receive payments for credit card purchases;
- processing services, payment settlements and providing point-of-sale equipment (such as computer terminals); and
- providing other ancillary services to the merchant.
- Credit union central
A central cooperative credit society, as defined in section 2 of the Cooperative Credit Associations Act, or a credit union central or a federation of credit unions or caisses populaires that is regulated by a provincial Act other than one enacted by the legislature of Quebec.Footnote 14 (centrale de caisses de crédit)
In respect of a document or source of information that is used to verify identity, is up to date, and, in the case of a government-issued photo identification document, must not have been expired when the ID was verified. (à jour)
- Dealer in precious metals and stones
A person or entity that, in the course of their business activities, buys or sells precious metals, precious stones or jewellery. It includes a department or an agent of Her Majesty in right of Canada or an agent or mandatary of Her Majesty in right of a province when the department or the agent or mandatary carries out the activity, referred to in subsection 65(1), of selling precious metals to the public.Footnote 15 (négociant en métaux précieux et pierres précieuses)
- Deferred profit sharing plan
- Deposit slip
A record that sets out:Footnote 17
- (a) the date of the deposit;
- (b) the name of the person or entity that makes the deposit;
- (c) the amount of the deposit and of any part of it that is made in cash;
- (d) the method by which the deposit is made; and
- (e) the number of the account into which the deposit is made and the name of each account holder.
- Directing Services
A business is directing services at persons or entities in Canada if at least one of the following applies:
- The business's marketing or advertising is directed at persons or entities located in Canada;
- The business operates a ".ca" domain name; or,
- The business is listed in a Canadian business directory.
Additional criteria may be considered, such as if the business describes its services being offered in Canada or actively seeks feedback from persons or entities in Canada. (diriger des services)
- Distributed ledger
For the purpose of section 151 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), a digital ledger that is maintained by multiple persons or entities and that can only be modified by a consensus of those persons or entities. Footnote 18 (registres distribués)
With respect to a reportable transaction, the disposition is what the funds or virtual currency was used for. For example, an individual arrives at a bank with cash and purchases a bank draft. The disposition is the purchase of the bank draft. (répartition)
- Electronic funds transfer
The transmission—by any electronic, magnetic or optical means—of instructions for the transfer of funds, including a transmission of instructions that is initiated and finally received by the same person or entity. In the case of SWIFT messages, only SWIFT MT-103 messages and their equivalent are included. It does not include a transmission or instructions for the transfer of funds: Footnote 19
- (a) that is carried out by means of a credit or debit card or a prepaid payment product if the beneficiary has an agreement with the payment service provider that permits payment by that means for the provision of goods and services;
- (b) that involves the beneficiary withdrawing cash from their account;
- (c) that is carried out by means of a direct deposit or pre-authorized debit;
- (d) that is carried out by cheque imaging and presentment
- (e) that is both initiated and finally received by persons or entities that are acting to clear or settle payment obligations between themselves; or
- (f) that is initiated or finally received by a person or entity referred to in paragraphs 5(a) to (h.1) of the Act for the purpose of internal treasury management, including the management of their financial assets and liabilities, if one of the parties to the transaction is a subsidiary of the other or if they are subsidiaries of the same corporation.
- Employees profit sharing plan
A body corporate, a trust, a partnership, a fund or an unincorporated association or organization.Footnote 21 (entité)
Actual events, actions, occurrences or elements that exist or are known to have happened or existed. Facts are not opinions. For example, facts surrounding a transaction or multiple transactions could include the date, time, location, amount or type of transaction or could include the account details, particular business lines, or the client's financial history. (faits)
- Family member
For the purposes of subsection 9.3(1) of the Act, a prescribed family member of a politically exposed foreign person, a politically exposed domestic person or a head of an international organization is:Footnote 22
- (a) their spouse or common-law partner;
- (b) their child;
- (c) their mother or father;
- (d) the mother or father of their spouse or common-law partner; or
- (e) a child of their mother or father.
- Fiat currency
A currency that is issued by a country and is designated as legal tender in that country.Footnote 23 (monnaie fiduciaire)
- Final receipt
In respect of an electronic funds transfer, means the receipt of the instructions by the person or entity that is to make the remittance to a beneficiary.Footnote 24 (destinataire)
- Financial entity
Means: Footnote 25
- (a) an entity that is referred to in any of paragraphs 5(a), (b) and (d) to (f) of the Act;
- (b) a financial services cooperative;
- (c) a life insurance company, or an entity that is a life insurance broker or agent, in respect of loans or prepaid payment products that it offers to the public and accounts that it maintains with respect to those loans or prepaid payment products, other than:
- (iii) advance payments to which the policy holder is entitles that are made to them by the insurer;
- (d) a credit union central when it offers financial services to a person, or to an entity that is not a member of that credit union central; and
- (e) a department, or an entity that is an agent of Her Majesty in right of Canada or an agent or mandatary of Her Majesty in right of a province, when it carries out an activity referred to in section 76.
- Financial Action Task Force
The Financial Action Task Force on Money Laundering established in 1989.Footnote 26 (Groupe d'action financière)
- Financial services cooperative
A financial services cooperative that is regulated by an Act respecting financial services cooperatives, CQLR, c. C-67.3, other than a caisse populaire.Footnote 27 (coopérative de services financiers)
- Foreign currency
A fiat currency that is issued by a country other than Canada.Footnote 28 (devise)
- Foreign currency exchange transaction
An exchange, at the request of another person or entity, of one fiat currency for another. Footnote 29 (opération de change en devise)
- Foreign currency exchange transaction ticket
A record respecting a foreign currency exchange transaction—including an entry in a transaction register—that sets out: Footnote 30
- (a) the date of the transaction;
- (b) in the case of a transaction of $3,000 or more, the name and address of the person or entity that requests the exchange, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
- (c) the type and amount of each of the fiat currencies involved in the payment made and received by the person or entity that requests the exchange;
- (d) the method by which the payment is made and received;
- (e) the exchange rates used and their source;
- (f) the number of every account that is affected by the transaction, the type of account and the name of each account holder; and
- (g) every reference number that is connected to the transaction and has a function equivalent to that of an account number.
- Foreign money services business
Persons and entities that do not have a place of business in Canada, that are engaged in the business of providing at least one of the following services that is directed at persons or entities in Canada, and that provide those services to their clients in Canada: Footnote 31
- (i) foreign exchange dealing,
- (iv) dealing in virtual currencies, or
- (v) any prescribed service.
- Foreign state
Except for the purposes of Part 2 of the Act, means a country other than Canada and includes any political subdivision or territory of a foreign state.Footnote 32 (État étranger)
- (a) cash and other fiat currencies, and securities, negotiable instruments or other financial instruments that indicate a title or right to or interest in them; or
- (b) a private key of a cryptographic system that enables a person or entity to have access to a fiat currency other than cash.
For greater certainty, it does not include virtual currency.Footnote 33 (fonds)
- Head of an international organization
A person who, at a given time, holds—or has held within a prescribed period before that time—the office or position of head of an international organization that is established by the governments of states or the head of an institution of any such organization.Footnote 34 (dirigeant d'une organisation internationale)
- Information record
A record that sets out the name and address of a person or entity and:Footnote 35
- (a) in the case of a person, their date of birth and the nature of their principal business or their occupation; and
- (b) in the case of an entity, the nature of its principal business.
In respect of an electronic funds transfer, means the first transmission of the instructions for the transfer of funds.Footnote 36 (amorcer)
- Institutional trust
For the purpose of section 15 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), means a trust that is established by a corporation or other entity for a particular business purpose and includes a pension plan trust, a pension master trust, a supplemental pension plan trust, a mutual fund trust, a pooled fund trust, a registered retirement savings plan trust, a registered retirement income fund trust, a registered education savings plan trust, a group registered retirement savings plan trust, a deferred profit sharing plan trust, an employee profit sharing plan trust, a retirement compensation arrangement trust, an employee savings plan trust, a health and welfare trust, an unemployment benefit plan trust, a foreign insurance company trust, a foreign reinsurance trust, a reinsurance trust, a real estate investment trust, an environmental trust and a trust established in respect of endowment, a foundation or a registered charity.Footnote 37 (fiducie institutionnelle)
- International electronic funds transfer
An electronic funds transfer other than for the transfer of funds within Canada.Footnote 38 (télévirement international)
- Inter vivos trust
A personal trust, other than a trust created by will. Footnote 39 (fiducie entre vifs)
Objects that are made of gold, silver, palladium, platinum, pearls or precious stones and that are intended to be worn as a personal adornment.Footnote 40 (bijou)
- Large cash transaction record
A record that indicates the receipt of an amount of $10,000 or more in cash in a single transaction and that contains the following information:Footnote 41
- (a) the date of the receipt;
- (b) if the amount is received for deposit into an account, the number of the account, the name of each account holder and the time of the deposit or an indication that the deposit is made in a night deposit box outside the recipient's normal business hours;
- (d) the type and amount of each fiat currency involved in the receipt;
- (e) the method by which the cash is received;
- (f) if applicable, the exchange rates used and their source;
- (g) the number of every other account that is affected by the transaction, the type of account and the name of each account holder
- (h) every reference number that is connected to the transaction and has a function equivalent to that of an account number;
- (i) the purpose of the transaction;
- (j) the following details of the remittance of, or in exchange for, the cash received:
- (i) the method of remittance;
- (ii) if the remittance is in funds, the type and amount of each type of funds involved;
- (k) if the amount is received by a dealer in precious metals and precious stones for the sale of precious metals, precious stones or jewellery:
- (i) the type of precious metals, precious stones or jewellery;
- (iii) the wholesale value of the precious metals, precious stones or jewellery.
- Large virtual currency transaction record
A record that indicates the receipt of an amount of $10,000 or more in virtual currency in a single transaction and that contains the following information:Footnote 42
- (a) the date of the receipt;
- (b) if the amount is received for deposit into an account, the name of each account holder;
- (d) the type and amount of each virtual currency involved in the receipt;
- (e) the exchange rates used and their source;
- (f) the number of every other account that is affected by the transaction, the type of account and the name of each account holder;
- (g) every reference number that is connected to the transaction and has a function equivalent to that of an account number;
- (h) every transaction identifier, including the sending and receiving addresses; and
- (i) if the amount is received by a dealer in precious metals and precious stones for the sale of precious metals, precious stones or jewellery:
- (i) the type of precious metals, precious stones or jewellery;
- (iii) the wholesale value of the precious metals, precious stones or jewellery
- Life insurance broker or agent:
A person or entity that is authorized under provincial legislation to carry on the business of arranging contracts of life insurance.Footnote 43 (représentant d'assurance-vie)
- Life insurance company
- Listed person
Has the same meaning as in section 1 of the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism.Footnote 45 (personne inscrite)
- Managing general agents (MGAs)
Life insurance brokers or agents that act as facilitators between other life insurance brokers or agents and life insurance companies. MGAs typically offer services to assist with insurance agents contracting and commission payments, facilitate the flow of information between insurer and agent, and provide training to, and compliance oversight of, insurance agents.(agent général de gestion)
A person who acts, under a mandate or agreement, for another person or entity. (mandataire)
- Marketing or Advertising
When a person or entity uses promotional materials such as advertisements, graphics for websites or billboards, etc., with the intent to promote money services business (MSB) services and to acquire business from persons or entities in Canada. (marketing ou publicité)
In relation to sections 24.1 to 39, the Minister of Public Safety and Emergency Preparedness and, in relation to any other provision of this Act, the Minister of Finance.Footnote 46 (ministre)
- Money laundering offence
An offence under subsection 462.31(1) of the Criminal Code.Footnote 47 The United Nations defines money laundering as "any act or attempted act to disguise the source of money or assets derived from criminal activity." Essentially, money laundering is the process whereby "dirty money"—produced through criminal activity—is transformed into "clean money," the criminal origin of which is difficult to trace. (infraction de recyclage des produits de la criminalité)
- Money laundering and terrorist financing indicators (ML/TF indicators)
Potential red flags that could initiate suspicion or indicate that something may be unusual in the absence of a reasonable explanation. [Indicateurs de blanchiment d'argent (BA) et de financement du terrorisme (FT) (indicateurs de BA/FT)]
- Money services business
A person or entity that has a place of business in Canada and that is engaged in the business of providing at least one of the following services: Footnote 48
- (i) foreign exchange dealing,
- (iv) dealing in virtual currencies, or
- (v) any prescribed service.
- Money services business agent
An individual or entity authorized to deliver services on behalf of a money services business (MSB). It is not an MSB branch. (mandataire d'une entreprise de services monétaires)
- Nature of principal business
An entity's type or field of business. Also applies to an individual in the case of a sole proprietorship. (nature de l'entreprise principale)
- New developments
Changes to the structure or operations of a business when new services, activities, or locations are put in place. For example, changes to a business model or business restructuring. (nouveaux développements)
- New technologies
The adoption of a technology that is new to a business. For example, when a business adopts new systems or software such as transaction monitoring systems or client onboarding and identification tools. (nouvelles technologies)
- No apparent reason
There is no clear explanation to account for suspicious behaviour or information. (sans raison apparente)
The job or profession of an individual. (profession ou métier)
An individual.Footnote 49 (personne)
- Politically exposed domestic person
A person who, at a given time, holds—or has held within a prescribed period before that time—one of the offices or positions referred to in any of paragraphs (a) to (j) in or on behalf of the federal government or a provincial government or the office or position referred to in paragraph (k) in a municipal government:Footnote 50
- (a) Governor General, lieutenant governor or head of government;
- (b) member of the Senate or House of Commons or member of a legislature;
- (c) deputy minister or equivalent rank;
- (d) ambassador, or attaché or counsellor of an ambassador;
- (e) military officer with a rank of general or above;
- (f) president of a corporation that is wholly owned directly by Her Majesty in right of Canada or a province;
- (g) head of a government agency;
- (h) judge of an appellate court in a province, the Federal Court of Appeal or the Supreme Court of Canada;
- (i) leader or president of a political party represented in a legislature;
- (j) holder of any prescribed office or position; or
- (k) mayor
- Politically exposed foreign person
A person who holds or has held one of the following offices or positions in or on behalf of a foreign state:Footnote 51
- (a) head of state or head of government;
- (b) member of the executive council of government or member of a legislature;
- (c) deputy minister or equivalent rank;
- (d) ambassador, or attaché or counsellor of an ambassador;
- (e) military officer with a rank of general or above;
- (f) president of a state-owned company or a state-owned bank;
- (g) head of a government agency;
- (h) judge of a supreme court, constitutional court or other court of last resort;
- (i) leader or president of a political party represented in a legislature; or
- (j) holder of any prescribed office or position.
In regards to completing a suspicious transaction report (STR), the likelihood that a transaction may be related to a money laundering/terrorist financing (ML/TF) offence. For example, based on your assessment of facts, context and ML/TF indicators you have reasonable grounds to suspect that a transaction is related to the commission or attempted commission of an ML/TF offence. (possibilité)
- Precious metal
Gold, silver, palladium or platinum in the form of coins, bars, ingots or granules or in any other similar form.Footnote 52 (métal précieux)
- Precious stones
Diamonds, sapphires, emeralds, tanzanite, rubies or alexandrite.Footnote 53 (pierre précieuse)
- Prepaid payment product
A product that is issued by a financial entity and that enables a person or entity to engage in a transaction by giving them electronic access to funds or virtual currency paid to a prepaid payment product account held with the financial entity in advance of the transaction. It excludes a product that: Footnote 54
- (a) enables a person or entity to access a credit or debit account or one that is issued for use only with particular merchants; or
- (b) is issued for single use for the purposes of a retail rebate program.
- Prepaid payment product account
An account – other than an account to which only a public body or, if doing so for the purposes of humanitarian aid, a registered charity as defined in subsection 248(1) of the Income Tax Act, can add funds or virtual currency – that is connected to a prepaid payment product and that permits:Footnote 55
- (a) funds or virtual currency that total $1,000 or more to be added to the account within a 24-hour period; or
- (b) a balance of funds or virtual currency of $1,000 or more to be maintained.
Prescribed by regulations made by the Governor in Council.Footnote 56 (Version anglaise seulement)
The likelihood in regards to completing a suspicious transaction report (STR) that a financial transaction is related to a money laundering/terrorist financing (ML/TF) offence. For example, based on facts, having reasonable grounds to believe that a transaction is probably related to the commission or attempted commission of an ML/TF offence. (probabilité)
- Production order
A judicial order that compels a person or entity to disclose records to peace officers or public officers. (ordonnance de communication)
- Public body
- (a) a department or an agent of Her Majesty in right of Canada or an agent or mandatary of Her Majesty in right of a province;
- (b) an incorporated city or town, village, metropolitan authority, township, district, county, rural municipality or other incorporated municipal body in Canada or an agent or mandatary in Canada of any of them; and
- (c) an organization that operates a public hospital and that is designated by the Minister of National Revenue as a hospital authority under the Excise Tax Act, or an agent or mandatary of such an organization.Footnote 57
- Real estate broker or sales representative
A person or entity that is authorized under provincial legislation to act as an agent or mandatary for purchasers or vendors in respect of the purchase or sale of real property or immovables.Footnote 58 (courtier ou agent immobilier)
- Real estate developer
A person or entity that, in any calendar year after 2007, has sold to the public, other than in the capacity of a real estate broker or sales representative: Footnote 59
- (a) five or more new houses or condominium units;
- (b) one or more new commercial or industrial buildings; or
- (c) one or more new multi-unit residential buildings each of which contains five or more residential units, or two or more new multi-unit residential buildings that together contain five or more residential units.
- Reasonable measures
Steps taken to achieve a desired outcome, even if they do not result in the desired outcome. For example, this can include doing one or more of the following:
- asking the client,
- conducting open source searches,
- retrieving information already available, including information held in non-digital formats, or
- consulting commercially available information.
- Receipt of funds record
A record that indicates the receipt of an amount of funds and that contains the following information: Footnote 60
- (a) the date of the receipt;
- (b) if the amount is received from a person, their name, address and date of birth and the nature of their principal business or their occupation;
- (c) if the amount is received from or on behalf of an entity, the entity's name and address and the nature of their principal business;
- (d) the amount of the funds received and of any part of the funds that is received in cash;
- (e) the method by which the amount is received;
- (f) the type and amount of each fiat currency involved in the receipt;
- (g) if applicable, the exchange rates used and their source;
- (h) the number of every account that is affected by the transaction in which the receipt occurs, the type of account and the name of each account holder;
- (i) the name and address of every other person or entity that is involved in the transaction, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
- (j) every reference number that is connected to the transaction and has a function equivalent to that of an account number; and
- (k) the purpose of the transaction.
- Registered pension plan
- Registered retirement income fund
In respect of information that is used to verify identity, means that the source is well known, reputable, and is considered one that you trust to verify the identity of the client. (fiable)
- Representative for service
An individual in Canada that has been appointed by a person or entity that is a foreign money services business (FMSB), pursuant to the PCMLTFA, to receive notices and documents on behalf of the FMSB. (représentant du service)
- Risk assessment
The review and documentation of potential money laundering/terrorist financing risks in order to help a business establish policies, procedures and controls to detect and mitigate these risks and their impact. (évaluation des risques)
- Securities dealer
A person or entity that is referred to in paragraph 5(g) of the Act.Footnote 63 (courtier en valeurs mobilières)
- Senior officer
In respect of an entity, means: Footnote 64
- (a) a director of the entity who is one of its full-time employees;
- (b) the entity's chief executive officer, chief operating officer, president, secretary, treasurer, controller, chief financial officer, chief accountant, chief auditor or chief actuary, or any person who performs any of those functions; or
- (c) any other officer who reports directly to the entity's board of directors, chief executive officer or chief operating officer.
- Service agreement
An agreement between a money services business (MSB) and an organization according to which the MSB will provide any of the following MSB services on an ongoing basis:
- money transfers;
- foreign currency exchange;
- issuing or redeeming money orders, traveller's cheques or anything similar; or
- dealing in virtual currencies.
A settlor is an individual or entity that creates a trust with a written trust declaration. The settlor ensures that legal responsibility for the trust is given to a trustee and that the trustee is provided with a trust instrument document that explains how the trust is to be used for the beneficiaries. A settlor includes any individual or entity that contributes financially to that trust, either directly or indirectly. (constituant)
- Shell bank
A foreign financial institution that: Footnote 65
- (a) does not have a place of business that:
- (b) is not controlled by, or under common control with, a depository institution, credit union or foreign financial institution that maintains a place of business referred to in paragraph (a) in Canada or in a foreign country
- (a) does not have a place of business that:
Includes an electronic signature or other information in electronic form that is created or adopted by a client of a person or entity referred to in section 5 of the Act and that is accepted by the person or entity as being unique to that client. Footnote 66 (signature)
- Signature card
In respect of an account, means a document that is signed by a person who is authorized to give instructions in respect of the account, or electronic data that constitutes the signature of such a person. Footnote 67 (fiche-signature)
The issuer or provider of information or documents for verifying identification. (source)
- Source of funds or of virtual currency (VC)
The origin of the particular funds or VC used to carry out a specific transaction or to attempt to carry out a transaction. It is how the funds were acquired, not where the funds may have been transferred from. For example, the source of funds could originate from activities or occurrences such as employment income, gifts, the sale of a large asset, criminal activity, etc. (origine des fonds ou de la monnaie virtuelle (MV))
- Source of wealth
The origin of a person's total assets that can be reasonably explained, rather than what might be expected. For example, a person's wealth could originate from an accumulation of activities and occurrences such as business undertakings, family estates, previous and current employment income, investments, real estate, inheritance, lottery winnings, etc. (origine de la richesse)
The Society for Worldwide Interbank Financial Telecommunication. Footnote 68 (SWIFT)
- Terrorist activity
- Terrorist activity financing offence
A terrorist financing offence is knowingly collecting or giving property (such as money) to carry out terrorist activities. This includes the use and possession of any property to help carry out the terrorist activities. The money earned for terrorist financing can be from legal sources, such as personal donations and profits from a business or charitable organization or from criminal sources, such as the drug trade, the smuggling of weapons and other goods, fraud, kidnapping and extortion. Footnote 70 (infraction de financement des activités terroristes)
- Third party
Any individual or entity that instructs another individual or entity to act on their behalf for a financial activity or transaction. (tiers)
- Threats to the security of Canada
- Training program
A written and implemented program outlining the ongoing training for your employees, agents or other individuals authorized to act on your behalf. It should contain information about all your obligations and requirements to be fulfilled under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its associated Regulations (programme de formation)
A right of property held by one individual or entity (a trustee) for the benefit of another individual or entity (a beneficiary). (fiducie)
- Trust company
A company that is referred to in any of paragraphs 5(d) to (e.1) of the Act. Footnote 72 (société de fiducie)
A trustee is the individual or entity authorized to hold or administer the assets of a trust. (fiduciaire)
In the context of civil law, a person who has been lawfully appointed to the care of the person and property of a minor. (tuteur)
- Two year effectiveness review:
A review, conducted every two years (at a minimum), by an internal or external auditor to test the effectiveness of your policies and procedures, risk assessment, and training program. (examen bisannuel de l'efficacité)
In respect of a document or information that is used to verify identity, appears legitimate or authentic and does not appear to have been altered or had any information redacted. The information must also be valid according to the issuer, for example if a passport is invalid because of a name change, it is not valid for FINTRAC purposes. (valide)
- Verify client identity
To refer to certain information or documentation, in accordance with the prescribed methods, to identify a client. (vérifier l'identité d'un client)
- Very large corporation or trust
A corporation or trust that has minimum net assets of $75 million CAD on its last audited balance sheet. The corporation's shares or units have to be traded on a Canadian stock exchange or on a stock exchange designated under subsection 262(1) of the Income Tax Act. The corporation or trust also has to operate in a country that is a member of the Financial Action Task Force (FATF). (personne morale ou fiducie dont l'actif est très important)
A contravention of the Act or the regulations that is designated as a violation by regulations made under subsection 73.1(1).Footnote 73 (violation)
- Virtual currency
Means: Footnote 74
- (a) a digital representation of value that can be used for payment or investment purposes that is not a fiat currency and that can be readily exchanged for funds or for another virtual currency that can be readily exchanged for funds; or
- (b) a private key of a cryptographic system that enables a person or entity to have access to a digital representation of value referred to in paragraph (a).
- Virtual currency exchange transaction
An exchange, at the request of another person or entity, of virtual currency for funds, funds for virtual currency or one virtual currency for another.Footnote 75 (opération de change en monnaie virtuelle)
- Virtual currency exchange transaction ticket
A record respecting a virtual currency exchange transaction—including an entry in a transaction register—that sets out: Footnote 76
- (a) the date of the transaction;
- (b) in the case of a transaction of $1,000 or more, the name and address of the person or entity that requests the exchange, the nature of their principal business or their occupation and, in the case of a person, their date of birth;
- (c) the type and amount of each type of funds and each of the virtual currencies involved in the payment made and received by the person or entity that requests the exchange;
- (d) the method by which the payment is made and received;
- (e) the exchange rates used and their source;
- (f) the number of every account that is affected by the transaction, the type of account and the name of each account holder;
- (g) every reference number that is connected to the transaction and has a function equivalent to that of an account number; and
- (h) every transaction identifier, including the sending and receiving addresses.
- Working days
In respect of an electronic funds transfer (EFT) report or a large virtual currency transaction report, a working day is a day between and including Monday to Friday. It excludes Saturday, Sunday, and a public holiday. (jour ouvrable)
- Date Modified: