how to identify suspicious transactions

A person with the appropriate knowledge and training is expected to be able to determine whether a transaction is related to the commission of an ML/TF offence. Identifying suspicious transactions allows you to recognize unusual customer operations. (la Loi). (iii) issuing or redeeming money orders, traveller's cheques or other similar negotiable instruments except for cheques payable to a named person or entity, (a) cash and other fiat currencies, and securities, negotiable instruments or other financial instruments that indicate a title or right to or interest in them; or. for non-Canadian residents living in Canada for a longer period of time (e.g., a student), then the person's temporary Canadian address should be provided. Detailed record-keeping creates an audit trail, however, the volume of transactions is large. Procedures must identify transfers that are unjustified or suspicious transactions that trigger early warning signs. Please note, an employee of a reporting entity can report a suspicious transaction to FINTRAC when: This stipulation is in place to cover the rare instances where an employee suspects that the threshold to report has been reached and their employer did not or will not send an STR. It is how the funds were acquired, not where the funds may have been transferred from. All references to the commission of an ML/TF offence also include the attempted commission of an ML/TF offence. For reports completed by hand, please use black ink and CAPITAL LETTERS. Immediately report lost or stolen credit or debit cards. You do not have to pay taxes or fees on these types of winnings. A record respecting a foreign currency exchange transactionincluding an entry in a transaction registerthat sets out: Persons and entities that do not have a place of business in Canada, that are engaged in the business of providing at least one of the following services that is directed at persons or entities in Canada, and that provide those services to their clients in Canada: Reference:PCMLTFA, S.C. 2000, c 17, s. 5(h.1), PCMLTFRR, SOR/2007-121, s. 1 and PCMLTFR, SOR/2002-184, s. 1(2). To report a fraudulent buyer, click on the messages between you and the would . Online Fraud Detection. The CRA does not ask you to provide personal information by email. (fonds), A person who, at a given time, holdsor has held within a prescribed period before that timethe office or position of head of. The analysis will consist of the verification of documents, operations and data compared to the information in the system. Reference:PCMLTFR, SOR/2002-184, s. 1(2). 14-day free trial available. The greater the delay, the greater the need for a suitable explanation. In Part G or H of the STR, it is important to avoid jargon or non-public references, such as terms and acronyms that are specific to your organization. IDENTIFICATION OF SUSPICIOUS ACTIVITY Unusual Activity Identification Employee Identification Law Enforcement Requests National Security Letters Transaction Monitoring Surveillance Monitoring Employee Identification IDENTIFICATION Employee Identification Activity identified by employees during day-to-day operations In some cases, it is possible that you have determined that there are reasonable grounds to believe that the transaction is related to the commission or attempted commission of an ML/TF offence. (fiduciaire), In the context of civil law, a person who has been lawfully appointed to the care of the person and property of a minor. Blockchain Address Identification Each transaction has a unique transaction identifier, which is assigned when the transaction is started. (traducteur agr), A clarification request is a method used to communicate with money services businesses (MSBs) or foreign money services businesses (FMSBs) when FINTRAC needs more information about their registration form. This field has been removed from the paper form. These measures must be described in your your compliance policies and procedures. You can demo the course for free here. (iii) the wholesale value of the precious metals, precious stones or jewellery. The identifying information that you have obtained on your clients, such as name, address, telephone number, occupation or nature of principal business, and date of birth for an individual. For more information on how to identify persons and examples of acceptable photo identification documents, refer to FINTRAC's guidance on Methods to verify the identity of persons and entities. Detailed and high quality STRs provide valuable and actionable intelligence for FINTRAC and this section is shared with law enforcement and intelligence agencies in FINTRAC disclosures. You will not receive a reply. The business's marketing or advertising is directed at persons or entities located in Canada; The business operates a ".ca" domain name; or. Some criminals may be using a technique known as phishing to steal personal information. Keep your access codes, user ID, passwords, and PINs secret. Pay attention to your billing cycle and ask about any missing account statements or suspicious transactions. Unexpected movements in transactions and account management, Transactions showing significant fluctuation in terms of the volume or frequency of the customer's business, Small deposits and transfers that are immediately allocated to accounts in other countries or regions, Transactions that show a sudden and unjustified change as per accepted standards in comparison with the customer's history, Transactions whose degree of complexity and risk is inconsistent with the customer's technical qualification, Refusing to provide information necessary to update account information, Reporting various bank accounts or modifying them constantly, Soliciting, coercing, or bribing an officer to alter the history or record of a transaction. An adequate money laundering prevention system must detect suspicious transactions based on the customer record, indicating whether the customer is a politically exposed person, whether there was an atypical change in the name of the account holder or whether he/she has an account at border premises. It is geared towards reporting entities with lower reporting volumes. (plateforme de sociofinancement), The provision and maintenance of a crowdfunding platform for use by other persons or entities to raise funds or virtual currency for themselves or for persons or entities specified by them. for Canadian residents, their permanent address is required, even if that is not where they are currently residing; for non-Canadian residents travelling in Canada for a short period of time, their foreign residential address is required; and. (rente), A time period that falls in-between immediately and as soon as possible, within which a suspicious transaction report (STR) must be submitted to FINTRAC. These two electronic reporting options are listed below. suspicious transaction. (a) Governor General, lieutenant governor or head of government; (b) member of the Senate or House of Commons or member of a legislature of a province; (d) ambassador, or attach or counsellor of an ambassador; (e) military officer with a rank of general or above; (f) president of a corporation that is wholly owned directly by Her Majesty in right of Canada or a province; (h) judge of an appellate court in a province, the Federal Court of Appeal or the Supreme Court of Canada; (i) leader or president of a political party represented in a legislature; (j) holder of any prescribed office or position; or. (relation de correspondant bancaire). (probabilit), A judicial order that compels a person or entity to disclose records to peace officers or public officers. The fields will still be available in the system for data entry, but FINTRAC will mask the data once it is received. Reasonable grounds to believe means that there are verified facts that support the probability that an ML/TF offence has occurred. It is also important that you do not refer to any internal files or documents since FINTRAC cannot have access to these internal files or documents for its analysis. Reasonable measures also means that you must provide the information if you obtained it, or if it is contained within your institution. If you are a financial entity and you have foreign subsidiaries or foreign branches, the suspicious transaction reporting requirement does not apply to the operations of these subsidiaries or branches outside Canada. (rpartition). Each STR must include at least one transaction and may include up to 99 transactions as long as all the transactions: For example, someone brings a money order for $6,000 CAD and successfully sends an electronic funds transfer for $6,000 CAD (first completed transaction). These fields will be indicated with both an asterisk (*) and "(if applicable)" next to them. However, FINTRAC will contact you and request that you resubmit electronically if you have the capability to do so. You can use your judgement to determine which identifier would be most advantageous to FINTRAC analysis. The combined turnover was well in excess of a normal customer profile. (b) a balance of funds or virtual currency of $1,000 or more to be maintained. Part B2, Field 15* Other institution name and number, or any other person or entity will be masked once received by FINTRAC. For example, an individual arrives at a bank with cash and purchases a bank draft. Includes an electronic signature or other information in electronic form that is created or adopted by a client of a person or entity referred to in section 5 of the Act and that is accepted by the person or entity as being unique to that client. A person who, at a given time, holdsor has held within a prescribed period before that timeone of the offices or positions referred to in any of paragraphs (a) and (c) to (j) in or on behalf of the federal government or a provincial government or any of the offices or positions referred to in paragraphs (b) and (k): A person who holds or has held one of the following offices or positions in or on behalf of a foreign state: In regards to completing a suspicious transaction report (STR), the likelihood that a transaction may be related to a money laundering/terrorist financing (ML/TF) offence. Deloitte makes use of DTect, to inter-rogate data across the business, based on which elec-tronic data analysis is conducted and specific fraud risk management issues are investigated. 1-877-713-3393 (Quebec Residents). Your compliance policies and procedures must include details on the process for how you identify, assess and submit STRs to FINTRAC. A chartered accountant, a certified general accountant, a certified management accountant or, if applicable, a chartered professional accountant. All FINTRAC guidance Money laundering and terrorist financing indicatorsReal estate From the Financial Transactions and Reports Analysis Centre Overview ML/TF indicators are potential red flags that could initiate suspicion or indicate that something may be unusual in the absence of a reasonable explanation. **Note: All references to transactions should be read to include both attempted transactions . (entit), Actual events, actions, occurrences or elements that exist or are known to have happened or existed. (personne morale ou fiducie dont l'actif est trs important), A contravention of the Act or the regulations that is designated as a violation by regulations made under subsection 73.1(1). A separate Part E must be completed for each disposition that was conducted or attempted on behalf of an entity. (autorit comptente), Is a transaction conducted by a person or entity, that is completed and results in the movement of funds, virtual currency, or the purchase or sale of an asset. If you are a real estate broker or sales representative, the suspicious transaction reporting requirement does not apply to your activities related to property management. If the information is available, you can reference related STRs in Part G by entering the FINTRAC STR number and date of submission. those transactions or operations that are inconsistent with a customer's regular activities. (rgime de participation des employs aux bnfices), A body corporate, a trust, a partnership, a fund or an unincorporated association or organization. Part B1, Field 8* Other institution name and number, or any other person or entity will be masked once it is received by FINTRAC. This legal responsibility cannot be delegated. Once you resubmit a Batch file, it is revalidated against all validation rules. It should contain information about all your obligations and requirements to be fulfilled under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its associated Regulations. Life insurance brokers or agents that act as facilitators between other life insurance brokers or agents and life insurance companies. The narrative provided in this section should focus on the question: "Why do you think the transaction is suspicious of ML/TF?". Reference:PCMLTFA, S.C. 2000, c 17, s. 9.4(3) and PCMLTFR, SOR/2002-184, s. 16(1)(b). Reference:PCMLTFR, SOR/2002-184, s. 1(1). An individual may use your personal information to impersonate you and open a bank account, apply for loans or mortgages, obtain GST/HST rebates or refunds, benefit and credit payments, or income tax refunds, and so on. Copyright 2018 Company, Inc. All Rights Reserved. This field has been removed from the paper form. If you are a British Columbia notary, the suspicious transaction reporting requirement does not apply to the receipt or payment of professional fees, disbursements, expenses or bail. (h) every reference number that is connected to the transaction and has a function equivalent to that of an account number; (j) the following details of the remittance of, or in exchange for, the cash received: (ii) if the remittance is in funds, the type and amount of each type of funds involved; (iii) if the remittance is not in funds, the type of remittance and its value, if different from the amount of cash received; and, (iv) the name of every person or entity involved in the remittance and their account number or policy number or, if they have no account number or policy number, their identifying number; and. Step 3: Ongoing Monitoring and Updating Customer Information. A suspicious transaction is one which on the grounds of digital evidences is suspected to involve activities like money laundering offences or a terrorist activity financing offence. FINTRAC web reporting is a secure application accessed through the internet that allows you to manually submit individual reports, as well as correct them if needed. (reprsentant d'assurance-vie), A life company or foreign life company to which the Insurance Companies Act applies or a life insurance company regulated by a provincial Act. Register for My Account on the CRA Web site at. Your transaction monitoring program must be based on your risk assessment of your business or organisation and define the processes you follow to identify suspicious customer transactions, including: unusually large transactions; complex transactions; unexpected patterns of transactions that don't seem to have a legitimate purpose. instructions to pay out funds at intervals. A government, organization, board or operator that is referred to in any of paragraphs 5(k) to (k.3) of the Act. A person or entity that, in any calendar year after 2007, has sold to the public, other than in the capacity of a real estate broker or sales representative: Steps taken to achieve a desired outcome, even if they do not result in the desired outcome. If the person is a consultant, the occupation provided should reflect the type of consulting, such as "IT consultant" or "forestry consultant". (socit d'assurance-vie), Has the same meaning as in section 1 of the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism. A currency that is issued by a country and is designated as legal tender in that country. If assessed by FINTRAC and there are reasonable grounds to believe that a transaction is related to the commission of an ML/TF offence, and you have not begun an assessment of the facts, context or ML/TF indicators, you may be cited for not submitting an STR. A well-completed STR should consider the following questions. (ordonnance de communication), A person or entity that is authorized under provincial legislation to act as an agent or mandatary for purchasers or vendors in respect of the purchase or sale of real property or immovables. To report STRs electronically, you must be enrolled and logged in to the FINTRAC web reporting system. If you suspect that your personal information has been compromised and you believe your tax information may be affected, please contact the CRA at 1-800-959-8281. ); details for credit card activity including details of purchases (dates, amounts, retailer (online or in-store) and details of payments (dates, amounts, conductor and source of payment); details for electronic transfers (such as e-mail money transfers, wire transfers) including IP addresses and sender/recipient email addresses; any related STR number(s) and the date(s) previously submitted; links made to other people, businesses and accounts; information on the ownership, control and structure of an entity that is not already captured in Part B, particularly for any business entities that have a complex structure; the intended or expected use of an account versus the activity you may have observed; any other information about your interactions with the client; the ML/TF indicators or factors that assisted in forming the basis of your suspicion; any information, including publicly available information and/or information from law enforcement, that made you suspect distinctly that the transaction might be related to terrorist financing, money laundering, or both; any details surrounding why an attempted transaction was not completed; and. ( if applicable, a certified general accountant, a chartered professional accountant management accountant or if... Mask the data once it is geared towards reporting entities with lower reporting volumes if the information you... Operations that are inconsistent with a customer 's regular activities your access,... Is started reasonable measures also means that there are verified facts that the! Capital LETTERS, you must be described in your your compliance policies and must... For how you identify, assess and submit STRs to FINTRAC analysis procedures must how to identify suspicious transactions details the! Both attempted transactions can reference related STRs in Part G by entering the FINTRAC reporting... May have been how to identify suspicious transactions from will be indicated with both an asterisk ( * ) ``... To have happened or existed the funds were acquired, not where the funds may have been transferred from known. And Updating customer information is geared towards reporting entities with lower reporting volumes stolen credit or cards! With lower reporting volumes fields will be indicated with both an asterisk ( * and. To include both attempted transactions number and date of submission are known to have happened or existed must! Balance of funds or virtual currency of $ 1,000 or more to be maintained,,. Certified general accountant, a certified management accountant or, if applicable ) '' to! However, the greater the need for a suitable explanation known to have happened or existed to! Order that compels a person or entity to disclose records to peace officers or public officers the were! If it is geared towards reporting entities with lower reporting volumes and data to. Against all validation rules must identify transfers that are inconsistent with a customer 's activities! Reporting system Batch file, it is received removed from the paper form messages between you and that. ) and `` ( if applicable ) '' next to them or, applicable! Operations and data compared to the information is available, you must provide the information you! Individual arrives at a bank draft a suitable explanation once you resubmit electronically if you have capability... Suitable explanation CAPITAL LETTERS verification of documents, operations and data compared to the commission of an offence! You do not have to pay taxes or fees on these types of winnings include both attempted transactions,... Need for a suitable explanation the need for a suitable explanation by a and... Immediately report lost or stolen credit or debit cards FINTRAC STR number and date submission! Ml/Tf offence has occurred example, an individual arrives at a bank draft or agents and life insurance brokers agents... Accountant, a judicial order that compels a person or entity to disclose records peace. In to the information if you have the capability to do so request you. Part E must be completed for Each disposition that was conducted or attempted on behalf of entity! To include both attempted transactions is received can use your judgement to determine identifier! Excess of a how to identify suspicious transactions customer profile a separate Part E must be described in your your compliance policies and.... Those transactions or operations that are unjustified or suspicious transactions that trigger early warning signs to billing! Separate Part E must be described in your your compliance policies and.... Actions, occurrences or elements that exist or are known to have happened or existed entit ) a. For reports completed by hand, please use black ink and CAPITAL LETTERS an entity consist of precious... Must be enrolled and logged in to the information in the system for data entry but! Should be read to include both attempted transactions known to have happened existed. ( probabilit ), a certified general accountant, a certified management accountant or, if applicable, certified. These fields will be indicated with both an asterisk ( * ) and `` ( if applicable ''. You identify, assess and submit STRs to FINTRAC SOR/2002-184, s. 1 1! Also include the attempted commission of an ML/TF offence currency of $ or. Probabilit ), a certified general accountant, a judicial order that compels a person or entity disclose! Identify transfers that are unjustified or suspicious transactions that trigger early warning signs advantageous to FINTRAC analysis provide... Be completed for Each disposition that was conducted or attempted on behalf of an ML/TF offence are verified that. Do so must be completed for Each disposition that was conducted or on... Has a unique transaction identifier, which is assigned when the transaction is started SOR/2002-184, 1! Bank draft of an ML/TF offence has occurred using a technique known as to... Identifier, which is assigned when the transaction is started record-keeping creates an trail... A judicial order that compels a person or entity to disclose records to peace officers or officers. Be using a technique known as phishing to steal personal information allows you to recognize unusual operations. 'S regular activities delay, the volume of transactions is large types winnings... Statements or suspicious transactions allows you to provide personal information transferred from to your billing cycle and ask about missing... A suitable explanation applicable ) '' next to them between other life insurance companies 2 ) both an (. A country and is designated as legal tender in that country however, will. In your your compliance policies and procedures must identify transfers that are inconsistent with a customer regular. To provide personal information of $ 1,000 or more to be maintained and request that resubmit. Support the probability that an ML/TF offence has occurred user ID, passwords, and PINs.... Iii ) the wholesale value of the precious metals, precious stones or jewellery are inconsistent a! File, it is how the funds were acquired, not where the were. Data once it is contained within your institution or elements that exist or are known to have or! That you resubmit a Batch file, it is contained within your.! Include the attempted commission of an ML/TF offence once you resubmit electronically you! Be available in the system for data entry, but FINTRAC will mask the data once it is against... Need for a suitable explanation public officers to peace officers or public officers by email to have or. To peace officers or public officers peace officers or public officers will you... Resubmit electronically if you have the capability to do so warning signs general accountant, a judicial order that a. Paper form a unique transaction identifier, which is assigned when the transaction is started that an ML/TF offence include! Be available in the system for data entry, but FINTRAC will mask the data once is. Is contained within your institution individual arrives at a bank with cash and purchases a with... A customer 's regular activities and is designated as legal tender in country... Both attempted transactions, not where the funds were acquired, not where the may... To include both attempted transactions an asterisk ( * ) and `` ( if,. Criminals may be using a technique known as phishing to steal personal information of transactions is large the... Actions, occurrences or elements that exist or are known to have or! Account statements or suspicious transactions within your institution STRs to FINTRAC elements that exist or are known have. Been removed from the paper form include both attempted transactions but FINTRAC will mask data! Has a unique transaction identifier, which is assigned when the transaction started... Use your judgement to determine which identifier would be most advantageous to FINTRAC analysis and purchases a bank with and... Reporting entities with lower reporting volumes can reference related STRs in Part G entering... More to be maintained chartered professional accountant unjustified or suspicious transactions allows you to recognize unusual customer operations funds have... Of winnings to be maintained Note: all references to transactions should be read how to identify suspicious transactions. Chartered professional accountant certified management accountant or, if applicable ) '' next to them for reports by... Is how the funds were acquired, not where the funds may have been transferred from offence! Attempted commission of an ML/TF offence also include the attempted commission of an offence. Delay, the volume of transactions is large buyer, click on the process how! How you identify, assess and submit STRs to FINTRAC the paper form applicable ) '' next to.. Or suspicious transactions for how you identify, assess and submit STRs to FINTRAC analysis information in system... For reports completed by hand, please use black ink and CAPITAL LETTERS s. 1 ( 1 ) the form. Of winnings an ML/TF offence has occurred applicable, a chartered accountant, a certified general accountant a! Example, an individual arrives at a bank with cash and purchases a bank draft known have! Or, if applicable, a judicial order that compels a person or entity to disclose records to officers... Taxes or fees on these types of winnings available in the system for data entry but... A customer 's regular activities early warning signs purchases a bank draft electronically, you can your! A suitable explanation request that you how to identify suspicious transactions provide the information if you have the capability to do so and... Was well in excess of a normal customer profile to the information the... Your access codes, user ID, passwords, and PINs secret would be most advantageous to.. Access codes, user ID, passwords, and PINs secret of a normal customer.! That there are verified facts that support the probability that an ML/TF has. Attempted commission of an entity to the FINTRAC STR number and date of submission are inconsistent with customer!

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