Guideline 3A: Submitting Suspicious Transaction Reports to FINTRAC Electronically

February 2006

This replaces the previous version of Guideline 3A: Submitting Suspicious Transaction Reports to FINTRAC Electronically issued in May 2003. The changes made to this version are indicated by a side bar to the right of the modified text in the PDF version.

Table of Contents

1. General
2. Suspicious Transaction Reporting Requirements

   2.1 FINTRAC Enrolment

   2.2 Suspicious Transaction Reporting Timelines

   2.3 Other Reports

   2.4 Means of Reporting to FINTRAC

   2.5 Information to be Contained in a Suspicious Transaction Report

3. Electronic Reporting

   3.1 Options for Electronic Reporting

   3.2 How to Complete Electronic Reports

   3.3 Acknowledgement of Receipt of an Electronic Report

   3.4 Report Corrections

4. Instructions for Completing a Suspicious Transaction Report

   4.1 General Instructions

   4.2 Accessing the F2R Reporting Screens

   4.3 Instructions for Submitting a New Report

   4.4 Instructions for Submitting a Change to a Previously Submitted Report

   4.5 Submitting Changes Through F2R

5. Comments?
6. How to Contact FINTRAC

Appendix 1: Field by Field Instructions for a Suspicious Transaction Report

Appendix 2: Navigation Through F2R Reporting Screens for a Suspicious Transaction Report

1. General

The following have to report suspicious and certain other transactions to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC): 

• financial entities (such as banks or authorized foreign banks with respect to their operations in Canada, credit unions, caisses populaires, trust and loan companies and agents of the Crown that accept deposit liabilities);
• life insurance companies, brokers and independent agents;
• securities dealers, portfolio managers and investment counsellors;
• foreign exchange dealers and money services businesses (for guidance on who is engaged in the business of money services or foreign exchange dealing, refer to the FINTRAC Interpretation Notice on this topic available from the Publications page of FINTRAC's Web site);
• agents of the Crown that sell or redeem money orders ;
• accountants and accounting firms, when carrying out certain activities on behalf of their clients or when receiving professional fees to engage in any of those activities.
• real estate brokers or sales representatives, when carrying out certain activities on behalf of their clients; and
• casinos (for a description of a casino in this context, see Guideline 6F:Record Keeping and Client Identification for Casinos)

If you are one of these "reporting entities", this guideline has been prepared by FINTRAC to help you submit suspicious transaction reports electronically. It explains reporting timelines, how reports have to be sent to FINTRAC, and what information has to be included in these reports.

For the purposes of suspicious transactions, an employee of any of the reporting entities described above is also a "reporting entity". If you are an employee and you have to submit a suspicious transaction report on your own behalf (that is, not on behalf of your employer), refer to Guideline 3B: Submitting Suspicious Transaction Reports to FINTRAC by Paper.

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. For more information about money laundering, terrorist financing or other requirements under the Act and Regulations, see the guidelines in this series: 

• Guideline 1: Backgrounder explains money laundering and terrorist financing and their international nature. It also provides an outline of the legislative requirements as well as an overview of FINTRAC's mandate and responsibilities.
• Guideline 2: Suspicious Transactions explains how to report a suspicious transaction. It also provides guidance on how to identify a suspicious transaction, including general and industry-specific indicators that may help when conducting or evaluating transactions.
• Guideline 3: Submitting Suspicious Transaction Reports to FINTRAC explains when and how to submit suspicious transaction reports. There are two different versions of Guideline 3, by reporting method.
• Guideline 4: Implementation of a Compliance Regime explains the requirement for reporting persons and entities to implement a regime to ensure compliance with their obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations.
• Guideline 5: Submitting Terrorist Property Reports to FINTRAC explains to reporting persons and entities when and how to submit a terrorist property report.
• Guideline 6: Record Keeping and Client Identification explains the requirement for reporting persons and entities to identify their clients and keep records. There are eight different versions of Guideline 6, by sector of activity.
• Guideline 7: Submitting Large Cash Transaction Reports to FINTRAC explains when and how to submit large cash transaction reports. There are two different versions of Guideline 7, by reporting method.
• Guideline 8: Submitting Electronic Funds Transfer Reports to FINTRAC explains when and how to submit EFT reports. There are three different versions of Guideline 8, by report type and reporting method.
• Guideline 9: Submitting Alternative to Large Cash Transaction Reports to FINTRAC explains when and how financial entities can choose the alternative to large cash transaction reports. This is only applicable to financial entities.

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 these guidelines, 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. Also throughout this guideline, the term "reporting entity" is used to refer to any person or entity required to report to FINTRAC.

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2. Suspicious Transaction Reporting Requirements

2.1 FINTRAC Enrolment

Effective February 2006, as a reporting entity, you have to be enrolled with FINTRAC to report electronically. FINTRAC will provide you with an identifier number to include in your reports.

If you were already submitting reports to FINTRAC before February 2006, your enrolment should be processed automatically. If you have previously reported, but have not received your FINTRAC reporting entity identifier number before February 2006, please contact FINTRAC (as explained in Section 6).

If you have never reported before, please contact FINTRAC (as explained in Section 6) to enrol before you report.

For more information about FINTRAC enrolment, contact us as explained in Section 6.

2.2 Suspicious Transaction Reporting Timelines

If you are a reporting entity as described in Section 1, you have to send a suspicious transaction report to FINTRAC when there are reasonable grounds to suspect that a transaction is related to the commission of a money laundering offence or a terrorist financing offence.

There is no minimum threshold amount for reporting a suspicious transaction. Guideline 2: Suspicious Transactions has more information on how to identify a suspicious transaction.

You have to submit suspicious transaction reports to FINTRAC, containing specific information (see Section 4). Once you have determined that there are reasonable grounds to suspect that the transaction is related to the commission of a money laundering or terrorist financing offence, your report, including all required and applicable information, must be sent within 30 calendar days.

This 30-day reporting time limit begins when you or any one of your employees first detects a fact about a transaction that constitutes reasonable grounds to suspect that it is related to the commission of a money laundering or terrorist financing offence. If such a fact is detected at the time of the transaction, the reporting timeline begins at the time of the transaction. However, if the fact is not detected at the time of the transaction, the 30-day time limit could begin at some time after. For example, if the fact were detected during a review by corporate security after the transaction took place, the 30-day time limit would begin when corporate security first detected the fact.

2.3 Other Reports

Information about other reporting requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act that apply to reporting entities can be found in the following guidelines: 

• Guideline 5: Submitting Terrorist Property Reports to FINTRAC
• Guideline 7: Submitting Large Cash Transaction Reports to FINTRAC
• Guideline 8: Submitting Electronic Funds Transfer Reports to FINTRAC

2.4 Means of Reporting to FINTRAC

Electronic Reporting

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

• A personal computer with the following characteristics:
  • 32 MB memory
  • 640 x 480 VGA video display (800 x 600 or higher is preferable)
  • any operating system running a Web browser, such as Internet Explorer (version 5.x or greater) or its equivalent; and
• An Internet connection

See Section 3 for more information on submitting reports to FINTRAC electronically.

Exception for Employees and Suspicious Transaction Reports

If you are an employee of a reporting entity, you are a "reporting entity" yourself, for the purposes of suspicious transactions only. This requires you to make a report to FINTRAC about a suspicious transaction unless you reported it to your superior. In this situation, if you need to make a report about a suspicious transaction that you did not report to your superior, you are considered not to have the technical capabilities to report electronically. This means you must submit this type of report by paper, as explained below.

This exception does not apply if you are submitting a suspicious transaction report on behalf of your employer or anyone else that is a reporting entity.

Paper Reporting

If you do not have the technical capabilities to send reports electronically, you must submit reports on paper. See Guideline 3B: Submitting Suspicious Transaction Reports to FINTRAC by Paper for more information on submitting paper suspicious transaction reports to FINTRAC.

2.5 Information to be Contained in a Suspicious Transaction Report

Your suspicion about there being a relation to a money laundering or a terrorist financing offence may be as a result of more than one transaction. In this case, include all the transactions that contributed to your suspicion in the same report.

By completing all applicable fields in your reports, you make an important contribution to FINTRAC's ability to isolate activity pointing to possible money laundering or terrorist activity financing. In the case of a suspicious transaction report, your detailed explanation of what led to the suspicion is also extremely important to FINTRAC's analysis. 

See Section 4 and Appendix 1 for more information about what has to be included in a suspicious transaction report.

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3. Electronic Reporting

3.1 Options for Electronic Reporting

As a reporting entity, you have to report suspicious transactions electronically to FINTRAC if you have the technical capabilities to do so (see Section 2.4).

Effective February 2006, there are two options for electronic reporting:

• FINTRAC's secure Web site (F2R); and
• Batch file transfer.

Both options provide for secure encrypted transmission to ensure data confidentiality and integrity. Reporting through batch requires more advanced technical capability than explained in Section 2.4.

If you were reporting using FINTRAC's Report Preparation Software or FINTRAC's secure Web site (Web form), these reporting methods are no longer available as of February 2006.

3.2 How to Complete Electronic Reports

Reporting through F2R

F2R contains the suspicious transaction reporting screens, with completion instructions. Drop-down menus appear wherever a code or specific selection is required.

See Appendix 1 for the completion instructions, including details of what each field must contain for a suspicious transaction report. Also, Appendix 2 explains how to navigate through the F2R reporting screens.

F2R reporting screens require that the Western European character setting is selected for your Web browser. To change your browser's character setting in Internet Explorer, click on "View" from the browser menu bar, select "Encoding" and then "Western European".

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 about how to get these, refer to the reporting area of FINTRAC's Web site at http://www.fintrac.gc.ca/reporting--declaration/1_e.asp.

Consult the Standard Batch Reporting Instructions and Specification for more information about how to report suspicious transactions through batch file transfer. This document is available from the Publications page of FINTRAC's Web site (see technical documentation at http://www.fintrac.gc.ca/publications/pub_e.asp). You can also refer to Appendix 1 of this guideline for instructions regarding the content of fields in a suspicious transaction report.

3.3 Acknowledgement of Receipt of an Electronic Report

FINTRAC will send you an acknowledgement message when your suspicious transaction report has been received electronically. This will include the date and time your report was received and a FINTRAC-generated identification number. Please keep this information for your records.

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 F2R, you will receive an acknowledgement message. These acknowledgements will be stored on F2R and available for viewing or printing.

3.4 Report Corrections

If a correction is required to a report that you sent through F2R, you will have to make that correction through F2R.

If a correction is required to a report that you sent through batch file transfer, you will do this according 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 F2R.

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4. Instructions for Completing a Suspicious Transaction Report

4.1 General Instructions

Instructions for the fields of the Suspicious Transaction Report screens are contained in Appendix 1. Additional instructions in Appendix 2 relate to navigation through the reporting screens on F2R.

The instructions in Appendices 1 and 2 are based on the reporting screens through F2R. However, the information about how to complete the fields can also be useful to those completing suspicious transaction reports through batch file transfer. If you report through batch, you need to refer to the Standard Batch Reporting Instructions and Specificationin addition to Appendix 1.

As explained in Section 2.4, if you do not have the capability to report electronically, refer to Guideline 3B: Submitting Suspicious Transactions to FINTRAC by Paper for more information.

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

• Mandatory:  All fields of a report marked with an asterisk (*) have to be completed.
• Mandatory where applicable:  The fields that have both an asterisk and "where applicable" next to them have to be completed if they are applicable to you or the transaction being reported.
• Reasonable efforts:  For all other fields that do not have an asterisk, you have to make reasonable efforts to get the information. "Reasonable efforts" means that you tried to get the information requested on the report. If the information is available to you, you must provide it in the report. If the information was not available at the time of the transaction, and it is not contained in your files or records, the field may be left blank.

4.2 Accessing the F2R Reporting Screens

To access F2R, reporting entities first have to be enrolled for electronic reporting with FINTRAC. At enrolment, each reporting entity has to assign an individual as their F2R administrator who will control all access to F2R. For more information about this, consult documents about FINTRAC's enrolment and use of F2R.

You can get to F2R from the reporting section of FINTRAC's main Web site (http://www.fintrac.gc.ca/). Once your F2R administrator has updated user information to enable you to complete reports, you will be provided with the following to be able to access the appropriate reporting screens:

• the identifier number for the reporting entity for whom you will be completing reports;
• your user ID; and
• your password. A temporary password will be assigned to you and you have to change it after the first time you log in to F2R.

If you are authorized to complete suspicious transaction reports, you will be able to select this report type from the report creation page within the "Report" section of F2R.

You will be able to complete a new report or continue working on an incomplete report (i.e., a report that was not previously submitted to FINTRAC). For more information about completing a report, see Appendices 1 and 2 of this guideline.

Also, depending on your access rights, you will be able to submit a request for change to a completed report (i.e., one that was previously submitted to FINTRAC). Section 4.4 contains instructions for submitting a change to a previously submitted report.

4.3 Instructions for Submitting a New Report

There are nine parts on the Suspicious Transaction Report form, but some are only to be completed if the part is applicable.

See Appendix 1 for instructions about the fields in each part of the report. If you use F2R, Appendix 2 provides additional instructions regarding navigation through the reporting screens. If you report through batch, you should also refer to the Standard Batch Reporting Instructions and Specification.

4.4 Instructions for Submitting a Change to a Previously Submitted Report

If you have to submit a change to a previously submitted suspicious transaction 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 30 calendar days of your having reasonable grounds to suspect, as explained in Section 2.2.

If you report through batch, refer to the technical documentation called Standard Batch Reporting Instructions and Specification to find out how to submit corrections for previously submitted reports by batch. If you choose to do this through F2R instead of by batch, read Section 4.5. That choice means that you cannot submit corrections by batch.

If you report through F2R, read Section 4.5.

4.5 Submitting Changes Through F2R

If you need to change a suspicious transaction report that you previously submitted to FINTRAC, you will have to request access to the report requiring change for this purpose. Once you are logged on to F2R, go to the "Report" area from the blue menu bar at the top and select "Request for change" from the left side menu. Enter the FINTRAC report reference number for the report in need of correction.

Within a few moments of your request, the screens for that report will be made available to you through the “Report queues. Click on the number under “Request for change.

Change details

Before any change to a report can be submitted to FINTRAC, you have to provide an explanation as to the correction made and provide a reason for the change.

Remember that you must provide any required changes to FINTRAC within the 30-calendar-day reporting deadline for the report.

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5. Comments?

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

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6. How to Contact FINTRAC

For further information on FINTRAC and its activities, and report submission, please go to FINTRAC's Web site (http://www.fintrac.gc.ca) or contact FINTRAC:

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

Toll-free: 1-866-346-8722