Guideline 8C: Submitting Electronic Funds Transfer Reports to FINTRAC by Paper
Appendix 1: Scenarios for EFT Reports Involving Another Reporting Entity
- Scenarios for Outgoing EFT Reports Involving Another Reporting Entity
- Scenarios for Incoming EFT Reports Involving Another Reporting Entity
Appendix 1A: Scenarios for Outgoing EFT Reports Involving Another Reporting Entity
It can happen that a client requests a transfer of funds and, instead of sending the EFT yourself, you order someone else that is a financial entity, a money services business or a casino in Canada to send it. In this case, you have to make the related outgoing EFT report to FINTRAC unless you provide them with the client's name and address. The following example provides two different scenarios to explain how the required reports are to be completed in such cases.
EXAMPLE
A client requests a money services business to send an international EFT of $12,000 from Canada. The money services business does not send the EFT itself, but orders a financial entity in Canada to do so. For the purposes of this example, the financial entity does not send the EFT as a SWIFT member of the SWIFT network. Also for the purposes of this example, neither the client ordering the EFT from the money services business nor the beneficiary of the EFT is acting on behalf of a third party.
SCENARIO 1
The money services business provides the client's name and address to the financial entity. In this scenario, the money services business does not send an outgoing EFT report to FINTRAC. Only the financial entity must report the EFT to FINTRAC, as follows:
- Part A is for general information about the transaction.
- In Part B, the financial entity has to provide FINTRAC with the money services business' full name and full address, along with the rest of the information about the money services business, as the money services business is considered the client of the financial entity in this context.
- Part C is for information about the financial entity, as the reporting entity.
- Part D applies to this report because the money services business is ordering the EFT on a client's behalf. The financial entity will provide the information about the money services business' client, as provided by the money services business.
- Part E is for information about the individual or entity outside Canada who will be receiving the EFT instructions. It is about the bank or other type of financial service provider who will receive the EFT instructions to provide payment to the beneficiary.
- Part F is for information about the beneficiary to whose benefit the EFT is sent.
- Part G does not apply to this report because, in this example, the EFT's beneficiary is not acting on anyone else's behalf. In other words, there is no third party beneficiary.
SCENARIO 2
The money services business does not provide the client's name and address to the financial entity. In this scenario, the money services business and the financial entity must both report the EFT to FINTRAC. The following table shows the similarities and differences for the two reports.
| Money services business' outgoing EFT report | Financial entity's outgoing EFT report | |
|---|---|---|
| Part A | General information about the transaction. | General information about the transaction. |
| Part B | The money services business has to provide FINTRAC with the client's full name and full address, along with the rest of the information about their client. | The financial entity has to provide FINTRAC with information about the money services business, as the money services business is considered the client ordering the EFT from the financial entity in this context. |
| Part C | Information about the money services business, as the reporting entity. | Information about the financial entity, as the reporting entity. |
| Part D | Does not apply to this report because the money services business' client is not ordering the EFT on anyone else's behalf. In other words, there is no third party related to the EFT order. | Does not apply to this report because the money services business is not providing information about their client to the financial entity and the money services business is required to provide that information in their own report to FINTRAC. In other words, there is no third party related to the EFT order. |
| Part E | Information about the individual or entity outside Canada who will be receiving the EFT instructions. This is not about the financial entity that is being ordered to send the EFT. It is about the bank or other type of financial service provider outside Canada who will receive the EFT instructions to provide payment to the beneficiary. | Information about the individual or entity outside Canada who will be receiving the EFT instructions. It is about the bank or other type of financial service provider outside Canada who will receive the EFT instructions to provide payment to the beneficiary. |
| Part F | Information about the beneficiary to whose benefit the EFT is sent. | Information about the beneficiary to whose benefit the EFT is sent. |
| Part G | Does not apply to this report because the beneficiary is not acting on anyone else's behalf. In other words, there is no third party beneficiary. | Does not apply to this report because the EFT's beneficiary is not acting on anyone else's behalf. In other words, there is no third party beneficiary. |
Note: For information about the contents of the financial entity's report if the EFT were sent as a SWIFT message, refer to the scenarios explained in Guideline 8B: Submitting SWIFT Electronic Funds Transfer Reports to FINTRAC.
Appendix 1B: Scenarios for Incoming EFT Reports Involving Another Reporting Entity
If you receive an electronic funds transfer from outside Canada, some of the information required in your report to FINTRAC is provided by the individual or entity sending you the instructions. The following example provides two different scenarios to explain how the required reports are to be completed in such cases.
EXAMPLE
A European funds transfer business, 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 financial entity (to be referred to in this example as Bank 1). The European business does not have a relationship with Bank 1, but does with another financial entity in Canada (to be referred to in this example as Bank 2). The EFT is therefore sent from the European business to Bank 2, for payment to a client of Bank 1.
For the purposes of this example, the EFT is not sent through the SWIFT network. Also 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 Bank 1, Bank 2 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, Bank 1 may also have to report to FINTRAC, as explained in the following scenarios.
SCENARIO 1
The EFT contains the name and address of Bank 1's client. In this scenario, Bank 1 does not report to FINTRAC. Bank 2 reports the incoming EFT to FINTRAC, as follows:
- Part A is for general information about the transaction.
- In Part B, Bank 2 must provide FINTRAC with the European business' 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 Bank 2's records, Bank 2 has to provide the European business' client's full address, telephone number, date of birth, occupation, identifier and identifier number.
- Part C is for information about the European business sending the EFT.
- Part D does not apply to this report because, in this example, the European business' ordering client is not acting on anyone else's behalf. In other words, there is no third party related to the EFT order.
- Part E is for information about Bank 2, as the reporting entity.
- Part F is for information about the beneficiary to whose benefit the EFT is sent. In this scenario, Bank 2 must provide Bank 1's client's full name, full address, and, if applicable, the client's account number. In addition, Bank 2 has to provide the client's telephone number, date of birth, occupation and identifier if any of that information is available at the time of the transaction or in Bank 2's records.
- Part G does not apply to this report because, in this example, the EFT's beneficiary is not acting on anyone else's behalf. In other words, there is no third party beneficiary.
SCENARIO 2
The EFT does not contain the name and address of Bank 1's client. In this scenario, both Bank 1 and Bank 2 report the incoming EFT (EFTI) to FINTRAC, as follows:
The following table shows the similarities and differences for the two reports.
| Bank 2 EFTI report |
Bank 1 EFTI report |
|
|---|---|---|
| Part A | General information about the transaction. | General information about the transaction. |
| Part B | Bank 2 has to provide FINTRAC with the European business' 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 Bank 2's records, Bank 2 has to provide the European business' client's full address, telephone number, date of birth, occupation, identifier and identifier number. | Bank 1 has to provide FINTRAC with the European business' 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 Bank 1's records, Bank 1 has to provide the European business' client's full address, telephone number, date of birth, occupation, identifier and identifier number. |
| Part C | Part C is for information about the European business sending the EFT. | Part C is for information about the European business sending the EFT. |
| Part D | Does not apply to this report because the European business' ordering client is not acting on anyone else's behalf. In other words, there is no third party related to the EFT order. | Does not apply to this report because the European business' ordering client is not acting on anyone else's behalf. In other words, there is no third party related to the EFT order. |
| Part E | Information about Bank 2, as the reporting entity. | Information about Bank 1, as the reporting entity. |
| Part F | Part F is for information about the beneficiary to whose benefit the EFT is sent. In this scenario, Bank 2 must provide Bank 1's full name, and, if applicable, Bank 1's account number. In addition, Bank 2 has to provide Bank 1's full address and telephone number if any of that information is available at the time of the transaction or in Bank 2's records. | Information about the beneficiary to whose benefit the EFT is sent. In this scenario, Bank 2 must provide its client's full name and, if applicable, the client's account number. In addition, Bank 1 has to provide its client's full address and telephone number if any of that information is available at the time of the transaction or in Bank 1's records. |
| Part G | Does not apply to this report because the beneficiary is not acting on anyone else's behalf. In other words, there is no third party beneficiary. | Does not apply to this report because the EFT's beneficiary is not acting on anyone else's behalf. In other words, there is no third party beneficiary. |
Note: Bank 2 in the above scenarios would have 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.