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FINTRAC Reporting Obligations: When and How to file STRs, LCTRs, LVCTRs, LPEPRs, and Sanctions Evasion

Timely and effective compliance starts with understanding your reporting obligations. This article outlines the key FINTRAC reports for Dealers in Precious Metals and Precious Stones (DPMS) including reporting thresholds, timelines and submission methods.

Applicable Reports for DPMS

  • Suspicious Transaction Reports (STR)
    • A suspicious transaction report is a type of report that you must submit to FINTRAC when a financial transaction occurs, or is attempted, in the course of your activities and there are reasonable grounds to suspect that the transaction is related to the commission or the attempted commission of a money laundering or terrorist activity financing offence.
    • There is no monetary threshold for submitting a STR.
    • Must be submitted “as soon as practicable.”
  • Large Cash Transaction Reports (LCTR) 
    • A large cash transaction occurs when you receive CAD $10,000 or more in cash in a single transaction.
    • You must also submit a Large Cash Transaction Report to FINTRAC in accordance with the 24-hour rule (this means you receive 2 or more amounts in cash that total $10,000 or more within a consecutive 24-hour window from the same customer)
    • Third party rule: There are requirements to determine whether a person or entity is acting on behalf of another person or entity for the receipt of a large cash transaction.
    • Must be submitted within 15 calendar days after the day on which the cash is received.
  • Large Virtual Currency Transaction Reports (LVCTR)
    • A large virtual currency transaction occurs when you receive virtual currency in an amount equivalent to $10,000 or more in a single transaction.
    • You must also submit a Large Virtual Currency Transaction Report to FINTRAC in accordance with the 24-hour rule (this means you receive 2 or more amounts in virtual currency that total $10,000 or more within a consecutive 24-hour window from the same customer)
    • Third party rule: There are requirements to determine whether a person or entity is acting on behalf of another person or entity for the receipt of a large virtual currency transaction.
    • Must be submitted within 5 working days after the day on which you receive the amount.
  • Listed Person or Entity Property Reports (LPEPR)  You must use the paper form to submit the LPEPR report.
    • Formally referred to as the Terrorist Property Report (TPR)
    • You must submit Listed Person or Entity Property Reports to FINTRAC by fax if you have the technical capability to do so. If you do not have the capability to submit it by fax, you must send the report by mail.
    • You must submit a Listed Person or Entity Property Report to FINTRAC immediately
  • Sanctions Evasion
    • Where there are reasonable grounds to suspect sanctions evasion by someone acting on behalf of a sanctioned person, then you must report these transactions on FINTRAC’s Suspicious Transaction Reports.

Reports should be submitted electronically when possible:

 

Electronic Submission Methods

FINTRAC’s Web Reporting System allows two ways to submit electronic reports:

  • FINTRAC Web Reporting (FWR): is a secure online portal for lower reporting volumes. The FWR reporting portal allows users to submit individual STRs, LCTRs, LVCTRs, LPEPRs and C reports.
  • FINTRAC API Reporting: Organizations with higher reporting volumes may use FINTRAC’s API link for secure, system-to-system transfer of report information to FINTRAC.

Each report has a reporting timeline, and missing a deadline can result in Administrative Monetary Penalties. You can use FWR Web Reporting or API to send reports to FINTRAC. FINTRAC reports should be filed electronically, when possible.

Registering for FINTRAC Reporting

If your business is not registered with the FINTRAC reporting system, you can enroll new accounts by contacting FINTRAC at: F2R@fintrac-canafe.gc.ca.

FINTRAC FWR Web Reporting System

Questions?

If you need any assistance or have questions, email: info@outliercanada.com