Guideline 8A: Submitting Non-SWIFT Electronic Funds Transfer Reports to FINTRAC Electronically

August 2019

Table of Contents

  1. General
  2. Who Has to Send an Electronic Funds Transfer Report to FINTRAC?
  3. Electronic Funds Transfer Reporting Requirements
  4. Electronic Reporting
  5. Instructions for Completing a Non-SWIFT Electronic Funds Transfer Report
  6. Comments?
  7. How to Contact FINTRAC

1. General

The objective of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) is to help detect and deter money laundering and the financing of terrorist activities. It is also to facilitate investigations and prosecutions of money laundering and terrorist activity financing offences. This includes reporting, record keeping, client identification and compliance regime requirements for individuals and entities described in section 2.

If you are such an individual or entity, this guideline has been prepared to help you submit electronic funds transfer (EFT) reports electronically. It explains reporting timelines, how reports have to be sent to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), and what information has to be included in these reports.

This guideline uses plain language to explain the most common reporting situations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act as well as the related regulations. It is provided as general information only. It is not legal advice, and is not intended to replace the Act and Regulations.

If you need more help after you read this or other guidelines, call FINTRAC's national toll-free enquiries line at 1-866-346-8722.

Throughout this guideline, several references are provided to additional information that may be available on external Web sites. FINTRAC is not responsible for the accuracy or reliability of the information contained on those external Web sites. The links provided are based on information available at the time of publishing of this guideline.

Throughout this guideline, any references to dollar amounts (such as $10,000) refer to the amount in Canadian dollars or its equivalent in foreign currency.

2. Who Has to Send an Electronic Funds Transfer Report to FINTRAC?

If you are one of the following individuals or entities (called reporting entities), you must report EFTs to FINTRAC.

2.1 Financial entities

Financial entities are banks (that is, those listed in Schedule I or II of the Bank Act) or authorized foreign banks with respect to their operations in Canada, credit unions, caisses populaires, financial services cooperatives, credit union centrals (when they offer financial services to anyone other than a member entity of the credit union central), trust companies, loan companies and agents of the Crown that accept deposit liabilities.

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

2.2 Money services businesses

A money services business means an individual or entity engaged in the business of any of the following activities:

Money services businesses include alternative money remittance systems, such as Hawala, Hundi, Chitti, etc.

For more information about who is engaged in the money services business, see the FINTRAC Interpretation Notice No. 1.

2.3 Casinos

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

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

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

3. Electronic Funds Transfer Reporting Requirements

3.1 Electronic reporting enrolment

As a reporting entity, you have to be enrolled with FINTRAC's electronic reporting system to report electronically.

For more information about FINTRAC enrolment, contact us as explained in section 7.

3.2 When do you have to report electronic funds transfers?

If you are a reporting entity as described in section 2, you have to report incoming and outgoing international electronic funds transfers (EFTs) of $10,000 or more to FINTRAC no later than five working days after the day of the transmission of the instructions (see subsection 3.7). Read subsection 3.3 to find out more about SWIFT EFTs. Subsection 3.4 and the rest of this guideline contain information about any other type of reportable EFT (that is, non-SWIFT).

3.3 SWIFT electronic funds transfers

The incoming and outgoing SWIFT EFT reporting requirement is only applicable to you if you are a financial entity or a money services business. Furthermore, it only applies if you send or receive EFTs by transmission of a SWIFT MT 103 message, as a SWIFT member, through the SWIFT network. SWIFT means the Society for Worldwide Interbank Financial Telecommunication. It is a co-operative owned by the international banking community that operates a global data processing system for the transmission of financial messages.

If you are a financial entity or a money services business and you send this type of EFT, read Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC. Your reporting obligations regarding EFTs also include sending or receiving EFTs by any other means, as explained below.

3.4 All other reportable electronic funds transfers (non-SWIFT)

The rest of this guideline provides information about the reporting requirement for international "non‑SWIFT" EFTs. This applies to you if you are a financial entity, a money services business or a casino. An EFT is the transmission of instructions for a transfer of funds through any electronic, magnetic or optical device, telephone instrument or computer. In this context, SWIFT EFT messages are excluded, as explained in subsection 3.3.

You have to send a non-SWIFT EFT report to FINTRAC for the following transactions.

Outgoing EFTs

These are instructions sent electronically for the transfer of $10,000 or more outside Canada at the request of a client in the following manner:

This type of EFT requires that you send an Outgoing International Non-SWIFT EFT Report (EFTO) to FINTRAC.

It can happen that a client requests a transfer of funds and, instead of sending the EFT yourself, you order someone else that is a financial entity, a money services business or a casino in Canada to send it. In this case, you have to make the related EFT report (EFTO) to FINTRAC unless you provide them with the client's name and address. In other words, if you give them your client's name and address, you do not have to report the EFT. See Appendix 1 for example scenarios of this type of situation.

If you send an EFT on your own behalf (not on behalf of a client) to an individual or entity in Canada, you do not have to report it, even if the final recipient of the funds is outside Canada

Incoming EFTs

These are instructions sent electronically for the transfer of $10,000 or more from outside Canada at the request of a client in the following manner:

This type of EFT requires that you send an Incoming International Non-SWIFT EFT Report (EFTI) to FINTRAC.

If you are a financial entity, a money services business or a casino and you received instructions for a transfer of funds from outside Canada, you have to make the related EFT report (EFTI) to FINTRAC, even if you have to forward the same instructions to another financial entity, money service business or casino in Canada. However, if you receive instructions for a transfer of funds from outside Canada from another financial entity, money services business or casino in Canada, you do not have to make an incoming EFT report, as long as the EFT contained the name and address of the beneficiary. If the EFT did not contain the name and address of the beneficiary and the original sender was outside Canada, you also have to make an incoming EFT report. This is true even if you do not get a copy of the instructions received by the other financial entity, money services business or casino.

See Appendix 1 for example scenarios of these types of situation.

Exception to the 24-hour rule for EFTs

The following exception applies if you send or receive a bundled EFT, that is an EFT with more than one beneficiary. The 24-hour-rule will not apply for any of the amounts under $10,000 included in a bundled EFT if it was sent at the request of a public body, a very large corporation, or the administrator of a federally or provincially regulated pension fund.

In this context, a public body means any of the following or their agent:

Also in this context, a very large corporation is one that has minimum net assets of $75 million on its last audited balance sheet. The corporation's shares have to be traded on a Canadian stock exchange or on a stock exchange outside Canada that is designated by the Minister of Finance. The corporation also has to operate in a country that is a member of the Financial Action Task Force (FATF). For more information about stock exchanges outside Canada that are designated by the Minister of Finance, refer to the July 2, 2008 news release available in the News area of the Department of Finance's Web site (http://www.fin.gc.ca).

To find out which countries are members of the FATF, refer to its Web site (http://www.fatf-gafi.org).

3.5 Electronic funds transfers in foreign currency

If you send or receive an EFT in a foreign currency, you will need to check whether it is the equivalent of 10,000 Canadian dollars or more to determine whether or not it is reportable to FINTRAC. For this purpose only, use the last exchange rate provided by the Bank of Canada available at the time of the transaction, instead of the actual exchange rate used to process the transaction. This calculation is only to check whether the $10,000 threshold is met for the transaction to be reportable as an EFT transaction.

For example, for an EFT that happened at 9:00 am on Tuesday following a holiday Monday, you would use the Bank of Canada rate from the previous working day (in this case, Friday) to determine whether the transaction is reportable. You can find the rate on the Bank of Canada Web site at http://www.bankofcanada.ca/rates/exchange/.

If there is no Bank of Canada rate published for the currency of the transaction, use the actual exchange rate applied when you processed the transaction to determine whether it is reportable.

Once you have determined that an EFT in a foreign currency is reportable based on the Bank of Canada rate, you will have to send an EFT report to FINTRAC. On the EFT report in Part A, enter the amount of the transaction in the foreign currency. If you converted this amount to or from Canadian dollars when you processed the transaction (other than using the Bank of Canada rate to determine whether or not it was reportable), enter the actual exchange rate you used to process the EFT in Part A of the report.

3.6 Other requirements associated with electronic funds transfers

In addition to the reporting requirements explained in this guideline, consider the following relating to an EFT transaction:

Record keeping and client identification

EFTs have associated record keeping and client identification requirements. For more information refer to FINTRAC record keeping guidance.

Originator information to include with transfers

If you send or receive an EFT of any amount, at the request of a client, there are obligations about originator information included with the transfer. For more information refer to FINTRAC know your client guidance.

Large cash transaction report

If an EFT transaction is initiated in cash, in the amount of $10,000 or more, you will likely have to make a large cash transaction report to FINTRAC in addition to making the EFT report about the transaction as required. For more information about making large cash transaction reports, consult Guideline 7: Submitting Large Cash Transaction Reports to FINTRAC.

Suspicious transaction report

If anything about an EFT transaction gives you reasonable grounds to suspect that it could be related to a money laundering or a terrorist activity financing offence, you have to make a suspicious transaction report to FINTRAC about the same transaction. This would be in addition to making the EFT report about the transaction as required.

The suspicious transaction report has many fields that are different from those of an EFT report. For example, there is a field in the suspicious transaction report for you to explain your suspicion about the transaction. There is also a field in that report for you to describe what action, if any, was taken by you, as a result of the suspicious transaction. This would include stating that you have made an EFT report for the same transaction (if that is the case).

For more information about making suspicious transaction reports, consult Guideline 1: Backgrounder and STR guidance.

Transactions related to terrorist property

If you know that any proposed transaction is related to property owned or controlled by or on behalf of a terrorist or a terrorist group, you should not complete the transaction. This is because terrorist property must be frozen under the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism as well as the Criminal Code.

For more information about this and to find out what your obligations are regarding any terrorist property in your control or possession, consult the following guidelines:

Casino disbursement report

If you are a casino sending an EFT that is part of a casino disbursement in the amount of $10,000 or more, you will likely have to make a casino disbursement report to FINTRAC in addition to making the EFT report about the transaction as required. For more information about making casino disbursement reports, consult Guideline 10: Submitting Casino Disbursement Reports to FINTRAC.

3.7 Reporting timeframes for electronic funds transfer reports

You have to send EFT reports to FINTRAC no later than five working days after the day of the transfer. The day of the transfer means:

3.8 Means of reporting electronic funds transfers to FINTRAC

Electronic reporting

As a reporting entity, you will have to submit all EFT reports to FINTRAC electronically if you have the technical capabilities to do so. The minimum technical capabilities are as follows:

See section 4 for more information on submitting reports to FINTRAC electronically.

Paper reporting

If you do not have the technical capabilities to send reports electronically, you must submit reports on paper. See Guideline 8C: Submitting Non-SWIFT Electronic Funds Transfer Reports to FINTRAC by Paper for more information on submitting paper non-SWIFT EFT reports to FINTRAC.

4. Electronic Reporting

4.1 Options for electronic reporting

As a reporting entity, you have to send electronic funds transfer reports electronically to FINTRAC if you have the technical capabilities to do so (see subsection 3.8).

There are two options for electronic reporting:

Both options provide for secure encrypted transmission to ensure data confidentiality and integrity. Reporting through batch will require more advanced technical capability than explained in subsection 3.8.

4.2 How to complete electronic reports

Reporting through FINTRAC web reporting

FINTRAC web reporting contains the reporting screens for electronic funds transfer reports, with completion instructions. Drop-down menus appear wherever a code or specific selection is required.

See Appendices 1A and 1B for the completion instructions, including details of what each field must contain for a non-SWIFT EFT report. Appendix 1A is about an outgoing non-SWIFT EFT report (EFTO) and Appendix 1B is about an incoming non-SWIFT EFT report (EFTI).

Reporting through batch file transfer

To use the batch file reporting mechanism, you need a public key infrastructure (PKI) certificate and specialized software available from FINTRAC. For more information, refer to the Batch reporting page.

Consult the Standard Batch Reporting Instructions and Specification for more information about how to report non-SWIFT EFTs through batch file transfer. You can also refer to Appendices 1A and 1B for instructions and details regarding the content of fields in a non-SWIFT EFT report.

4.3 Acknowledgement of receipt of an electronic report

FINTRAC will send you an acknowledgement message when your EFT report has been received electronically.

If you send your reports by batch, you will receive two acknowledgements. The first will confirm that your batch has been received by FINTRAC. The second will confirm that it has been processed.

For each report submitted through FINTRAC web reporting, you will receive an acknowledgement message, including the date and time your report was received and the report’s identification number. These acknowledgements will be stored within the FINTRAC web reporting system and available for viewing or printing.

4.4 Report corrections

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

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

After receiving FINTRAC’s notification, you should provide the necessary information to FINTRAC within the five–working–day reporting deadline. In other words, this information should be sent to FINTRAC within five working days of the transfer (see subsection 3.7). Your obligation to report will not be fulfilled until you send the complete report to FINTRAC.

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

If a correction is required to a report that you sent through batch file transfer, you will do this according to your choice of correction options upon enrolment. For more information about this, refer to the Standard Batch Reporting Instructions and Specification and the documents about FINTRAC’s enrolment and use of FINTRAC web reporting.

5. Instructions for Completing a Non-SWIFT Electronic Funds Transfer Report

5.1 General instructions

The contents of a non-SWIFT EFT depend on whether it is an outgoing or incoming transfer. The required information for each type of report, along with field-by-field instructions, are listed in Appendices 1A and B, as follows:

The information about how to complete the fields can also be useful to those completing non-SWIFT EFT reports through batch file transfer. If you report through batch, you need to refer to the Standard Batch Reporting Instructions and Specification in addition to Appendix 1.

As explained in subsection 3.8, if you do not have the technical capability to report electronically, refer to Guideline 8C: Submitting Non-SWIFT Electronic Funds Transfer Reports to FINTRAC by Paper for more information.

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

The outgoing and incoming non-SWIFT EFT reports have the same mandatory, mandatory where applicable and reasonable efforts fields.

As explained in subsection 3.4, EFT reports can be about one of multiple EFTs of less than $10,000 each conducted within 24 consecutive hours of each other that add up to $10,000 or more. Because those individual EFTs were each under $10,000, the information for some mandatory fields in the report may not be available in your records or from the time of the transaction. In this case, "reasonable efforts" applies to those otherwise mandatory fields.

You have to complete a separate EFT report for each EFT transaction, even if you are reporting multiple EFTs of less than $10,000 each.

5.2 Accessing the FINTRAC web reporting screens

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

If you are authorized to complete non-SWIFT EFTO or EFTI reports, you will be able to select these report types in FINTRAC web reporting. You will be able to complete a new report or continue working on an incomplete report (that is, a report that was not previously submitted to FINTRAC).

Also, depending on your access rights, you will be able to submit a request for change to a completed report (that is, one that was previously submitted to FINTRAC). Subsection 5.4 contains instructions for submitting a change to a previously submitted report.

5.3 Instructions for submitting a new report

There are eight parts to the non-SWIFT EFT report, but some are only to be completed if the part is applicable.

If you report through batch, you should also refer to the Standard Batch Reporting Instructions and Specification.

5.4 Instructions for submitting a change to a previously submitted report

If you have to submit a change to a previously submitted non-SWIFT EFT report, you must provide any required changes to FINTRAC within the reporting deadline for the report. In other words, this information should be sent to FINTRAC within five working days of the transfer.

If you report through batch, refer to the technical documentation called Standard Batch Reporting Instructions and Specification to find out how to submit changes for previously submitted reports by batch. If you choose to do this through FINTRAC web reporting instead of by batch, read subsection 5.5. That choice means that you cannot submit changes by batch.

If you report through FINTRAC web reporting, read subsection 5.5.

5.5 Submitting changes through FINTRAC web reporting

The following explains how to make a change to a previously submitted non-SWIFT EFT report through FINTRAC web reporting:

Change details

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

Remember that you must provide any required changes to FINTRAC within the reporting deadline for the report. In other words, this information should be sent to FINTRAC within five working days of the transfer.

6. Comments?

These guidelines will be reviewed on a periodic basis. If you have any comments or suggestions to help improve them, please send your comments to the mailing address provided below, or by email to guidelines-lignesdirectrices@fintrac-canafe.gc.ca.

7. How to Contact FINTRAC

For further information on FINTRAC and its activities, reporting and other obligations, please go to FINTRAC's Web site at https://www.fintrac-canafe.gc.ca or contact FINTRAC:

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

Toll-free: 1-866-346-8722

Appendix 1: Scenarios for EFT Reports Involving Another Reporting Entity

Appendix 1A: Scenarios for Outgoing EFT Reports Involving Another Reporting Entity

It can happen that a client requests a transfer of funds outside Canada and, instead of sending the EFT yourself, you order someone else that is a financial entity, a money services business or casino in Canada to send it. In this case, you have to make the related EFT report (EFTO) to FINTRAC unless you provide them with the client's name and address. The following example provides two different scenarios to explain how the required reports are to be completed in such cases.

Example

A client requests a money services business to send an international EFT of $12,000 from Canada. The money services business does not send the EFT itself, but orders a financial entity in Canada to do so. For the purposes of this example, the financial entity does not send the EFT as a SWIFT member of the SWIFT network. Also for the purposes of this example, neither the client ordering the EFT from the money services business nor the beneficiary of the EFT is acting on behalf of a third party.

Scenario 1

The money services business provides the client's name and address to the financial entity. In this scenario, the money services business does not send an EFTO report to FINTRAC. Only the financial entity must report the EFT to FINTRAC, as follows:

Scenario 2

The money services business does not provide the client's name and address to the financial entity. In this scenario, the money services business and the financial entity must both report the EFT to FINTRAC. The following table shows the similarities and differences for the two reports.

Money services business' EFTO report Financial entity's EFTO report
Part A General information about the transaction. General information about the transaction.
Part B The money services business has to provide FINTRAC with the client's full name and full address, along with the rest of the information about their client. The financial entity has to provide FINTRAC with information about the money services business, as the money services business is considered the client ordering the EFT from the financial entity in this context.
Part C Information about the money services business, as the reporting entity. Information about the financial entity, as the reporting entity.
Part D Does not apply to this report because the money services business' client is not ordering the EFT on anyone else's behalf. In other words, there is no ordering client's third party. Does not apply to this report because the money services business is not providing information about their client to the financial entity and the money services business is required to provide that information in their own report to FINTRAC. In other words, there is no ordering client's third party.
Part E Information about the individual or entity outside Canada who will be receiving the EFT instructions. This is not about the financial entity that is being ordered to send the EFT. It is about the bank or other type of financial service provider outside Canada who will receive the EFT instructions to provide payment to the beneficiary. Information about the individual or entity outside Canada who will be receiving the EFT instructions. It is about the bank or other type of financial service provider outside Canada who will receive the EFT instructions to provide payment to the beneficiary.
Part F Information about the beneficiary to whose benefit the EFT is sent. Information about the beneficiary to whose benefit the EFT is sent.
Part G Does not apply to this report because the beneficiary is not acting on anyone else's behalf. In other words, there is no beneficiary's third party. Does not apply to this report because the EFT's beneficiary is not acting on anyone else's behalf. In other words, there is no beneficiary's third party.

Note: For information about the contents of the financial entity's report if the EFT were sent as a SWIFT message, refer to the scenarios explained in Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC.

Appendix 1B: Scenarios for Incoming EFT Reports Involving Another Reporting Entity

If you receive an electronic funds transfer from outside Canada, some of the information required in your report to FINTRAC is provided by the individual or entity sending you the instructions. The following example provides two different scenarios to explain how the required reports are to be completed in such cases.

Example

A European funds transfer business, at the request of an individual client in Europe, sends an EFT of $12,000 to be paid to an individual in Canada through a particular financial entity (to be referred to in this example as Bank 1). The European business does not have a relationship with Bank 1, but does with another financial entity in Canada (to be referred to in this example as Bank 2). The EFT is therefore sent from the European business to Bank 2, for payment to a client of Bank 1.

For the purposes of this example, the EFT is not sent through the SWIFT network. Also for the purposes of this example, neither the client ordering the EFT in Europe nor the beneficiary of the EFT in Canada is acting on behalf of a third party.

Even if the ultimate beneficiary is a client of Bank 1, Bank 2 must report to FINTRAC, as it is the first to receive the EFT in Canada. Depending on whether or not the name and address of the beneficiary was included in the EFT, Bank 1 may also have to report to FINTRAC, as explained in the following scenarios.

Scenario 1

The EFT contains the name and address of Bank 1's client. In this scenario, Bank 1 does not report to FINTRAC. Bank 2 reports the incoming EFT (EFTI) to FINTRAC, as follows:

Scenario 2

The EFT does not contain the name and address of Bank 1's client. In this scenario, both Bank 1 and Bank 2 report the incoming EFT (EFTI) to FINTRAC.

The following table shows the similarities and differences for the two reports.

Bank 2 EFTI report Bank 1 EFTI report
Part A General information about the transaction. General information about the transaction.
Part B Bank 2 has to provide FINTRAC with the European business' client's full name and, if applicable, the client's account number. In addition, if the information is available at the time of the transaction or in Bank 2's records, Bank 2 has to provide the European business' client's full address, telephone number, date of birth, occupation, identifier and identifier number. Bank 1 has to provide FINTRAC with the European business' client's full name and, if applicable, the client's account number. In addition, if the information is available at the time of the transaction or in Bank 1's records, Bank 1 has to provide the European business' client's full address, telephone number, date of birth, occupation, identifier and identifier number.
Part C Part C is for information about the European business sending the EFT. Part C is for information about the European business sending the EFT.
Part D Does not apply to this report because the European business' ordering client is not acting on anyone else's behalf. In other words, there is no ordering client's third party. Does not apply to this report because the European business' ordering client is not acting on anyone else's behalf. In other words, there is no ordering client's third party.
Part E Information about Bank 2, as the reporting entity. Information about Bank 1, as the reporting entity.
Part F Part F is for information about the beneficiary to whose benefit the EFT is sent. In this scenario, Bank 2 must provide Bank 1's full name, and, if applicable, Bank 1's account number. In addition, Bank 2 has to provide Bank 1's full address and telephone number if any of that information is available at the time of the transaction or in Bank 2's records. Information about the beneficiary to whose benefit the EFT is sent. In this scenario, Bank 2 must provide its client's full name and, if applicable, the client's account number. In addition, Bank 1 has to provide its client's full address and telephone number if any of that information is available at the time of the transaction or in Bank 1's records.
Part G Does not apply to this report because the beneficiary is not acting on anyone else's behalf. In other words, there is no beneficiary's third party. Does not apply to this report because the EFT's beneficiary is not acting on anyone else's behalf. In other words, there is no beneficiary's third party.

Note: Bank 2 in the above scenarios has to take reasonable measures to ensure that the EFT includes originator information.

Date Modified: