Section 5: Reporting Requirements

What is FINTRAC?

The Financial Transactions and Reports Analysis Centre of Canada

What is FINTRAC's role?

Collect analyze and disclose information to detect prevent and deter ML and TF

Who has reporting obligations under the PCMLTFA?

Reporting entities

What are the seven report types in Section 5?

LCTR LPEPR STR EFTR Cross Border Currency Casino Disbursement and LVCTR

What does LCTR stand for?

Large Cash Transaction Report

What does LPEPR stand for?

Listed Person or Entity Property Report

What does EFTR stand for?

Electronic Funds Transfer Report

What does LVCTR stand for?

Large Virtual Currency Transaction Report

What does MSB stand for?

Money Services Business

What activities can make a business an MSB?

Foreign exchange money transmission money orders virtual currency and certain PSP activities

What alternative remittance systems are considered MSBs?

Hawala Hundi and Chitti

What is the reporting threshold for an LCTR?

CAD 10000

What is considered cash under the PCMLTFA?

Canadian or foreign bank notes and coins

What is not considered cash for LCTR purposes?

Cheques money orders and negotiable instruments

When must an LCTR be filed?

Within 15 calendar days

Who receives LCTRs?

FINTRAC

What exchange rate is used for foreign currency cash transactions?

Latest Bank of Canada rate available at the time

What is the 24-hour rule?

Aggregation of qualifying transactions within a static 24-hour window

What amount triggers reporting under the 24-hour rule?

CAD 10000 or more

What are the three aggregation categories for LCTRs?

Conductor beneficiary and third party

Can transactions below CAD 10000 become reportable?

Yes through aggregation

What is a static 24-hour window?

A fixed reporting window documented in policies and procedures

Does the 24-hour rule apply across multiple locations?

Yes

Must an LCTR be filed for a CAD 10000 cash deposit through an ABM?

Yes

For ABM deposits who must be identified?

The account holder

When is a financial entity exempt from filing an LCTR?

When cash is received from another financial entity or a public body

What additional requirements accompany an LCTR?

Record keeping and client identification

Can an LCTR also require an STR?

Yes

Can an LCTR also require an EFTR?

Yes

What report replaced the Terrorist Property Report?

LPEPR

When did the LPEPR replace the Terrorist Property Report?

February 28 2025

What is unique about an LPEPR?

A transaction does not need to occur

What triggers an LPEPR?

Property owned or controlled by a terrorist group or listed person or entity

What legislation may create a listed person or entity?

Criminal Code United Nations Act SEMA and Magnitsky Act

What is property for LPEPR purposes?

Any real or personal property under possession or control

Give examples of property under an LPEPR.

Cash accounts real estate securities insurance and virtual currency

Who must submit LPEPRs?

Reporting entities

When must an LPEPR be submitted?

Without delay

Who else must be notified when listed property is identified?

RCMP and CSIS

How quickly must RCMP and CSIS be notified?

Without delay

What must happen if property belongs to a terrorist group?

It must be frozen

Can a transaction involving known terrorist property proceed?

No

When should an STR also be filed with an LPEPR?

When a completed or attempted transaction occurs

What is the maximum fine for LPEPR non-compliance?

Up to CAD 2000000

What is the maximum imprisonment for LPEPR non-compliance?

Up to 5 years

What is the reporting threshold for cross-border currency reporting?

CAD 10000

Is it illegal to move more than CAD 10000 across the border?

No but it must be reported

Who receives cross-border currency reports?

CBSA

Who ultimately analyzes the information?

FINTRAC

What items are covered by cross-border reporting?

Currency and monetary instruments

Give examples of monetary instruments.

Travellers cheques stocks and bonds

Who must report cross-border movements of CAD 10000 or more?

Individuals and businesses

What four methods can transport reportable funds?

Person mail courier and public transportation

What form is used when an individual carries reportable funds?

E677

What form is used for general reporting?

E667

What form is completed by the person in charge of a conveyance?

E668

Which forms are generally used for courier shipments?

E667 and E668

Can undeclared reportable currency be seized?

Yes

What penalty applies to first-time disclosure with no concealment?

5 percent up to CAD 2500

What penalty may apply when funds are concealed or falsely declared?

25 percent of undeclared funds

What penalty may apply when funds are hidden in false compartments?

50 percent of undeclared funds

What is the key compliance obligation for cross-border currency?

Report amounts of CAD 10000 or more

What is an EFT?

Electronic transmission of instructions for the transfer of funds

What is the reporting threshold for EFT reporting?

CAD 10000

Which entities typically report EFTs?

Financial entities MSBs FMSBs and certain casinos

What is a SWIFT EFT commonly called?

Wire transfer

What SWIFT message is commonly associated with reportable EFTs?

MT 103

What is a Non-SWIFT EFT?

International transfer through methods other than SWIFT

Who reports an EFT?

The entity that initiates or finally receives it

Do intermediaries report EFTs?

No

What must intermediaries do?

Keep records and comply with the Travel Rule

What is initiation of an EFT?

The first transmission of transfer instructions

What is final receipt of an EFT?

The final reporting entity receives instructions for remittance

When must an EFT report be submitted?

Within 5 working days

What starts the reporting timeline for outgoing EFTs?

Transmission of instructions

What starts the reporting timeline for incoming EFTs?

Receipt of instructions

What are the aggregation categories for outgoing EFTs?

Requester third party and beneficiary

What are the aggregation categories for incoming EFTs?

Requester and beneficiary

Can SWIFT and Non-SWIFT EFTs be aggregated together?

Yes

What is the Travel Rule?

Required transfer of prescribed originator and beneficiary information

What originator information is required?

Name address and account or reference number

What beneficiary information is required?

Name address and account or reference number if applicable

Can Travel Rule information be removed?

No

What should be done if Travel Rule information is missing?

Take reasonable measures to obtain it

What may happen if Travel Rule information cannot be obtained?

The transaction may be suspended or rejected

Since 2015 who also receives reportable EFT information?

CRA

Does one report satisfy both FINTRAC and CRA requirements?

Yes

Can an EFT also require an LCTR?

Yes

Can an EFT also require an STR?

Yes

What is a Casino Disbursement Report?

A report for qualifying casino disbursements

What is the reporting threshold for a Casino Disbursement Report?

CAD 10000

When must a Casino Disbursement Report be filed?

Within 15 calendar days

Who receives Casino Disbursement Reports?

FINTRAC

Does the 24-hour rule apply to casino disbursements?

Yes

What casino aggregation categories apply?

Same requester same beneficiary or same person on whose behalf conducted

Should casinos wait until the end of the 24-hour window before reporting?

Yes

Name common reportable casino disbursements.

Chip redemption slot jackpots bets credit advances cheque cashing and reimbursements

Are payouts in chips tokens or slot tickets reportable disbursements?

No