Guideline 8C: Submitting Electronic Funds Transfer Reports to FINTRAC by Paper

April 2006

This, along with the new Guideline 8A: Submitting non-SWIFT Electronic Funds Transfer Reports to FINTRAC Electronically and new Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC, 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  When Do You Have to Report Electronic Funds Transfers?

   2.2  SWIFT Electronic Funds Transfers

   2.3  All Other Electronic Funds Transfers

   2.4  Electronic Funds Transfers in Foreign Currency

   2.5  Other Requirements Associated with Electronic Funds Transfers

   2.6  Reporting Timeframes for Electronic Funds Transfer Reports

   2.7  Means of Reporting Electronic Funds Transfers 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 an International Electronic Funds Transfer Report
   • General information
   • Part A: Information about the transaction
   • Part B: Information about the client ordering the EFT
   • Part C: Information about the individual or entity sending the payment instructions for the EFT
   • Part D: Information about any third party related to the EFT order
   • Part E: Information about the individual or entity receiving the payment instructions for the EFT
   • Part F: Information about the client to whose benefit payment is made
   • Part G: Information about any third party beneficiary of the EFT payment (if the client to whose benefit the payment is made is acting on behalf of a third party)
5. Comments?
6. How to Contact FINTRAC

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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  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 EFTs to FINTRAC. Read Section 2.2 to find out more about SWIFT EFTs. Section 2.3 and the rest of this guideline contain information about any other type of reportable EFT (i.e., non-SWIFT).

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2.2  SWIFT Electronic Funds Transfers

The SWIFT EFT reporting requirement is only applicable to you if you send EFTs 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.

These reports cannot be made on paper. They can only be made electronically. Please refer to Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC for information about submitting reports about SWIFT EFTs.

Your reporting obligations regarding EFTs also include sending or receiving EFTs by any other means, as explained below.

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2.3  All Other Electronic Funds Transfers

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 2.2.

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

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 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 to FINTRAC unless you provide them with the client's name and address. In other words, if you give them your client's name and address, you do not have to report the EFT.

See Appendix 1 for example scenarios of this type of situation.

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 Electronic Funds Transfer Report 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 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 1 for example scenarios of this type of situation.

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2.4  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.

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.

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2.5  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

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2.6  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.

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2.7  Means of Reporting Electronic Funds Transfers to FINTRAC

Electronic reporting

As a reporting person or entity, you 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 the following Web browsers: Internet Explorer version 5.x (Windows® 98/Me/NT/2000); and
• An Internet connection.

Please refer to Guideline 8A: Submitting Electronic Funds Transfer Reports to FINTRAC Electronically 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 Section 3 for more information on submitting paper EFT reports to FINTRAC.

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3  Paper Reporting

3.1  How to Complete Paper Reports

If you do not have the technical capability to submit reports electronically (see Section 2.7), you have to submit paper EFT 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) 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 details of what each field must contain for the non-SWIFT EFT report.

If you have to submit SWIFT EFT reports, these cannot be made on paper. They can only be made electronically, as explained in Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC.

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

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3.3  Acknowledgement of Receipt of a Paper Report

FINTRAC will not send you any acknowledgement when your paper EFT report has been received.

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4  Instructions for Completing an International Electronic Funds Transfer Report

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, 24th floor
Ottawa, Ontario
Canada K1P 1H7

Toll-free: 1-866-346-8722

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