As of today, businesses subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) must report transactions suspected to be related to sanctions evasion to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). This is in addition to longstanding obligations to report transactions where there are reasonable grounds to suspect that they are related to money laundering and terrorist activity financing offences.
FINTRAC updated the following guidance to provide details on how to report suspected sanctions evasion in a Suspicious Transaction Report: Reporting suspicious transactions to FINTRAC.
It includes new values for suspicion type in the Suspicious Transaction Report form, such as:
- sanctions evasion
- money laundering and sanctions evasion
- terrorist financing and sanctions evasion
- money laundering, terrorist financing and sanctions evasion
If businesses don’t have the system capability at this time to select “sanctions evasion” as the primary suspicion type, they must select “money laundering” and add #SANCTIONS in the “Description of suspicious activity” section.
As a reminder, additional resources on sanctions evasion are available on FINTRAC’s website:
- Report suspected sanctions evasion
- Special Bulletin on financial activity associated with suspected sanctions evasion
- Joint financial intelligence advisory: illegal procurement of dual-use goods by Russian end-users
For questions, please contact FINTRAC by telephone at 1-866-346-8722 (toll-free) or by email at guidelines-lignesdirectrices@
