Guideline 9: Alternative to Large Cash Transaction Reports to FINTRAC

Appendix 3: Can Your Client be Considered for the Alternative to Large Cash Transaction Reports?

The following nine questions, if answered in order, will help you determine whether or not a particular business of a corporation can be considered for the alternative to large cash transaction reports. The first three questions are about the corporation, and the rest are about the business. If you get to question 4 for a corporation that has more than one business, go through questions 4 to 9 to get a distinct answer for each business that you wish to consider.

For more information about the conditions, see section 2 of this guideline.

  1. Is the client a corporation?
    • If the answer is yes, continue to question 2.
    • If the answer is no, the client cannot be considered for the alternative to large cash transaction reports.

     
  2. Is any of the corporation's business related to pawnbroking?
    • If the answer is yes, the client cannot be considered for the alternative to large cash transaction reports.
    • If the answer is no, continue to question 3.

     
  3. Is the corporation's principal business the sale of vehicles, vessels, farm machinery, aircraft, mobile homes, jewellery, precious gems or metals, antiquities or art?
    • If the answer is yes, the client cannot be considered for the alternative to large cash transaction reports.
    • If the answer is no, continue to question 4.

     
  4. Is the corporation's business a business type that can be considered for purposes of the alternative to large cash transaction reports (see Appendix 1)?
    • If the answer is yes, continue to question 5.
    • If the answer is no, the client cannot be considered for the alternative to large cash transaction reports.

     
  5. Has the client had an account with you for the business for at least 24 months?
    • If the answer is yes, skip question 6 and continue to question 7.
    • If the answer is no, continue to question 6.

     
  6. Did the client have an account for the business with another financial entity for at least 24 months immediately before opening an account with you? (Answer this question only if you answered no to question 5.)
    • If the answer is yes, continue to question 7.
    • If the answer is no, the client cannot be considered for the alternative to large cash transaction reports.

     
  7. Do you have records that show that, in the preceding 12 months, the client deposited $10,000 or more in cash, on an annual average of at least twice a week, into the account referred to in question 5 or question 6?
    • If the answer is yes, continue to question 8.
    • If the answer is no, the client cannot be considered for the alternative to large cash transaction reports.

     
  8. Were the cash deposits of this business consistent with the business' usual practices?
    • If the answer is yes, continue to question 9.
    • If the answer is no, the client cannot be considered for the alternative to large cash transaction reports.

     
  9. Have you taken reasonable measures to determine the source of cash for those deposits?
    • If yes, you may choose the alternative to large cash transaction reports for this business.
    • If no, the client's business cannot be considered for the alternative to large cash transaction reports.