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

February 2006

This, along with the new Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC and new Guideline 8C: Submitting non-SWIFT Electronic Funds Transfer Reports to FINTRAC by Paper, replaces the previous version of Guideline 8: Submitting Electronic Funds Transfer Reports to FINTRAC issued in November 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. Electronic Funds Transfer Reporting Requirements.

   2.1 FINTRAC Enrolment

   2.2 When Do You Have to Report Electronic Funds Transfers?

   2.3 SWIFT Electronic Funds Transfers

   2.4 All Other Reportable Electronic Funds Transfers (non-SWIFT)

   2.5 Electronic Funds Transfers in Foreign Currency

   2.6 Other Requirements Associated with Electronic Funds Transfers

   2.7 Reporting Timeframes for Electronic Funds Transfer Reports

   2.8 Means of Reporting Electronic Funds Transfers 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 Non-SWIFT Electronic Funds Transfer 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 non-SWIFT Electronic Funds Transfer Reports

Appendix 1A: Field by Field Instructions for an Outgoing International non-SWIFT Electronic Funds Transfer Report (EFTO)

Appendix 1B: Field by Field Instructions for an Incoming International non-SWIFT Electronic Funds Transfer Report (EFTI)

Appendix 2: Navigation Through Non-SWIFT EFT Report Screens

Appendix 3: Scenarios for EFT Reports Involving Another Reporting Entity

Back to the guidelines menu

1.  General

The following have to report electronic funds transfers (EFTs) 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);
• foreign exchange dealers (persons and entities engaged in the business of foreign exchange dealing); and
• money services businesses (including alternative remittance systems, such as Hawala, Hindi, Chitti, etc.).

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

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.

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. Also throughout this guideline, the term "reporting entity" refers to any person or entity required to report to electronic funds transfers to FINTRAC.

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2.  Electronic Funds Transfer Reporting Requirements

2.1  FINTRAC Enrolment

Effective February 2006, as a reporting entity, you have to be enrolled with FINTRAC for electronic reporting. 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 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 enrol before you report.

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

2.2  When Do You Have to Report Electronic Funds Transfers?

If you are a financial entity, a money services business or a foreign exchange dealer, you have to report certain international electronic funds transfers (EFTs) to FINTRAC. Read Section 2.3 to find out more about SWIFT EFTs. Section 2.4 and the rest of this guideline contain information about any other type of reportable EFT (i.e., non-SWIFT).

2.3  SWIFT Electronic Funds Transfers

The SWIFT EFT reporting requirement is only applicable to you if you send EFTs by transmission of a SWIFT MT 100 or 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.

Note:  A reportable EFT includes the SWIFT MT 100 message. However, this type of message was removed from the SWIFT network in November 2003.

If 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.

2.4  All Other Reportable Electronic Funds Transfers (non-SWIFT)

The rest of this guideline provides information about the reporting requirement for international "non-SWIFT" EFTs. 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 Section 2.3.

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:

• in a single transaction; or
• in two or more transfers of less than $10,000 each (that total $10,000 or more) in the following situations:
  • if you are an entity, your employee or senior officer knows the transfers were made within 24 consecutive hours of each other by or on behalf of the same individual or entity; or 
  • if you are an individual, you know the transfers were made within 24 consecutive hours of each other by or on behalf of the same individual or entity.

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 foreign exchange dealer 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 3 for example scenarios of this type of situation.

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

• in a single transaction; or
• in two or more transfers of less than $10,000 each (that total $10,000 or more) in the following situations:
  • if you are an entity, your employee or senior officer knows the transfers were made within 24 consecutive hours of each other by or on behalf of the same individual or entity; or 
  • if you are an individual, you know the transfers were made within 24 consecutive hours of each other by or on behalf of the same individual or entity.

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

If you are a financial entity, money services business or foreign exchange dealer 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 foreign exchange dealer in Canada. However, if you receive this type of instructions from another financial entity, money services business or foreign exchange dealer in Canada, you do not have to make an incoming EFT report even if the original sender was outside Canada. See Appendix 3 for example scenarios of this type of situation.

2.5  Electronic Funds Transfers in Foreign Currency

If you send 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 noon 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 noon rate from the previous working day (in this case, Friday) to determine whether the transaction is reportable. You can find the noon rate 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 an EFT in a foreign currency is reportable based on the Bank of Canada noon 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 noon 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. 

2.6  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. These are explained in Guideline 6: Record Keeping and Client Identification.

Large cash transaction report
If an EFT transaction is initiated in cash (in the amount of $10,000 or more), you may 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 the following guidelines:

• 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 should not 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 guidelines:

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

2.7  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. 

2.8  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: 

• 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 8C: Submitting non-SWIFT Electronic Funds Transfer Reports to FINTRAC by Paper for more information on submitting paper non-SWIFT EFT reports to FINTRAC. 

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3.  Electronic Reporting

3.1  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 (see Section 2.8).

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

• FINTRAC's secure Web site (F2R); or
• 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 2.8.

If you were reporting using FINTRAC's Report Preparation Software, this reporting method is no longer available as of February 2006.

3.2  How to Complete Electronic Reports

Reporting through F2R
F2R 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). 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 non-SWIFT EFTs 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 Appendices 1A and 1B for instructions and details regarding the content of fields in a non-SWIFT EFT report.

3.3  Acknowledgement of Receipt of an Electronic Report

FINTRAC will send you an acknowledgement message when your EFT 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 your EFT report contains incomplete information, FINTRAC may notify you. The notification will indicate the date and time your report was received, the FINTRAC-generated identification number, 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 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 Non-SWIFT Electronic Funds Transfer Report

4.1  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:

• Outgoing International non-SWIFT EFT Report (EFTO)
  (see Appendix 1A)
• Incoming International non-SWIFT EFT Report (EFTI)
  (see Appendix 1B)

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 non-SWIFT EFT 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 2.5, 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: 

• 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.

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

As explained in Section 2.4, 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 transaction, even if you are reporting multiple EFTs of less than $10,000 each.

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 F2R 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 non-SWIFT EFTO or EFTI reports, you will be able to select these report types 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 non-SWIFT EFT report, but some are only to be completed if the part is applicable.

See Appendix 1A or 1B 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 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 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 non-SWIFT EFT 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 non-SWIFT EFT 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 non-SWIFT EFT 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. You will get a search screen to retrieve the report in need of change. 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 five working days of the EFT.

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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 at 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