Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC

Appendix 3: Scenarios for Incoming SWIFT EFT Reports Involving Another Reporting Entity

It can happen that a financial entity or a money services business receives a SWIFT message for a transfer of funds from outside of Canada to a beneficiary in Canada, but has to send the transfer to another reporting entity in Canada that also has to report EFTs. If the message does not include the name and address of the beneficiary, both reporting entities will have to report the EFT to FINTRAC.

EXAMPLE

A European bank, at the request of an individual client in Europe, sends an EFT of $12,000 to be paid to an individual in Canada through a particular money services business (MSB). The European bank sends it through the SWIFT network to a financial entity in Canada, with instructions for payment to a client of the MSB.

For the purposes of this example, neither the client ordering the EFT in Europe nor the beneficiary of the EFT in Canada is acting on behalf of a third party.

Even if the ultimate beneficiary is a client of the MSB, the financial entity must report to FINTRAC, as it is the first to receive the EFT in Canada. Depending on whether or not the name and address of the beneficiary was included in the EFT, the MSB may also have to report to FINTRAC, as explained in the following scenarios.

SCENARIO 1

The EFT contains the name and address of the MSB's client. In this scenario, the MSB does not report to FINTRAC. The financial entity sends an incoming SWIFT message report to FINTRAC, as follows:

  • Part A is for general information about the transaction. This is provided in Tags:13C:, :32A:, :33B:, :36: and :26T: from the SWIFT message.

  • In Part B, the financial entity must provide FINTRAC with the European bank's client's full name and, if applicable, the client's account number. This is provided in Tag :50: from the SWIFT message.

  • Part C is for information about the European bank sending the EFT. This is provided in Tag :51A: and the application header from the SWIFT message.

  • Part D does not apply to this report because, in this example, the European bank's ordering client is not acting on anyone else's behalf.

  • Parts E to I do not apply, as there are no correspondents, no reimbursement or intermediary institutions, and no beneficiary customer account institution.

  • Part J is for information about the financial entity, as the reporting entity. This is provided in the basic header from the SWIFT message as well as in the FINTRAC header required for each batch report.

  • Part K is for information about the beneficiary to whose benefit the EFT is sent (Tag :59: in the SWIFT message). In this scenario, the financial entity must provide the MSB's client's full name, full address, and, if applicable, the client's account number.

  • Part L is for additional payment information provided in Tags :20:, :23B:, :23E:, :70:, :71A:, :71F:, :71G:, :72:, :77B:, and :77T: from the SWIFT message.

SCENARIO 2

The EFT does not contain the name and address of the MSB's client. In this scenario, both the MSB and the financial entity report the incoming EFT to FINTRAC. The financial entity sends an incoming SWIFT message report and the MSB sends an incoming international non-SWIFT EFT report (EFTI) to FINTRAC.

The following table shows the similarities and differences for the two reports.

Financial entity
Incoming EFTS report		 MSB
EFTI report

General information about the transaction (Tags:13C:, :32A:, :33B:, :36: and :26T: from the SWIFT message)

General information about the transaction (Part A)

The financial entity has to provide FINTRAC with the European bank's client's full name and, if applicable, the client's account number. This is provided in Tag :50: from the SWIFT message.

The MSB has to provide FINTRAC with the European bank's client's full name and, if applicable, the client's account number. In addition, if the information is available at the time of the transaction or in the MSB's records, the MSB has to provide the European bank's client's full address, telephone number, date of birth, occupation, identifier and identifier number. (Part B)

Information about the European bank sending the EFT (Tag :51A: and the application header from the SWIFT message)

Information about the European bank sending the EFT (Part C)

Information about ordering client's third party does not apply to this report because the European bank's ordering client is not acting on anyone else's behalf.

Information about ordering client's third party (Part D) does not apply to this report because the European bank's ordering client is not acting on anyone else's behalf.

Information about the financial entity, as the reporting entity (basic header from the SWIFT message and FINTRAC header required for each batch report)

Information about the MSB, as the reporting entity (Part E)

Information about the beneficiary to whose benefit the EFT is sent (Tag :59: in the SWIFT message) is required. In this scenario, as the financial entity does not have the client's name and address, the MSB's full name, full address, and, if applicable, the MSB's account number are to be included in the report.

Information about the beneficiary to whose benefit the EFT is sent (Part F) is required. In this scenario, the MSB must provide its client's full name and, if applicable, the client's account number.

Information about the beneficiary's third party does not apply to this report.

Information about the beneficiary's third party does not apply to this report because the EFT's beneficiary is not acting on anyone else's behalf (Part G).

Other SWIFT tags may apply according to additional payment information in the SWIFT message for which there is no equivalent in a non-SWIFT report.

Note: The financial entity in the above scenarios has to take reasonable measures to ensure that the EFT includes originator information. For more information about this requirement for both incoming and outgoing EFTs, see Guideline 6: Record Keeping and Client Identification.