FINTRAC Issues Ministerial Directive on Reporting Large Virtual Currency Transactions
New Requirements for Financial Institutions
The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) has issued a Ministerial Directive requiring financial institutions to report large virtual currency transactions. Effective immediately, financial institutions are required to report any virtual currency transactions received in an amount equivalent to $10,000 CAD or more using the Large Virtual Currency Transaction Report.
Reporting Suspicious Transactions
The directive also requires that all negotiable instruments and issuing or redeeming transactions originating from or bound for Iran be reported using the Reporting Suspicious Transactions to FINTRAC form. To identify these transactions, a report reference number must include the prefix “IR2020” before the reporting entity’s report reference number.
- For example: if the reporting entity’s report reference number is ABCD1234, it would become IR2020ABCD1234.
- The same prefix must also be inserted into the G section of the suspicious transaction report.
High-Risk Transactions
The directive applies to all transactions associated with Iran, which are considered high-risk and require monitoring for potential money laundering or terrorist financing offenses. Attempted transactions that do not meet the reasonable grounds to suspect threshold must still be reported if they involve a listed person or terrorist group.
- Financial institutions are required to report any property in their possession or control that is owned or controlled by or on behalf of a listed person or terrorist group using the Reporting Terrorist Property to FINTRAC form.
- This includes information about any transaction or proposed transaction relating to that property.
Reporting Timeframes
The reporting timeframes for these transactions vary depending on the type of transaction:
- Electronic funds transfers must be reported within 5 working days.
- Large cash transactions must be reported within 15 days.
Compliance Requirements
Financial institutions are advised to review their compliance programs and procedures to ensure they are meeting the requirements of the Ministerial Directive. Failure to comply with the directive could result in serious consequences, including administrative monetary penalties.
Accessing the Full Text of the Directive
The full text of the Ministerial Directive can be found on FINTRAC’s website at www.fintrac-canafe.gc.ca.