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Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC
September 2008
This replaces the previous version of Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC issued in February 2006. The changes made are indicated by a side bar to the right of the modified text in the PDF version.
Table of Contents
- General
- Who Has to Send an Electronic Funds Transfer Report to FINTRAC?
- 2.1 Financial Entities
- 2.2 Money Services Businesses
- 2.3 Casinos
- Electronic Funds Transfer Reporting Requirements
- 3.1 Electronic Reporting Enrolment
- 3.2 When Do You Have to Report Electronic Funds Transfers?
- 3.3 SWIFT Electronic Funds Transfers
- 3.4 Electronic Funds Transfers in Foreign Currency
- 3.5 Other Requirements Associated with Electronic Funds Transfers
- 3.6 Reporting Timeframes for Electronic Funds Transfer Reports
- Electronic Reporting
- Instructions for Completing a SWIFT Electronic Funds Transfer Report
- Comments?
- How to Contact FINTRAC
Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC (PDF version, 77 KB) 
1. General
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 an individual or entity described in section 2, 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.
Information is included about new obligations or changes to existing obligations that took effect in June 2007 and June 2008. If you need information about requirements in effect before June 2007, consult the previous version of this guideline (February 2006).
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 entities to implement a regime to ensure compliance with their obligations under the Act and associated Regulations.
- Guideline 5: Submitting Terrorist Property Reports to FINTRAC explains to reporting entities when and how to submit a terrorist property report.
- Guideline 6: Record Keeping and Client Identification explains the requirement for reporting entities to identify their clients and keep records. There are several different versions of Guideline 6, with each one applicable to a particular 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 electronic funds transfer reports. There are three different versions of Guideline 8, by type of electronic funds transfer 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.
- Guideline 10: Submitting Casino Disbursement Reports to FINTRAC explains when and how to submit casino disbursement reports. There are two different versions of Guideline 10, by reporting method.
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 individual or entity required to report electronic funds transfers to FINTRAC.
2. Who Has to Send an Electronic Funds Transfer Report to FINTRAC?
If you are one of the following individuals or entities, you must report EFTs to FINTRAC.
The EFT reporting requirement does not apply to legal counsel or legal firms when they are providing legal services.
2.1 Financial Entities
Financial entities are banks (i.e., 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, 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
Effective June 23, 2008, a money services business means an individual or entity engaged in the business of any of the following activities:
- foreign exchange dealing;
- remitting or transmitting funds by any means or through any individual, entity or electronic funds transfer network; or
- issuing or redeeming money orders, traveller's cheques or other similar negotiable instruments. This does not include redeeming cheques payable to a named individual or entity. In other words, cashing cheques made out to a particular individual or entity is not included.
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 the FINTRAC Interpretation Notice No. 1, available under "General publications" on the Publications page of FINTRAC's Web site (http://www.fintrac-canafe.gc.ca).
2.3 Casinos
Effective June 23, 2008, casinos have to report EFTs to FINTRAC. However, this guideline is about SWIFT EFTs and does not apply for casinos. If you are a casino, read Guideline 8A: Submitting non-SWIFT Electronic Funds Transfer Reports to FINTRAC Electronically.
Casinos are those authorized by a Canadian provincial, territorial or federal government to do business and that conduct their business in a permanent establishment. It only includes those where roulette or card games are played in the establishment, or where there is a slot machine. For these purposes, a slot machine does not include a video lottery terminal.
Registered charities may be authorized to carry on business temporarily as a casino for charitable purposes. If this type of business is carried out in the establishment of a casino for no more than two consecutive days at a time under the supervision of the casino, the activities are considered to be the supervising casino's. In this case, the supervising casino is responsible for the requirements explained in this guideline related to the charity 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. FINTRAC will provide you with an identifier number to include in your reports.
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 financial entity, a money services business or a casino, you have to report certain international EFTs to FINTRAC. This guideline explains the reporting requirements related to SWIFT EFTs for financial entities or money services businesses. If you are a casino, or you are a financial entity or a money services business and you send EFTs other than those explained below, read Guideline 8A: Submitting non-SWIFT Electronic Funds Transfer Reports to FINTRAC Electronically.
3.3 SWIFT Electronic Funds Transfers
The 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 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.
You have to send a SWIFT EFT report to FINTRAC for the following transactions:
Outgoing EFTs
These are SWIFT MT 103 messages for $10,000 or more sent 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 24-hour rule 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 SWIFT EFT report to FINTRAC. These reports can only be sent electronically, by batch, as explained in section 4.
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 casino in Canada to send it. In this case, you have to make the related non-SWIFT EFT report (EFTO) to FINTRAC unless you provide that other reporting entity 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 2 for example scenarios of this type of situation.
If you send an EFT to an individual or entity in Canada, you do not have to report it, even if the final recipient of the funds is outside Canada.
Incoming EFTs
These are SWIFT MT 103 messages for $10,000 or more that you receive and that are sent 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 24-hour rule 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 SWIFT EFT report to FINTRAC. These reports can only be sent electronically, by batch, as explained in section 4.
If you are a financial entity, a money services business or a casino and you received instructions for a transfer of funds from outside Canada, you have to make the related incoming EFT report to FINTRAC, even if you have to forward the same instructions to another financial entity, money service business or casino in Canada. However, if you receive instructions for a transfer of funds from outside Canada from another financial entity, money services business or casino in Canada, you do not have to make an incoming EFT report, as long as the EFT contained the name and address of the beneficiary. If the EFT did not contain the name and address of the beneficiary and the original sender was outside Canada, you also have to make an incoming EFT report. This is true even if you do not get a copy of the instructions received by the other financial entity, money services business or casino.
See Appendix 2 for example scenarios of this type of situation.
Exception to the 24-hour rule for EFTs
Effective June 30, 2007, 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:
- 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 in the Forms and Publications section of the Canada Revenue Agency's Web site (http://www.cra-arc.gc.ca).
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 Backgrounder issued with a July 2, 2008 news release available in the Media Room's news releases on the Department of Finance's Web site (http://www.fin.gc.ca).
3.4 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 noon 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 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 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 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.
3.5 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.
Originator information to include with transfers
Effective June 23, 2008, if you send or receive an EFT of any amount, at the request of a client, there are new obligations about originator information included with the transfer. For more details about this, see 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 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 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 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:
- Guideline 1: Backgrounder
- Guideline 5: Submitting Terrorist Property Reports to FINTRAC
3.6 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. In the case of an incoming EFT, the day of the transfer means the day the instructions were sent to you. In the case of an outgoing EFT, it means the day you transmit the instructions regarding the transfer of funds.
4. Electronic Reporting
4.1 SWIFT EFT Reporting
SWIFT EFT reports can only be sent to FINTRAC electronically, by batch. These reports cannot be made on paper.
4.2 How to Complete Electronic Reports
To use the batch file reporting mechanism, you need a public key infrastructure (PKI) certificate and specialized software available from FINTRAC. For more information about batch reporting SWIFT EFTs, consult the specifications document called SWIFT Batch Reporting Instructions and Specification. This document is available from technical documentation on the publications page of FINTRAC's Web site (http://www.fintrac-canafe.gc.ca). Also refer to the Appendix 1 of this guideline for instructions and details regarding the content of a SWIFT EFT report.
For more information about batch reporting, including how to get a PKI certificate and the specialized software required, refer to the reporting area of FINTRAC's Web site (http://www.fintrac-canafe.gc.ca).
4.3 Acknowledgement of Receipt of an Electronic Report
FINTRAC will send you an acknowledgement message when your EFT report has been received electronically. This will include the date and time your report was received and the identification number for your report. Please keep this information for your records.
For SWIFT EFT reports, 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.
4.4 Report Corrections
If your EFT report contains incomplete information, FINTRAC may notify you. The notification will indicate the date and time your report was received, the 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. Your obligation to report will not be fulfilled until you send the complete report to FINTRAC.
For more information about this, refer to the SWIFT Batch Reporting Instructions and Specification.
5. Instructions for Completing a SWIFT Electronic Funds Transfer Report
5.1 General Instructions
The contents of a SWIFT EFT report depend on whether the report is about an outgoing or incoming transfer. The required information for each type of report is listed in Appendices 1A and B, as follows:
- Outgoing International SWIFT EFT Report (see Appendix 1A)
- Incoming International SWIFT EFT Report (see Appendix 1B)
Based on the reporting requirements for SWIFT EFT reports, information is either mandatory, mandatory where applicable, or requires "reasonable efforts", as follows:
- Mandatory: This information has to be provided.
- Mandatory where applicable: This information has to be provided if it is applicable to you or the transaction being reported.
- Reasonable efforts: For all other information required, you have to make reasonable efforts to get the information. "Reasonable efforts" means that you tried to get the information required in the report. If the information is available to you, you must provide it in the report. If the information was not available at the time of the transaction, and it is not contained in your files or records, the relevant field(s) may be left blank.
The specifications for SWIFT EFT reports do not reflect the mandatory, mandatory where applicable and reasonable efforts fields in the same manner as your other reports to FINTRAC. The SWIFT EFT report specifications reflect "tags" according to the way information is entered to transmit the EFT message based on the SWIFT network rules. In some cases, those rules can be different from what is required in your report to FINTRAC.
Here are some examples to illustrate this point:
Example 1
If there is an intermediary institution for a SWIFT EFT, your report to FINTRAC must contain either the bank identification code (BIC) or the full name and full address of the intermediary. This information is mandatory, if applicable.
In the SWIFT network rules, intermediary information (tag :56:) is optional. Furthermore, for those messages that do involve an intermediary, the SWIFT network rules provide three options regarding information to be included. However, only two of those options (option A or D) provide the mandatory information for your report to FINTRAC. The other (option C) provides neither the BIC nor the full name and address. This means that a SWIFT EFT message with option C at tag :56: does not provide the mandatory if applicable information for your report to FINTRAC, even if it meets the SWIFT network rules.
Example 2
For your report to FINTRAC, the bank operation code is information that requires reasonable efforts. However, based on the SWIFT network rules, the bank operation code (tag :23B:) is required. This means that you should be providing this information in your report to FINTRAC, because it should be available to you.
For these reasons, tags in the SWIFT EFT report do not use asterisks to demonstrate mandatory fields. The instructions for each tag in the report explain which information is mandatory or mandatory where applicable and which requires reasonable efforts.
If information for a tag that requires reasonable efforts is not available for a particular SWIFT EFT, omit that tag from the report. If a tag with mandatory where applicable information does not apply to the EFT being reported, also omit that tag from the report. In all other cases, you have to provide the tag and the information required. Under no circumstances in a SWIFT EFT report should you indicate that a required tag in a report is not applicable.
As explained in subsection 3.3, 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, some of the information that is mandatory for the report may not be available in your records or from the time of the transaction. In this case, "reasonable efforts" applies to this otherwise mandatory information.
You have to complete a separate EFT report for each EFT transaction, even if you are reporting multiple EFTs of less than $10,000.
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@fintrac-canafe.gc.ca.
7. 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-canafe.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
