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

As per the amendments to the Regulations that came into force on June 1, 2021, reporting entities must submit an electronic funds transfer (EFT) report to FINTRAC only when:

For more information related to FINTRAC's expectation of reporting entities who may be facing challenges with the EFT reporting obligation, please see the Notice on the assessment of obligations coming into force on June 1, 2021.

Also, as of June 1, 2021 (as described in the Notice on forthcoming regulatory amendments and flexibility, updated December 2, 2021), FINTRAC expects reporting entities to continue submitting EFT reports as they did before June 1, 2021, and to continue using the current reporting form until the updates to the form are implemented.

Overview

The objective of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) is to help detect and deter money laundering and the financing of terrorist activities. It is also to facilitate investigations and prosecutions of money laundering and terrorist activity financing offences. This includes reporting, record keeping, client identification and compliance regime requirements for individuals and entities described in section 2.

If you are such an individual or entity, this guideline has been prepared to help you submit electronic funds transfer (EFT) reports electronically. It explains reporting timelines, how reports have to be sent to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), and what information has to be included in these reports.

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.

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 this guideline, 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.

Who is this guidance for

  • Financial entities
  • Money services businesses
  • Casinos

In this guidance

  1. Overview
  2. Who Has to Send an Electronic Funds Transfer Report to FINTRAC?
  3. Electronic Funds Transfer Reporting Requirements
  4. Electronic Reporting
  5. Instructions for Completing a Non-SWIFT Electronic Funds Transfer Report
  6. Comments?
  7. How to Contact FINTRAC

Related guidance

2. Who Has to Send an Electronic Funds Transfer Report to FINTRAC?

If you are one of the following individuals or entities (called reporting entities), you must report EFTs to FINTRAC.

**Note: If you are a financial entity or casino, you do not have to submit an EFT report when you initiate or are the final recipient of an international EFT of $10,000 or more in a single transaction when the EFT is carried out by means of a credit/debit card or prepaid payment product, where the beneficiary has an agreement with the payment service provider that permits payment by that means for the provision of goods and services.

2.1 Financial entities

Financial entities are banks (that is, those listed in Schedule I or II of the Bank Act) or authorized foreign banks with respect to their operations in Canada, credit unions, caisses populaires, financial services cooperatives, credit union centrals (when they offer financial services to anyone other than a member entity of the credit union central), trust companies, loan companies and agents of the Crown that accept deposit liabilities.

If you are a financial entity and you have foreign subsidiaries or foreign branches, the EFT reporting requirement does not apply to their operations outside Canada.

2.2 Money services businesses

A money services business means an individual or entity engaged in the business of any of the following activities:

Money services businesses include alternative money remittance systems, such as Hawala, Hundi, Chitti, etc.

For more information about who is engaged in the money services business, see FINTRAC guidance for Money services businesses.

2.3 Casinos

You have legislative requirements under the PCMLTFA if you are a casino. A casino is an entity that is authorized to do business in Canada if it is:

A registered charity authorized to carry on business in a casino for a period of two consecutive days or less, under the supervision of the casino, is not considered to be a casino.

In Canada, the provincial and territorial governments delegate which entity is legally responsible, and can therefore conduct and manage the gaming activities at a casino. The reporting entity subject to the Act, is the entity that is authorized by the province to conduct and manage a casino.

3. Electronic Funds Transfer Reporting Requirements

3.1 Electronic reporting enrolment

As a reporting entity, you have to be enrolled with FINTRAC's electronic reporting system to report electronically.

For more information about FINTRAC enrolment, contact us as explained in section 7.

3.2 When do you have to report electronic funds transfers?

If you are a reporting entity as described in section 2, you have to report incoming and outgoing international electronic funds transfers (EFTs) of $10,000 or more to FINTRAC no later than five working days after the day of the transmission of the instructions (see subsection 3.7). Read subsection 3.3 to find out more about SWIFT EFTs. Subsection 3.4 and the rest of this guideline contain information about any other type of reportable EFT (that is, non-SWIFT).

3.3 SWIFT electronic funds transfers

The incoming and outgoing SWIFT EFT reporting requirement is only applicable to you if you are a financial entity or a money services business. Furthermore, it only applies if you send or receive EFTs by transmission of a SWIFT 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.

If you are a financial entity or a money services business and 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.

3.4 All other reportable electronic funds transfers (non-SWIFT)

The rest of this guideline provides information about the reporting requirement for international "non‑SWIFT" EFTs. This applies to you if you are a financial entity, a money services business or a casino. 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 subsection 3.3.

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:

This type of EFT requires that you send an Outgoing International Non-SWIFT EFT Report (EFTO) to FINTRAC.

Incoming EFTs

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

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

Exception to the 24-hour rule for EFTs

The following exception applies if you send or receive a bundled EFT, that is an EFT with more than one beneficiary. The 24-hour-rule will not apply for any of the amounts under $10,000 included in a bundled EFT if it was sent at the request of a public body, a very large corporation, or the administrator of a federally or provincially regulated pension fund.

In this context, a public body means any of the following or their agent:

Also in this context, a very large corporation is one that has minimum net assets of $75 million on its last audited balance sheet. The corporation's shares have to be traded on a Canadian stock exchange or on a stock exchange outside Canada that is designated by the Minister of Finance. The corporation also has to operate in a country that is a member of the Financial Action Task Force (FATF). For more information about stock exchanges outside Canada that are designated by the Minister of Finance, refer to the July 2, 2008 news release available in the News area of the Department of Finance's Web site (https://www.canada.ca/en/department-finance.html).

To find out which countries are members of the FATF, refer to its Web site (http://www.fatf-gafi.org).

3.5 Electronic funds transfers in foreign currency

If you send or receive 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 exchange 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 rate from the previous working day (in this case, Friday) to determine whether the transaction is reportable. You can find the rate on the Bank of Canada Web site at https://www.bankofcanada.ca/rates/exchange/.

If there is no Bank of Canada 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 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 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.

3.6 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. For more information refer to FINTRAC record keeping guidance.

Originator information to include with transfers

If you send or receive an EFT of any amount, at the request of a client, there are obligations about originator information included with the transfer. For more information refer to FINTRAC know your client guidance.

Large cash transaction report

If an EFT transaction is initiated in cash, in the amount of $10,000 or more, you will likely 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 suspicious transaction reports, consult STR guidance.

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 Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism 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:

Casino disbursement report

If you are a casino sending an EFT that is part of a casino disbursement in the amount of $10,000 or more, you will likely have to make a casino disbursement report to FINTRAC in addition to making the EFT report about the transaction as required. For more information about making casino disbursement reports, consult Guideline 10: Submitting Casino Disbursement Reports to FINTRAC.

3.7 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. The day of the transfer means:

3.8 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:

See section 4 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.

4. Electronic Reporting

4.1 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 to do so (see subsection 3.8).

There are two options for electronic reporting:

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 subsection 3.8.

4.2 How to complete electronic reports

Reporting through FINTRAC web reporting

FINTRAC web reporting contains the reporting screens for electronic funds transfer reports, with completion instructions. Drop-down menus appear wherever a code or specific selection is required.

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, refer to the Batch reporting page.

Consult the Standard Batch Reporting Instructions and Specification for more information about how to report non-SWIFT EFTs through batch file transfer. You can also refer to Appendices 1A and 1B for instructions and details regarding the content of fields in a non-SWIFT EFT report.

4.3 Acknowledgement of receipt of an electronic report

FINTRAC will send you an acknowledgement message when your EFT report has been received electronically.

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 FINTRAC web reporting, you will receive an acknowledgement message, including the date and time your report was received and the report’s identification number. These acknowledgements will be stored within the FINTRAC web reporting system and available for viewing or printing.

4.4 Report corrections

If you need to request an EFT report for change in FINTRAC web reporting, you will do so based on the acknowledgement for that report.

In addition, if your EFT report contains incomplete or inaccurate information, FINTRAC may notify you. The notification will indicate the date and time your report was received, a FINTRAC-generated identification number for the report, 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 transfer (see subsection 3.7). 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 FINTRAC web reporting, you will have to make that correction through FINTRAC web reporting.

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 FINTRAC web reporting.

5. Instructions for Completing a Non-SWIFT Electronic Funds Transfer Report

5.1 General instructions

The contents of a non-SWIFT EFT depend on whether it is an outgoing or incoming transfer.

If you report through batch, you need to refer to the Standard Batch Reporting Instructions and Specification.

As explained in subsection 3.8, 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:

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

As explained in subsection 3.4, 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 EFT transaction, even if you are reporting multiple EFTs of less than $10,000 each.

5.2 Accessing the FINTRAC web reporting screens

To access FINTRAC web reporting, reporting entities must be enrolled for electronic reporting with FINTRAC.

If you are authorized to complete non-SWIFT EFTO or EFTI reports, you will be able to select these report types in FINTRAC web reporting. You will be able to complete a new report or continue working on an incomplete report (that is, a report that was not previously submitted to FINTRAC).

Also, depending on your access rights, you will be able to submit a request for change to a completed report (that is, one that was previously submitted to FINTRAC). Subsection 5.4 contains instructions for submitting a change to a previously submitted report.

5.3 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.

If you report through batch, you should also refer to the Standard Batch Reporting Instructions and Specification.

5.4 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 transfer.

If you report through batch, refer to the technical documentation called Standard Batch Reporting Instructions and Specification to find out how to submit changes for previously submitted reports by batch. If you choose to do this through FINTRAC web reporting instead of by batch, read subsection 5.5. That choice means that you cannot submit changes by batch.

If you report through FINTRAC web reporting, read subsection 5.5.

5.5 Submitting changes through FINTRAC web reporting

The following explains how to make a change to a previously submitted non-SWIFT EFT report through FINTRAC web reporting:

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 transfer.

6. 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-lignesdirectrices@fintrac-canafe.gc.ca.

7. How to Contact FINTRAC

For further information on FINTRAC and its activities, reporting and other obligations, please go to FINTRAC's Web site at https://fintrac-canafe.canada.ca or contact FINTRAC:

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

Toll-free: 1-866-346-8722

Details and history

Published: April 2022

For assistance

If you have questions about this guidance, please contact FINTRAC by email at guidelines-lignesdirectrices@fintrac-canafe.gc.ca.

Date Modified: