Guideline 7A: Submitting Large Cash Transaction Reports to FINTRAC Electronically

February 2006

This replaces the previous version of Guideline 7A: Submitting Large Cash Transaction Reports to FINTRAC Electronically issued in March 2004. 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. Large Cash Transaction Reporting Requirements

   2.1 FINTRAC Enrolment

   2.2 When Does a Large Cash Transaction Report Have to be Made?

   2.3 Cash Transactions in Foreign Currency

   2.4 Other Requirements Associated with Large Cash Transactions

   2.5 Means of Reporting to FINTRAC

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 Large Cash 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 Large Cash Transaction Report

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

1. General

The following have to report large cash 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 area 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 large cash 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. It also explains who has to report large cash transactions if you are a reporting entity and are an employee, an agent or acting on behalf of another reporting entity.

This guideline uses plain language to explain the most common reporting situations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the 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. Furthermore, all references to cash mean money in circulation in any country (bank notes or coins). In this context, cash does not include cheques, money orders or other similar negotiable instruments.

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. Large Cash 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 to FINTRAC, please contact FINTRAC (as explained in Section 6) to enroll before you report.

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

2.2 When Does a Large Cash Transaction Report Have to be Made?

If you are a reporting entity as described in Section 1, you have to send a large cash transaction report to FINTRAC in the following situations:

• You receive an amount of $10,000 or more in cash in the course of a single transaction;or
• You receive two or more cash amounts of less than $10,000 each that total $10,000 or more. In this case, if you are an individual, you have to make a large cash transaction report if you know the transactions were made within 24 consecutive hours of each other by or on behalf of the same individual or entity. If you are an entity, you have to make a large cash transaction report if your employee or senior officer knows the transactions were made within 24 consecutive hours of each other by or on behalf of the same individual or entity.

You have to send a large cash transaction report to FINTRAC within 15 calendar days after the transaction.

Employees or agents of another reporting entity

If you are a person described in Section 1 and you are an employee of a reporting entity, your employer is responsible for meeting the large cash transaction reporting requirement associated to any of your activities as an employee. This would apply, for example, in the case of an accountant employed by a bank.

Similarly, if you are a person or entity described in Section 1 and you are an agent of or you are authorized to act on behalf of a reporting entity, it is that reporting entity' s responsibility to meet the large cash transaction reporting requirement associated to any of your activities on their behalf. This would apply for example in the case of a credit union acting as an agent for another credit union. However, if you are a life insurance broker or independent agent and as such are authorized to act on behalf of another reporting entity, you are responsible for meeting the large cash transaction reporting requirement to FINTRAC (unless you are an employee as explained above).

Exceptions to reporting large cash transactions

You do not have to make a large cash transaction report to FINTRAC if the cash is received from a financial entity. In this context, a financial entity means any of the following:

• a bank (i.e., one that is listed in Schedule I or II of the Bank Act) or an authorized foreign bank with respect to its operations in Canada;
• a credit union or a caisse populaire;
• a trust and loan company; or
• an agent of the Crown that accepts deposit liabilities. 

If you are a reporting entity other than a casino, you do not have to make a large cash transaction report to FINTRAC if the cash is received from a public body. In this context, a public body means any of the following or their agent:

• a provincial or federal department or Crown agency;
• an incorporated municipal body (including an incorporated city, town, village, metropolitan authority, district, county, etc.);
• a hospital authority. a hospital authority means an organization that operates a public hospital and that is designated to be a hospital authority for GST/HST purposes. For more information on the designation of hospital authorities, refer to GST/HST Memoranda Series, Chapter 25.2, Designation of Hospital Authorities available from the Canada Revenue Agency' s Web site. At the time of publishing of this guideline, the document was available at the following link: http://www.ccra-adrc.gc.ca/E/pub/gm/25-2/README.html

Financial entities may choose, in certain specific circumstances, an alternative to making large cash transaction reports for certain clients that are corporations. If you are a financial entity, see Guideline 9: Submitting Alternative to Large Cash Transaction Reports to FINTRAC for more information about this.

2.3 Cash Transactions in Foreign Currency

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

For example, for a cash transaction in foreign currency that happened at 9:00 am on Tuesday following a holiday Monday, you would use the Bank of Canada noon rate from the previous Friday to determine whether it is a large cash transaction. You can find the noon rate applicable at the time of a transaction on the Bank of Canada Web site at http://www.bankofcanada.ca/en/exchange.htm. If there is no Bank of Canada noon 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 a cash transaction in foreign currency is in fact reportable based on the Bank of Canada noon rate, you will have to send a large cash transaction report to FINTRAC. On this report, you will indicate any amounts involved in the transaction in foreign currency, and indicate the appropriate currency code. You are not required to provide information about any exchange rate applicable to the transaction in the large cash transaction report. The exchange rate is only relevant to determine whether or not the transaction is a large cash transaction.

2.4 Other Requirements Associated with Large Cash Transactions

In addition to the reporting requirements explained in this guideline, consider the following relating to a large cash transaction:

Record keeping and client identification
Large cash transactions have associated record keeping and client identification requirements. These are explained in Guideline 6: Record Keeping and Client Identification.

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

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

Suspicious transaction report
If anything about a large cash 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. This would be in addition to making the large cash transaction report about the same transaction as required.

The suspicious transaction report has very similar fields to those of a large cash transaction report. There are some differences, such as a field in the suspicious transaction report for you to explain your suspicion about the transaction. There is also a field in that report for you to describe what action, if any, was taken by you as a result of the suspicious transaction. This would include stating that you have made a large cash transaction report for the same transaction (if that is the case).

For more information about suspicious transaction reports, consult the following:

• Guideline 1: Backgrounder
• Guideline 2: Suspicious Transactions
• Guideline 3: Submitting Suspicious Transaction Reports to FINTRAC

Transactions related to terrorist property
If you know that any proposed transaction is related to property owned or controlled by or on behalf of a terrorist or a terrorist group, you cannot complete the transaction. This is because terrorist property must be frozen under the United Nations Suppression of Terrorism Regulations 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:

• Guideline 1: Backgrounder
• Guideline 5: Submitting Terrorist Property Reports to FINTRAC

2.5 Means of Reporting to FINTRAC

Electronic Reporting
As a reporting entity, you will have to submit all large cash transaction reports 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.

Paper Reporting
If you do not have the technical capabilities to send reports electronically, you must submit reports on paper. See Guideline 7B: Submitting Large Cash Transaction Reports to FINTRAC by Paper for more information.

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3. Electronic Reporting

3.1 Options for Electronic Reporting

As a reporting entity, you have to report large cash transactions electronically to FINTRAC if you have the technical capabilities (see Section 2.5).

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 will require more advanced technical capability than explained in Section 2.5.

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 large cash 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 large cash transaction report. Also, Appendix 2 explains how to navigate through the F2R reporting screens.

F2R reporting screens will not work properly unless 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 reportingarea 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 large cash transactions through batch file transfer. This document is available from the publications area 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 large cash transaction report.

3.3 Acknowledgement of Receipt of an Electronic Report

FINTRAC will send you an acknowledgement message when your large cash 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 you send a large cash transaction report that contains incomplete information, FINTRAC may notify you. The notification will indicate the date and time your report was received, a FINTRAC-generated identification number, along with information on the fields that must be completed or corrected.

After receiving FINTRAC' s notification, you must provide the necessary information to FINTRAC within the 15-calendar-day reporting deadline. In other words, this information should be sent to FINTRAC within 15 calendar days after the transaction. 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 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 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 F2R.

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4. Instructions for Completing a Large Cash Transaction Report

4.1 General Instructions

Instructions for the fields of the Large Cash 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 in F2R. However, the information about how to complete the fields can also be useful to those completing large cash transaction 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 Section 2.5, if you do not have the technical capability to report electronically, refer to Guideline 7B: Submitting Large Cash Transaction 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: 

• 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.

As explained in Section 2.1, a large cash transaction report can be about multiple transactions 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 transactions were under $10,000, the information for some mandatory fields in the report may not be available in your records or from the time of the transaction. In this case, " reasonable efforts" applies to those otherwise mandatory fields.

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 large cash 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 eight parts to the large cash transaction report, 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 large cash 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 15 calendar days of the large cash transaction.

If you report through batch,refer to the technical documentation called Standard Batch Reporting Instructions and Specificationto 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

To make a change to a previously submitted large cash transaction report through F2R, once you are logged on to F2R, go to the " Report" area from the blue menu bar at the top, and select one of the following:

• Report returned for further action (RRFA)
  If a large cash transaction report is returned to you by FINTRAC for correction, you can access it through the queue for reports returned for further action. Select " Report queues" from the left side menu in the " Report" area and click on the number displayed under " RRFA" . The entire report will be available.
  
  If a zero is displayed, there are no reports awaiting further action in this queue.
   
• Change a report
  If you need to change a large cash transaction report that you previously submitted to FINTRAC, you will have to request that this report be sent back to you for this purpose. Select " Request for change" from the left side menu and 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 change made. If it was not requested by FINTRAC, you also have to provide a reason for the change.

Remember that you must provide any required changes to FINTRAC within the reporting deadline for the report. In other words, this information should be sent to FINTRAC within 15 calendar days after the large cash transaction.

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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