Guideline 7B: Submitting Large Cash Transaction Reports to FINTRAC by Paper

March 29, 2004

This replaces the previous version of Guideline 7B: Submitting Large Cash Transaction Reports to FINTRAC by Paper issued in March 2003.  The changes made since then are indicated in the right margin of the PDF version.

Table of Contents

1. General
2. Large Cash Transaction Reporting Requirements

   2.1 When Does a Large Cash Transaction Report Have to be Made? 2.2 Cash Transactions in Foreign Currency 2.3 Other Requirements Associated with Large Cash Transactions 2.4 Means of Reporting to FINTRAC

3. Paper Reporting

   3.1 How to Complete Paper Reports 3.2 How to Send Paper Reports to FINTRAC 3.3 Acknowledgement of Receipt of a Paper Report

4. Instructions for Completing a Large Cash Transaction Report
5. Comments?
6. How to Contact FINTRAC

1. General

The following persons or entities have to report large cash transactions to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC):

• financial entities (such as banks, credit unions, caisses populaires, trust and loan companies and agents of the Crown that accept deposit liabilities);
• life insurance companies, brokers and agents;
• securities dealers, portfolio managers and investment counsellors;
• persons and entities engaged in the business of foreign exchange dealing;
• money services businesses (including alternative remittance systems, such as Hawala, Hindi, Chitti, etc.);
• agents of the Crown that sell or redeem money orders;
• accountants and accounting firms (when carrying out certain activities on behalf of their clients);
• real estate brokers or sales representatives (when carrying out certain activities on behalf of their clients); and
• casinos with a slot machine or roulette or card games, but excluding certain temporary charity casinos.

If you are one of these reporting persons or entities, this guideline has been prepared by FINTRAC to help you submit large cash transaction reports by paper.  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 person or entity and are an employee, an agent or acting on behalf of another reporting person or 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, 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 when and how to submit terrorist property reports.
• 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.
• 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.
• 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 FINTRACs 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.

2. Large Cash Transaction Reporting Requirements

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.

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

If you are a reporting person or entity (see 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 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. 

If you are a reporting person and an employee of a reporting person or entity, your employer is responsible for meeting the large cash transaction reporting requirement associated to any of your activities as an employee. 

Similarly, if you are a reporting person or entity and you are an agent of or you are authorized to act on behalf of a reporting person or entity, it is that reporting person or entity’s responsibility to meet the large cash transaction reporting requirement associated to any of your activities on their behalf.  However, if you are a life insurance broker or independent agent, you are responsible for reporting to FINTRAC (unless you are an employee as explained above). 

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 a bank, credit union, caisse populaire, a trust and loan company or an agent of the Crown that accepts deposit liabilities.   

If you are a reporting person or 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.

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2.2 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. The large cash transaction report does not require information about any exchange rate applicable to the transaction. The exchange rate is only relevant to determine whether or not the transaction is a large cash transaction.

2.3 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 results in 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

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2.4 Means of Reporting to FINTRAC

Electronic Reporting

As a reporting person or 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 the following Web browsers: Internet Explorer version 5.x (Windows 98/Me/NT/2000); and

• An Internet connection

See Guideline 7A: Submitting Large Cash Transactions to FINTRAC Electronically for more information.

Paper Reporting

If you do not have the technical capabilities to send reports electronically, you must submit reports on paper. See Section 4 (below) for more information on submitting paper large cash transaction reports to FINTRAC.

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3. Paper Reporting

If you do not have the technical capability (see Section 2.3 above), you will have to submit paper large cash transaction reports to FINTRAC. In this case, forms will be available for paper filing as follows:

• A file is accessible from the reporting forms area of the publications section of FINTRAC’s Web site (http://www.fintrac.gc.ca/publications/pub_e.asp) to be printed at your local library or any other place with Internet access
• Call 1-866-346-8722 for a copy to be faxed or mailed to you.

See Section 4 for completion instructions.  It includes details of what each field must contain for a large cash transaction report. 

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3.2 How to Send Paper Reports to FINTRAC

There are two ways to send a paper report to FINTRAC:

• Fax: 1-866-226-2346; or
• Mail to the following address:

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3.3 Acknowledgement of Receipt of a Paper Report

FINTRAC will not send you any acknowledgement when your paper large cash transaction report has been received.

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4. Instructions for Completing a Large Cash Transaction Report

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5. Comments?

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6. How to Contact FINTRAC

For further information on FINTRAC and its activities, and report submission, please go to FINTRACs Web site or contact FINTRAC:

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