FINTRAC Interpretation Notice no. 5

March 14, 2014

Large Cash Transactions through Automated Banking Machines

The purpose of this interpretation notice is to clarify the requirements for financial entities when large cash transactions are conducted through an automated banking machine (ABM).

Relevant Provisions of the Regulations

The Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR) subsection 1(2) definition of "large cash transaction record"; section 3, paragraph 12(1)(a); section 13, and section 53.

Keeping a Record

If a cash transaction in the amount of $10,000 or more is conducted at an ABM, a large cash transaction record is required to capture the information on the receipt of the cash. A record is also required when a series of cash transactions are considered to be a large cash transaction under the 24-hour rule. (For more information about the 24-hour rule, see FINTRAC Interpretation Notice No. 4.)

The large cash transaction record has to include the name of each individual or entity in whose account the amount was deposited. However, there is no requirement for the large cash transaction record to include the name of the individual who made the deposit.

For more information about what is required in a large cash transaction record, see Guideline 6G: Record Keeping and Client Identification for Financial Entities.

Reporting the Transaction

If a cash transaction in the amount of $10,000 or more is conducted at an ABM or if a series of cash transactions at an ABM, or multiple ABMs, are considered to be a large cash transaction based on the 24-hour rule, a large cash transaction report is required.

Individual Conducting the Transaction

For a transaction using an ABM, it is reasonable to assume that the cardholder whose ABM card was used to access the ABM is the conductor of the transaction, unless other information is provided.

Identifying the Conductor

When cash is deposited through an ABM, financial entities are not required to identify the individual making the deposit.

Information about Where the Transaction Occurred

If a large cash transaction is conducted through an ABM, the complete address of the location of the ABM where the transaction occurred is required in Part A (Information about where the transaction took place) of the large cash transaction report.

Cash Transactions through the ABM of Another Financial Entity

Generally, ABM deposits are only possible within the ABM network of the same financial entity. However, some financial entities have entered into agreements to enable their clients/members to make deposits at another financial entity's ABMs.

In these situations, the financial entity that holds the client/member's account has the reporting obligation and record keeping requirements associated with large cash transactions conducted for those accounts through the ABM of another financial entity. The financial entity holding the client's/member's account must ensure that arrangements are in place in order to be informed by the financial entity whose ABM received the deposit that their client/member conducted a large cash transaction. The financial entity holding the client's/member's account also needs to obtain the required information from the other financial entity, such as the time, date and exact amount of the cash transaction, as well as the complete address of the ABM.

The financial entity holding the client/member's account must ensure that its locations in F2R are updated to include the address information for the other financial entity's ABM that was used in the transaction, in order for the information to be included in the large cash transaction report.

Cash Transactions into a Business Account through an ABM that is (Other than a Night Deposit or a Quick Drop)

Some financial entities provide business clients with the opportunity to make cash deposits using the night deposit box and then immediately update their account using an ABM.

To make this type of deposit, business clients must use an ABM (using their ABM card and PIN). The transaction is typically recorded as an ABM transaction by the financial entity's system, and commercial clients are immediately credited their deposits, which are verified the following day.

Although the cash was deposited in the night deposit box, the operation was carried out using an ABM. Therefore, this type of transaction is not considered to be a night deposit and should not be treated as such.

Since the transaction is carried out at an ABM in a business account (other than a night deposit or quick drop), Part E of the Large Cash Transaction Report (Information on the person conducting the transaction that is a deposit into a business account other than a night deposit or a quick drop) becomes mandatory and the name of the person who deposited the money must be entered in Part E.

The cardholder whose ABM card was used to access the ABM is the conductor of this transaction. If the name on the ABM card is the business's name, one of the three signing authorities for the business account may be designated as the person who deposited the money. The name of the business should not be entered as the conductor on the large cash transaction report.

For more information about reporting large cash transactions, see Guideline 7: Submitting Large Cash Transaction Reports to FINTRAC.

This interpretation notice clarifies how FINTRAC administers and interprets provisions of the existing legislation, regulations or guidelines. It is not based on specific circumstances and may be subject to change in the event of additional or different considerations.


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