Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile

You are here:

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile (PDF version, 314 kb)
Reference number: 2021-SIRA-001June 2021
In February 2021, the Government of Canada added four ideologically motivated violent extremism (IMVE) organizations to the Criminal Code list of terrorist entities. Reporting entities should be aware of these new listings, as well as observed patterns in the financing behaviour of IMVE threat actors.Footnote 1
The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) continues to support reporting entities by producing strategic intelligence products, which provide analytical perspectives on the nature, scope and threats posed by money laundering and terrorism financing. To that end, this Special Bulletin presents the results of FINTRAC’s analysis of IMVE-related transaction reporting, supplemented by information from media reports and academic research.
Introduction
IMVE in Canada is driven by a range of grievances that transcend the traditional left–right ideological spectrum. IMVE is also distinct from religiously motivated violent extremism (RMVE) and politically motivated violent extremism (PMVE). The Canadian Security Intelligence Service has divided the violence carried out by threat actors associated with IMVE in Canada into four categories:

xenophobic violence: racially or ethnically motivated violence based on fear or hatred of what is perceived to be foreign, strange or different;
anti-authoritarian violence: violence against the authority of state and law-enforcement entities;
gender-driven violence: violence motivated by hatred of those with a different gender or sexual orientation; and
other grievance-driven and ideologically motivated violence: violence committed by individuals with no clear association with an organized group or any external guidance.

The terrorism threats posed by IMVE threat actors are on the rise around the world. According to a 2020 Trends Alert report published by the United Nations Counter-Terrorism Committee Executive Directorate, there has been a significant rise in terrorist attacks with links to extreme right-wing movements and ideologiesFootnote 3 over the last five years.
In 2019, Blood and Honour and its armed branch, Combat 18, were the first two IMVE-related organizations to be included on the Criminal Code list of terrorist entities. In February 2021, the Government of Canada added four IMVE organizations to this list: Proud Boys, Atomwaffen Division, The Base and Russian Imperial Movement.
Violence in Canada that was motivated in whole or in part by IMVE has tended to take the form of spontaneous arsons, assaults and homicides. Targets include people of the Islamic and Jewish faiths, people of colour, women, Indigenous peoples and members of LGBTQ2 communities. Examples of recent IMVE attacks in Canada include the Quebec City mosque attack in 2017, the Toronto van attack in 2018 and the Toronto spa attack in 2020. This last instance saw, for the first time in Canada, terrorism charges brought against an individual associated with an IMVE ideology.
IMVE threat actors in Canada thrive online as the Internet allows these actors to connect anonymously across borders. IMVE threat actors in Canada use the Internet to make targeted calls for attacking equity-deserving groups offline, and to perpetuate racist and misogynistic tropes on social media that feed into broader narratives associated with conspiracy theories and anti-government movements.
Lone actors in the global IMVE context—those who, by themselves, carry out or attempt to carry out violent attacks in their home country or travel to possibly take part in violent activities elsewhere—raise their own funds, using their savings, employment income or money from family and friends.
Internationally, IMVE threat actors have raised funds through commercial activities, such as selling merchandise, holding events such as talks and concerts, crowdfunding, charging membership fees and accepting donations. IMVE threat actors have also been known to turn to drug trafficking, weapons trafficking and robberies to fund their operations. IMVE threat actors use the funds raised to recruit new members, engage in day-to-day activities and carry out promotional efforts such as making videos. In addition, the funds go toward organizing marches and events, maintaining websites, paying the legal fees of individuals arrested for their involvement in the IMVE movement, acquiring weapons and establishing safe houses.
In recent years, online crowdfunding platforms and social media sites have started to crack down on IMVE fundraising and promotional activities. This has led IMVE threat actors to seek alternative outlets. These tend to be smaller platforms than the mainstream ones, and they do not always have the resources to monitor and shut down IMVE activities. In response to increased restrictions on online platforms, IMVE threat actors have been encouraging their followers to send them money via mail, cheques or money orders. Following their de-platforming, IMVE threat actors have also increasingly turned to virtual currencies for fundraising. Threat actors mainly use virtual currency donations to fund their propaganda and recruitment efforts. The use of virtual currency has been associated with only one IMVE attack so far.
Observations in suspicious transaction reporting
FINTRAC observed a number of key patterns in IMVE threat actors when analyzing reporting that contained a reference to IMVE-related activity. Overwhelmingly, this data highlights general suspicions of terrorist activity financing and money laundering, particularly of the proceeds of drug-related crimes. The majority of IMVE-related financial transactions were concentrated in Alberta, British Columbia and Ontario.
Lone actors
The financial behaviour of lone IMVE actors is similar to that of lone actors in the RMVE space. Lone actors primarily used personal funds, such as those received from employment income or family members, to carry out attacks. There was no indication in the reporting that the family members were aware that the funds would be used for violent action.
As such, lone actors may be difficult to identify through transactions patterns or financial activity alone. Lone actors commonly used electronic money transfers to both send and receive funds, made cash withdrawals, and carried out regular debit and credit activity to send funds. Further, many lone actors were observed to have sent money transfers to unknown third parties. Lone actors were also observed using their own funds to buy weapons, either through online chain stores or in person. These individuals also carried out routine debit and credit account activity.
Cross-border networks
Individuals in Canada may fund international IMVE networks, while not necessarily being members of organized groups themselves. These individuals typically used payment processing companies and money services businesses to make international funds transfers. While these transactions tended to be small, recurring transfers to multiple nodes of the same international network in different countries, they totalled significant amounts. Financial support to IMVE threat actors also took the form of one-time donations.
Funds were typically sent to pay membership fees, purchase merchandise and gear, and to make general donations to IMVE threat actors overseas. Additionally, some of the beneficiaries forwarded the funds to recruiters for far-right militias and other similar groups. FINTRAC observed that Canadians were most often senders, not recipients, of funds.
Organized threat actors
Organized IMVE threat actors in Canada use both personal and business accounts to conduct their financial activities. Personal and business account transactions showed connections between IMVE threat actors, and individuals and companies charged with crimes such as fraud, robbery, assaulting police officers, drug trafficking and weapons offenses.
Using personal accounts, IMVE threat actors largely relied on electronic money transfers and cash deposits for their fundraising activities. These transfers typically involved small amounts. The majority of funds were suspected to be used to buy firearms and gear, as well as for donations and membership fees. FINTRAC observed several IMVE-related payments to personal accounts from crowdfunding sites.
FINTRAC is aware of the growing use of virtual currencies by IMVE threat actors to send and receive funds. However, the individuals conducting transactions with someone in the network of IMVE threat actors were not always an IMVE threat actor themselves.
The continued use of business accounts by IMVE-related actors could enable groups to raise larger amounts of funds under the guise of legitimate business transactions. This is because business transactions are generally larger than those involving personal accounts and can be conducted without raising much suspicion.
Characteristics in the financing of IMVE activity
The broad characteristics of IMVE found in suspicious transaction reports and set out below may not necessarily be indicative of terrorist financing. Consequently, reporting entities must examine them in conjunction with additional risk indicators such as transactions with links to IMVE threat actors listed as terrorist entities or adverse media reporting.

[Read More] […]

Read More…

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile

You are here:

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile (PDF version, 314 kb)
Reference number: 2021-SIRA-001June 2021
In February 2021, the Government of Canada added four ideologically motivated violent extremism (IMVE) organizations to the Criminal Code list of terrorist entities. Reporting entities should be aware of these new listings, as well as observed patterns in the financing behaviour of IMVE threat actors.Footnote 1
The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) continues to support reporting entities by producing strategic intelligence products, which provide analytical perspectives on the nature, scope and threats posed by money laundering and terrorism financing. To that end, this Special Bulletin presents the results of FINTRAC’s analysis of IMVE-related transaction reporting, supplemented by information from media reports and academic research.
Introduction
IMVE in Canada is driven by a range of grievances that transcend the traditional left–right ideological spectrum. IMVE is also distinct from religiously motivated violent extremism (RMVE) and politically motivated violent extremism (PMVE). The Canadian Security Intelligence Service has divided the violence carried out by threat actors associated with IMVE in Canada into four categories:

xenophobic violence: racially or ethnically motivated violence based on fear or hatred of what is perceived to be foreign, strange or different;
anti-authoritarian violence: violence against the authority of state and law-enforcement entities;
gender-driven violence: violence motivated by hatred of those with a different gender or sexual orientation; and
other grievance-driven and ideologically motivated violence: violence committed by individuals with no clear association with an organized group or any external guidance.

The terrorism threats posed by IMVE threat actors are on the rise around the world. According to a 2020 Trends Alert report published by the United Nations Counter-Terrorism Committee Executive Directorate, there has been a significant rise in terrorist attacks with links to extreme right-wing movements and ideologiesFootnote 3 over the last five years.
In 2019, Blood and Honour and its armed branch, Combat 18, were the first two IMVE-related organizations to be included on the Criminal Code list of terrorist entities. In February 2021, the Government of Canada added four IMVE organizations to this list: Proud Boys, Atomwaffen Division, The Base and Russian Imperial Movement.
Violence in Canada that was motivated in whole or in part by IMVE has tended to take the form of spontaneous arsons, assaults and homicides. Targets include people of the Islamic and Jewish faiths, people of colour, women, Indigenous peoples and members of LGBTQ2 communities. Examples of recent IMVE attacks in Canada include the Quebec City mosque attack in 2017, the Toronto van attack in 2018 and the Toronto spa attack in 2020. This last instance saw, for the first time in Canada, terrorism charges brought against an individual associated with an IMVE ideology.
IMVE threat actors in Canada thrive online as the Internet allows these actors to connect anonymously across borders. IMVE threat actors in Canada use the Internet to make targeted calls for attacking equity-deserving groups offline, and to perpetuate racist and misogynistic tropes on social media that feed into broader narratives associated with conspiracy theories and anti-government movements.
Lone actors in the global IMVE context—those who, by themselves, carry out or attempt to carry out violent attacks in their home country or travel to possibly take part in violent activities elsewhere—raise their own funds, using their savings, employment income or money from family and friends.
Internationally, IMVE threat actors have raised funds through commercial activities, such as selling merchandise, holding events such as talks and concerts, crowdfunding, charging membership fees and accepting donations. IMVE threat actors have also been known to turn to drug trafficking, weapons trafficking and robberies to fund their operations. IMVE threat actors use the funds raised to recruit new members, engage in day-to-day activities and carry out promotional efforts such as making videos. In addition, the funds go toward organizing marches and events, maintaining websites, paying the legal fees of individuals arrested for their involvement in the IMVE movement, acquiring weapons and establishing safe houses.
In recent years, online crowdfunding platforms and social media sites have started to crack down on IMVE fundraising and promotional activities. This has led IMVE threat actors to seek alternative outlets. These tend to be smaller platforms than the mainstream ones, and they do not always have the resources to monitor and shut down IMVE activities. In response to increased restrictions on online platforms, IMVE threat actors have been encouraging their followers to send them money via mail, cheques or money orders. Following their de-platforming, IMVE threat actors have also increasingly turned to virtual currencies for fundraising. Threat actors mainly use virtual currency donations to fund their propaganda and recruitment efforts. The use of virtual currency has been associated with only one IMVE attack so far.
Observations in suspicious transaction reporting
FINTRAC observed a number of key patterns in IMVE threat actors when analyzing reporting that contained a reference to IMVE-related activity. Overwhelmingly, this data highlights general suspicions of terrorist activity financing and money laundering, particularly of the proceeds of drug-related crimes. The majority of IMVE-related financial transactions were concentrated in Alberta, British Columbia and Ontario.
Lone actors
The financial behaviour of lone IMVE actors is similar to that of lone actors in the RMVE space. Lone actors primarily used personal funds, such as those received from employment income or family members, to carry out attacks. There was no indication in the reporting that the family members were aware that the funds would be used for violent action.
As such, lone actors may be difficult to identify through transactions patterns or financial activity alone. Lone actors commonly used electronic money transfers to both send and receive funds, made cash withdrawals, and carried out regular debit and credit activity to send funds. Further, many lone actors were observed to have sent money transfers to unknown third parties. Lone actors were also observed using their own funds to buy weapons, either through online chain stores or in person. These individuals also carried out routine debit and credit account activity.
Cross-border networks
Individuals in Canada may fund international IMVE networks, while not necessarily being members of organized groups themselves. These individuals typically used payment processing companies and money services businesses to make international funds transfers. While these transactions tended to be small, recurring transfers to multiple nodes of the same international network in different countries, they totalled significant amounts. Financial support to IMVE threat actors also took the form of one-time donations.
Funds were typically sent to pay membership fees, purchase merchandise and gear, and to make general donations to IMVE threat actors overseas. Additionally, some of the beneficiaries forwarded the funds to recruiters for far-right militias and other similar groups. FINTRAC observed that Canadians were most often senders, not recipients, of funds.
Organized threat actors
Organized IMVE threat actors in Canada use both personal and business accounts to conduct their financial activities. Personal and business account transactions showed connections between IMVE threat actors, and individuals and companies charged with crimes such as fraud, robbery, assaulting police officers, drug trafficking and weapons offenses.
Using personal accounts, IMVE threat actors largely relied on electronic money transfers and cash deposits for their fundraising activities. These transfers typically involved small amounts. The majority of funds were suspected to be used to buy firearms and gear, as well as for donations and membership fees. FINTRAC observed several IMVE-related payments to personal accounts from crowdfunding sites.
FINTRAC is aware of the growing use of virtual currencies by IMVE threat actors to send and receive funds. However, the individuals conducting transactions with someone in the network of IMVE threat actors were not always an IMVE threat actor themselves.
The continued use of business accounts by IMVE-related actors could enable groups to raise larger amounts of funds under the guise of legitimate business transactions. This is because business transactions are generally larger than those involving personal accounts and can be conducted without raising much suspicion.
Characteristics in the financing of IMVE activity
The broad characteristics of IMVE found in suspicious transaction reports and set out below may not necessarily be indicative of terrorist financing. Consequently, reporting entities must examine them in conjunction with additional risk indicators such as transactions with links to IMVE threat actors listed as terrorist entities or adverse media reporting.

[Read More] […]

Read More…

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile

You are here:

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile (PDF version, 314 kb)
Reference number: 2021-SIRA-001June 2021
In February 2021, the Government of Canada added four ideologically motivated violent extremism (IMVE) organizations to the Criminal Code list of terrorist entities. Reporting entities should be aware of these new listings, as well as observed patterns in the financing behaviour of IMVE threat actors.Footnote 1
The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) continues to support reporting entities by producing strategic intelligence products, which provide analytical perspectives on the nature, scope and threats posed by money laundering and terrorism financing. To that end, this Special Bulletin presents the results of FINTRAC’s analysis of IMVE-related transaction reporting, supplemented by information from media reports and academic research.
Introduction
IMVE in Canada is driven by a range of grievances that transcend the traditional left–right ideological spectrum. IMVE is also distinct from religiously motivated violent extremism (RMVE) and politically motivated violent extremism (PMVE). The Canadian Security Intelligence Service has divided the violence carried out by threat actors associated with IMVE in Canada into four categories:

xenophobic violence: racially or ethnically motivated violence based on fear or hatred of what is perceived to be foreign, strange or different;
anti-authoritarian violence: violence against the authority of state and law-enforcement entities;
gender-driven violence: violence motivated by hatred of those with a different gender or sexual orientation; and
other grievance-driven and ideologically motivated violence: violence committed by individuals with no clear association with an organized group or any external guidance.

The terrorism threats posed by IMVE threat actors are on the rise around the world. According to a 2020 Trends Alert report published by the United Nations Counter-Terrorism Committee Executive Directorate, there has been a significant rise in terrorist attacks with links to extreme right-wing movements and ideologiesFootnote 3 over the last five years.
In 2019, Blood and Honour and its armed branch, Combat 18, were the first two IMVE-related organizations to be included on the Criminal Code list of terrorist entities. In February 2021, the Government of Canada added four IMVE organizations to this list: Proud Boys, Atomwaffen Division, The Base and Russian Imperial Movement.
Violence in Canada that was motivated in whole or in part by IMVE has tended to take the form of spontaneous arsons, assaults and homicides. Targets include people of the Islamic and Jewish faiths, people of colour, women, Indigenous peoples and members of LGBTQ2 communities. Examples of recent IMVE attacks in Canada include the Quebec City mosque attack in 2017, the Toronto van attack in 2018 and the Toronto spa attack in 2020. This last instance saw, for the first time in Canada, terrorism charges brought against an individual associated with an IMVE ideology.
IMVE threat actors in Canada thrive online as the Internet allows these actors to connect anonymously across borders. IMVE threat actors in Canada use the Internet to make targeted calls for attacking equity-deserving groups offline, and to perpetuate racist and misogynistic tropes on social media that feed into broader narratives associated with conspiracy theories and anti-government movements.
Lone actors in the global IMVE context—those who, by themselves, carry out or attempt to carry out violent attacks in their home country or travel to possibly take part in violent activities elsewhere—raise their own funds, using their savings, employment income or money from family and friends.
Internationally, IMVE threat actors have raised funds through commercial activities, such as selling merchandise, holding events such as talks and concerts, crowdfunding, charging membership fees and accepting donations. IMVE threat actors have also been known to turn to drug trafficking, weapons trafficking and robberies to fund their operations. IMVE threat actors use the funds raised to recruit new members, engage in day-to-day activities and carry out promotional efforts such as making videos. In addition, the funds go toward organizing marches and events, maintaining websites, paying the legal fees of individuals arrested for their involvement in the IMVE movement, acquiring weapons and establishing safe houses.
In recent years, online crowdfunding platforms and social media sites have started to crack down on IMVE fundraising and promotional activities. This has led IMVE threat actors to seek alternative outlets. These tend to be smaller platforms than the mainstream ones, and they do not always have the resources to monitor and shut down IMVE activities. In response to increased restrictions on online platforms, IMVE threat actors have been encouraging their followers to send them money via mail, cheques or money orders. Following their de-platforming, IMVE threat actors have also increasingly turned to virtual currencies for fundraising. Threat actors mainly use virtual currency donations to fund their propaganda and recruitment efforts. The use of virtual currency has been associated with only one IMVE attack so far.
Observations in suspicious transaction reporting
FINTRAC observed a number of key patterns in IMVE threat actors when analyzing reporting that contained a reference to IMVE-related activity. Overwhelmingly, this data highlights general suspicions of terrorist activity financing and money laundering, particularly of the proceeds of drug-related crimes. The majority of IMVE-related financial transactions were concentrated in Alberta, British Columbia and Ontario.
Lone actors
The financial behaviour of lone IMVE actors is similar to that of lone actors in the RMVE space. Lone actors primarily used personal funds, such as those received from employment income or family members, to carry out attacks. There was no indication in the reporting that the family members were aware that the funds would be used for violent action.
As such, lone actors may be difficult to identify through transactions patterns or financial activity alone. Lone actors commonly used electronic money transfers to both send and receive funds, made cash withdrawals, and carried out regular debit and credit activity to send funds. Further, many lone actors were observed to have sent money transfers to unknown third parties. Lone actors were also observed using their own funds to buy weapons, either through online chain stores or in person. These individuals also carried out routine debit and credit account activity.
Cross-border networks
Individuals in Canada may fund international IMVE networks, while not necessarily being members of organized groups themselves. These individuals typically used payment processing companies and money services businesses to make international funds transfers. While these transactions tended to be small, recurring transfers to multiple nodes of the same international network in different countries, they totalled significant amounts. Financial support to IMVE threat actors also took the form of one-time donations.
Funds were typically sent to pay membership fees, purchase merchandise and gear, and to make general donations to IMVE threat actors overseas. Additionally, some of the beneficiaries forwarded the funds to recruiters for far-right militias and other similar groups. FINTRAC observed that Canadians were most often senders, not recipients, of funds.
Organized threat actors
Organized IMVE threat actors in Canada use both personal and business accounts to conduct their financial activities. Personal and business account transactions showed connections between IMVE threat actors, and individuals and companies charged with crimes such as fraud, robbery, assaulting police officers, drug trafficking and weapons offenses.
Using personal accounts, IMVE threat actors largely relied on electronic money transfers and cash deposits for their fundraising activities. These transfers typically involved small amounts. The majority of funds were suspected to be used to buy firearms and gear, as well as for donations and membership fees. FINTRAC observed several IMVE-related payments to personal accounts from crowdfunding sites.
FINTRAC is aware of the growing use of virtual currencies by IMVE threat actors to send and receive funds. However, the individuals conducting transactions with someone in the network of IMVE threat actors were not always an IMVE threat actor themselves.
The continued use of business accounts by IMVE-related actors could enable groups to raise larger amounts of funds under the guise of legitimate business transactions. This is because business transactions are generally larger than those involving personal accounts and can be conducted without raising much suspicion.
Characteristics in the financing of IMVE activity
The broad characteristics of IMVE found in suspicious transaction reports and set out below may not necessarily be indicative of terrorist financing. Consequently, reporting entities must examine them in conjunction with additional risk indicators such as transactions with links to IMVE threat actors listed as terrorist entities or adverse media reporting.

[Read More] […]

Read More…

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile

You are here:

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile (PDF version, 314 kb)
Reference number: 2021-SIRA-001June 2021
In February 2021, the Government of Canada added four ideologically motivated violent extremism (IMVE) organizations to the Criminal Code list of terrorist entities. Reporting entities should be aware of these new listings, as well as observed patterns in the financing behaviour of IMVE threat actors.Footnote 1
The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) continues to support reporting entities by producing strategic intelligence products, which provide analytical perspectives on the nature, scope and threats posed by money laundering and terrorism financing. To that end, this Special Bulletin presents the results of FINTRAC’s analysis of IMVE-related transaction reporting, supplemented by information from media reports and academic research.
Introduction
IMVE in Canada is driven by a range of grievances that transcend the traditional left–right ideological spectrum. IMVE is also distinct from religiously motivated violent extremism (RMVE) and politically motivated violent extremism (PMVE). The Canadian Security Intelligence Service has divided the violence carried out by threat actors associated with IMVE in Canada into four categories:

xenophobic violence: racially or ethnically motivated violence based on fear or hatred of what is perceived to be foreign, strange or different;
anti-authoritarian violence: violence against the authority of state and law-enforcement entities;
gender-driven violence: violence motivated by hatred of those with a different gender or sexual orientation; and
other grievance-driven and ideologically motivated violence: violence committed by individuals with no clear association with an organized group or any external guidance.

The terrorism threats posed by IMVE threat actors are on the rise around the world. According to a 2020 Trends Alert report published by the United Nations Counter-Terrorism Committee Executive Directorate, there has been a significant rise in terrorist attacks with links to extreme right-wing movements and ideologiesFootnote 3 over the last five years.
In 2019, Blood and Honour and its armed branch, Combat 18, were the first two IMVE-related organizations to be included on the Criminal Code list of terrorist entities. In February 2021, the Government of Canada added four IMVE organizations to this list: Proud Boys, Atomwaffen Division, The Base and Russian Imperial Movement.
Violence in Canada that was motivated in whole or in part by IMVE has tended to take the form of spontaneous arsons, assaults and homicides. Targets include people of the Islamic and Jewish faiths, people of colour, women, Indigenous peoples and members of LGBTQ2 communities. Examples of recent IMVE attacks in Canada include the Quebec City mosque attack in 2017, the Toronto van attack in 2018 and the Toronto spa attack in 2020. This last instance saw, for the first time in Canada, terrorism charges brought against an individual associated with an IMVE ideology.
IMVE threat actors in Canada thrive online as the Internet allows these actors to connect anonymously across borders. IMVE threat actors in Canada use the Internet to make targeted calls for attacking equity-deserving groups offline, and to perpetuate racist and misogynistic tropes on social media that feed into broader narratives associated with conspiracy theories and anti-government movements.
Lone actors in the global IMVE context—those who, by themselves, carry out or attempt to carry out violent attacks in their home country or travel to possibly take part in violent activities elsewhere—raise their own funds, using their savings, employment income or money from family and friends.
Internationally, IMVE threat actors have raised funds through commercial activities, such as selling merchandise, holding events such as talks and concerts, crowdfunding, charging membership fees and accepting donations. IMVE threat actors have also been known to turn to drug trafficking, weapons trafficking and robberies to fund their operations. IMVE threat actors use the funds raised to recruit new members, engage in day-to-day activities and carry out promotional efforts such as making videos. In addition, the funds go toward organizing marches and events, maintaining websites, paying the legal fees of individuals arrested for their involvement in the IMVE movement, acquiring weapons and establishing safe houses.
In recent years, online crowdfunding platforms and social media sites have started to crack down on IMVE fundraising and promotional activities. This has led IMVE threat actors to seek alternative outlets. These tend to be smaller platforms than the mainstream ones, and they do not always have the resources to monitor and shut down IMVE activities. In response to increased restrictions on online platforms, IMVE threat actors have been encouraging their followers to send them money via mail, cheques or money orders. Following their de-platforming, IMVE threat actors have also increasingly turned to virtual currencies for fundraising. Threat actors mainly use virtual currency donations to fund their propaganda and recruitment efforts. The use of virtual currency has been associated with only one IMVE attack so far.
Observations in suspicious transaction reporting
FINTRAC observed a number of key patterns in IMVE threat actors when analyzing reporting that contained a reference to IMVE-related activity. Overwhelmingly, this data highlights general suspicions of terrorist activity financing and money laundering, particularly of the proceeds of drug-related crimes. The majority of IMVE-related financial transactions were concentrated in Alberta, British Columbia and Ontario.
Lone actors
The financial behaviour of lone IMVE actors is similar to that of lone actors in the RMVE space. Lone actors primarily used personal funds, such as those received from employment income or family members, to carry out attacks. There was no indication in the reporting that the family members were aware that the funds would be used for violent action.
As such, lone actors may be difficult to identify through transactions patterns or financial activity alone. Lone actors commonly used electronic money transfers to both send and receive funds, made cash withdrawals, and carried out regular debit and credit activity to send funds. Further, many lone actors were observed to have sent money transfers to unknown third parties. Lone actors were also observed using their own funds to buy weapons, either through online chain stores or in person. These individuals also carried out routine debit and credit account activity.
Cross-border networks
Individuals in Canada may fund international IMVE networks, while not necessarily being members of organized groups themselves. These individuals typically used payment processing companies and money services businesses to make international funds transfers. While these transactions tended to be small, recurring transfers to multiple nodes of the same international network in different countries, they totalled significant amounts. Financial support to IMVE threat actors also took the form of one-time donations.
Funds were typically sent to pay membership fees, purchase merchandise and gear, and to make general donations to IMVE threat actors overseas. Additionally, some of the beneficiaries forwarded the funds to recruiters for far-right militias and other similar groups. FINTRAC observed that Canadians were most often senders, not recipients, of funds.
Organized threat actors
Organized IMVE threat actors in Canada use both personal and business accounts to conduct their financial activities. Personal and business account transactions showed connections between IMVE threat actors, and individuals and companies charged with crimes such as fraud, robbery, assaulting police officers, drug trafficking and weapons offenses.
Using personal accounts, IMVE threat actors largely relied on electronic money transfers and cash deposits for their fundraising activities. These transfers typically involved small amounts. The majority of funds were suspected to be used to buy firearms and gear, as well as for donations and membership fees. FINTRAC observed several IMVE-related payments to personal accounts from crowdfunding sites.
FINTRAC is aware of the growing use of virtual currencies by IMVE threat actors to send and receive funds. However, the individuals conducting transactions with someone in the network of IMVE threat actors were not always an IMVE threat actor themselves.
The continued use of business accounts by IMVE-related actors could enable groups to raise larger amounts of funds under the guise of legitimate business transactions. This is because business transactions are generally larger than those involving personal accounts and can be conducted without raising much suspicion.
Characteristics in the financing of IMVE activity
The broad characteristics of IMVE found in suspicious transaction reports and set out below may not necessarily be indicative of terrorist financing. Consequently, reporting entities must examine them in conjunction with additional risk indicators such as transactions with links to IMVE threat actors listed as terrorist entities or adverse media reporting.

[Read More] […]

Read More…

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile

You are here:

Special Bulletin on Ideologically Motivated Violent Extremism: A Terrorist Activity Financing Profile (PDF version, 314 kb)
Reference number: 2021-SIRA-001June 2021
In February 2021, the Government of Canada added four ideologically motivated violent extremism (IMVE) organizations to the Criminal Code list of terrorist entities. Reporting entities should be aware of these new listings, as well as observed patterns in the financing behaviour of IMVE threat actors.Footnote 1
The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) continues to support reporting entities by producing strategic intelligence products, which provide analytical perspectives on the nature, scope and threats posed by money laundering and terrorism financing. To that end, this Special Bulletin presents the results of FINTRAC’s analysis of IMVE-related transaction reporting, supplemented by information from media reports and academic research.
Introduction
IMVE in Canada is driven by a range of grievances that transcend the traditional left–right ideological spectrum. IMVE is also distinct from religiously motivated violent extremism (RMVE) and politically motivated violent extremism (PMVE). The Canadian Security Intelligence Service has divided the violence carried out by threat actors associated with IMVE in Canada into four categories:

xenophobic violence: racially or ethnically motivated violence based on fear or hatred of what is perceived to be foreign, strange or different;
anti-authoritarian violence: violence against the authority of state and law-enforcement entities;
gender-driven violence: violence motivated by hatred of those with a different gender or sexual orientation; and
other grievance-driven and ideologically motivated violence: violence committed by individuals with no clear association with an organized group or any external guidance.

The terrorism threats posed by IMVE threat actors are on the rise around the world. According to a 2020 Trends Alert report published by the United Nations Counter-Terrorism Committee Executive Directorate, there has been a significant rise in terrorist attacks with links to extreme right-wing movements and ideologiesFootnote 3 over the last five years.
In 2019, Blood and Honour and its armed branch, Combat 18, were the first two IMVE-related organizations to be included on the Criminal Code list of terrorist entities. In February 2021, the Government of Canada added four IMVE organizations to this list: Proud Boys, Atomwaffen Division, The Base and Russian Imperial Movement.
Violence in Canada that was motivated in whole or in part by IMVE has tended to take the form of spontaneous arsons, assaults and homicides. Targets include people of the Islamic and Jewish faiths, people of colour, women, Indigenous peoples and members of LGBTQ2 communities. Examples of recent IMVE attacks in Canada include the Quebec City mosque attack in 2017, the Toronto van attack in 2018 and the Toronto spa attack in 2020. This last instance saw, for the first time in Canada, terrorism charges brought against an individual associated with an IMVE ideology.
IMVE threat actors in Canada thrive online as the Internet allows these actors to connect anonymously across borders. IMVE threat actors in Canada use the Internet to make targeted calls for attacking equity-deserving groups offline, and to perpetuate racist and misogynistic tropes on social media that feed into broader narratives associated with conspiracy theories and anti-government movements.
Lone actors in the global IMVE context—those who, by themselves, carry out or attempt to carry out violent attacks in their home country or travel to possibly take part in violent activities elsewhere—raise their own funds, using their savings, employment income or money from family and friends.
Internationally, IMVE threat actors have raised funds through commercial activities, such as selling merchandise, holding events such as talks and concerts, crowdfunding, charging membership fees and accepting donations. IMVE threat actors have also been known to turn to drug trafficking, weapons trafficking and robberies to fund their operations. IMVE threat actors use the funds raised to recruit new members, engage in day-to-day activities and carry out promotional efforts such as making videos. In addition, the funds go toward organizing marches and events, maintaining websites, paying the legal fees of individuals arrested for their involvement in the IMVE movement, acquiring weapons and establishing safe houses.
In recent years, online crowdfunding platforms and social media sites have started to crack down on IMVE fundraising and promotional activities. This has led IMVE threat actors to seek alternative outlets. These tend to be smaller platforms than the mainstream ones, and they do not always have the resources to monitor and shut down IMVE activities. In response to increased restrictions on online platforms, IMVE threat actors have been encouraging their followers to send them money via mail, cheques or money orders. Following their de-platforming, IMVE threat actors have also increasingly turned to virtual currencies for fundraising. Threat actors mainly use virtual currency donations to fund their propaganda and recruitment efforts. The use of virtual currency has been associated with only one IMVE attack so far.
Observations in suspicious transaction reporting
FINTRAC observed a number of key patterns in IMVE threat actors when analyzing reporting that contained a reference to IMVE-related activity. Overwhelmingly, this data highlights general suspicions of terrorist activity financing and money laundering, particularly of the proceeds of drug-related crimes. The majority of IMVE-related financial transactions were concentrated in Alberta, British Columbia and Ontario.
Lone actors
The financial behaviour of lone IMVE actors is similar to that of lone actors in the RMVE space. Lone actors primarily used personal funds, such as those received from employment income or family members, to carry out attacks. There was no indication in the reporting that the family members were aware that the funds would be used for violent action.
As such, lone actors may be difficult to identify through transactions patterns or financial activity alone. Lone actors commonly used electronic money transfers to both send and receive funds, made cash withdrawals, and carried out regular debit and credit activity to send funds. Further, many lone actors were observed to have sent money transfers to unknown third parties. Lone actors were also observed using their own funds to buy weapons, either through online chain stores or in person. These individuals also carried out routine debit and credit account activity.
Cross-border networks
Individuals in Canada may fund international IMVE networks, while not necessarily being members of organized groups themselves. These individuals typically used payment processing companies and money services businesses to make international funds transfers. While these transactions tended to be small, recurring transfers to multiple nodes of the same international network in different countries, they totalled significant amounts. Financial support to IMVE threat actors also took the form of one-time donations.
Funds were typically sent to pay membership fees, purchase merchandise and gear, and to make general donations to IMVE threat actors overseas. Additionally, some of the beneficiaries forwarded the funds to recruiters for far-right militias and other similar groups. FINTRAC observed that Canadians were most often senders, not recipients, of funds.
Organized threat actors
Organized IMVE threat actors in Canada use both personal and business accounts to conduct their financial activities. Personal and business account transactions showed connections between IMVE threat actors, and individuals and companies charged with crimes such as fraud, robbery, assaulting police officers, drug trafficking and weapons offenses.
Using personal accounts, IMVE threat actors largely relied on electronic money transfers and cash deposits for their fundraising activities. These transfers typically involved small amounts. The majority of funds were suspected to be used to buy firearms and gear, as well as for donations and membership fees. FINTRAC observed several IMVE-related payments to personal accounts from crowdfunding sites.
FINTRAC is aware of the growing use of virtual currencies by IMVE threat actors to send and receive funds. However, the individuals conducting transactions with someone in the network of IMVE threat actors were not always an IMVE threat actor themselves.
The continued use of business accounts by IMVE-related actors could enable groups to raise larger amounts of funds under the guise of legitimate business transactions. This is because business transactions are generally larger than those involving personal accounts and can be conducted without raising much suspicion.
Characteristics in the financing of IMVE activity
The broad characteristics of IMVE found in suspicious transaction reports and set out below may not necessarily be indicative of terrorist financing. Consequently, reporting entities must examine them in conjunction with additional risk indicators such as transactions with links to IMVE threat actors listed as terrorist entities or adverse media reporting.

[Read More] […]

Read More…

Canada’s AML/ATF regime is stronger today with the coming-into-force of the regulatory amendments.

Regulatory amendments in force as of June 1, 2021

You are here:

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Regulatory amendments in force as of June 1, 2021

The changes to the Regulations made under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act announced in the Canada Gazette in July 2019 and June 2020 are in force as of June 1, 2021. These changes help strengthen Canada’s anti-money laundering and anti-terrorist financing regime by closing certain gaps, such as those stemming from technological advances.
At a high level, the changes include, but are not limited to, the following:

Obligations for transactions involving virtual currencies, including to report the receipt of a large amount of virtual currency and to follow associated know-your-client obligations;
The requirement for certain businesses that initiate or finally receive electronic funds transfers to report instead of the businesses that are intermediaries in these transfers, however the intermediaries must keep records of the transactions;
The requirement for new information fields to be reported (for example, online identifiers, email addresses, etc.);
The expansion to all reporting entity sectors of the requirement to obtain and take reasonable measures to confirm the accuracy of information obtained on the beneficial owners of a corporation, trust or other entity that is a client;
The requirement to aggregate on the beneficiary when applying the 24-hour rule to certain transactions;
The requirement for financial entities to treat prepaid payment products and related accounts similarly to bank accounts;
The expansion to all reporting entity sectors of the requirement to determine whether a client is a politically exposed person or the head of an international organization in certain circumstances;
The requirement for the life insurance sector to keep records and verify the identity of a beneficiary before a payout; and
New methods that reporting entities can use to verify the identity of person and entities.

FINTRAC’s guidance has been updated to reflect these requirements.  
FINTRAC expects reporting entities (REs) to comply with the amendments, but understands that many may face challenges in meeting these obligations. For further information on how FINTRAC will assess compliance with the new requirements, please consult the May 18, 2021 Notice on the assessment of obligations coming into force on June 1, 2021. Furthermore, additional flexibilities that are being provided by FINTRAC on an exceptional and transitionary basis can be found by consulting the November 16, 2020 Notice on forthcoming regulatory amendments and flexibility.
FINTRAC would like to thank the businesses that have provided input on the implementation of the new requirements and on the related guidance. With their feedback, FINTRAC has been able to create better products that support our common goal of having a strong anti-money laundering and anti-terrorist financing regime that keeps our financial system secure.

[Read More] […]

Read More…

Canada’s AML/ATF regime is stronger today with the coming-into-force of the regulatory amendments.

Regulatory amendments in force as of June 1, 2021

You are here:

Home
Regulatory amendments in force as of June 1, 2021

The changes to the Regulations made under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act announced in the Canada Gazette in July 2019 and June 2020 are in force as of June 1, 2021. These changes help strengthen Canada’s anti-money laundering and anti-terrorist financing regime by closing certain gaps, such as those stemming from technological advances.
At a high level, the changes include, but are not limited to, the following:

Obligations for transactions involving virtual currencies, including to report the receipt of a large amount of virtual currency and to follow associated know-your-client obligations;
The requirement for certain businesses that initiate or finally receive electronic funds transfers to report instead of the businesses that are intermediaries in these transfers, however the intermediaries must keep records of the transactions;
The requirement for new information fields to be reported (for example, online identifiers, email addresses, etc.);
The expansion to all reporting entity sectors of the requirement to obtain and take reasonable measures to confirm the accuracy of information obtained on the beneficial owners of a corporation, trust or other entity that is a client;
The requirement to aggregate on the beneficiary when applying the 24-hour rule to certain transactions;
The requirement for financial entities to treat prepaid payment products and related accounts similarly to bank accounts;
The expansion to all reporting entity sectors of the requirement to determine whether a client is a politically exposed person or the head of an international organization in certain circumstances;
The requirement for the life insurance sector to keep records and verify the identity of a beneficiary before a payout; and
New methods that reporting entities can use to verify the identity of person and entities.

FINTRAC’s guidance has been updated to reflect these requirements.  
FINTRAC expects reporting entities (REs) to comply with the amendments, but understands that many may face challenges in meeting these obligations. For further information on how FINTRAC will assess compliance with the new requirements, please consult the May 18, 2021 Notice on the assessment of obligations coming into force on June 1, 2021. Furthermore, additional flexibilities that are being provided by FINTRAC on an exceptional and transitionary basis can be found by consulting the November 16, 2020 Notice on forthcoming regulatory amendments and flexibility.
FINTRAC would like to thank the businesses that have provided input on the implementation of the new requirements and on the related guidance. With their feedback, FINTRAC has been able to create better products that support our common goal of having a strong anti-money laundering and anti-terrorist financing regime that keeps our financial system secure.

[Read More] […]

Read More…

FINTRAC has published guidance on reporting large virtual currency transactions.

Accountant

A chartered accountant, a certified general accountant, a certified management accountant or, if applicable, a chartered professional accountant.Footnote 1 (comptable)

Accounting firm

An entity that is engaged in the business of providing accounting services to the public and has at least one partner, employee or administrator that is an accountant.Footnote 2 (cabinet d’expertise comptable)

Act

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).Footnote 3 (la Loi)

Administrative monetary penalties (AMPs)

Civil penalties that may be issued to reporting entities by FINTRAC for non-compliance with the PCMLTFA and associated Regulations. (pénalité administrative pécuniaire [PAP])

Affiliate

An entity is affiliated with another entity if one of them is wholly owned by the other, if both are wholly owned by the same entity or if their financial statements are consolidated.Footnote 4 (entité du même groupe)

Annuity

Has the same meaning as in subsection 248(1) of the Income Tax ActFootnote 5 (rente)

As soon as practicable

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. The completion and submission of the STR should take priority over other tasks. In this context, the report must be completed promptly, taking into account the facts and circumstances of the situation. While some delay is permitted, it must have a reasonable explanation. (aussitôt que possible)

Attempted transaction

Occurs when an individual or entity starts to conduct a transaction that is not completed. For example, a client or a potential client walks away from conducting a $10,000 cash deposit. (opération tentée)

Authentic

In respect of verifying identity, means genuine and having the character of an original, credible, and reliable document or record. (authentique)

Authorized person

A person who is authorized under subsection 45(2).Footnote 6 (personne autorisée)

Authorized user

A person who is authorized by a holder of a prepaid payment product account to have electronic access to funds or virtual currency available in the account by means of a prepaid payment product that is connected to it.Footnote 7 (utilisateur autorisé)

Beneficial Owner(s)

Beneficial owners are the individuals who are the trustees, and known beneficiaries and settlors of a trust, or who directly or indirectly own or control 25% or more of i) the shares of a corporation or ii) an entity other than a corporation or trust, such as a partnership. The ultimate beneficial owner(s) cannot be another corporation or entity; it must be the actual individual(s) who owns or controls the entity. (bénéficiaire effectif)

Beneficiary

A beneficiary is the individual or entity that will benefit from a transaction or to which the final remittance is made. (bénéficiaire)

Branch

A branch is a part of your business at a distinct location other than your main office. (succursale)

British Columbia notary corporation

An entity that carries on the business of providing notary services to the public in British Columbia in accordance with the Notaries Act, R.S.B.C. 1996, c. 334.Footnote 8 (société de notaires de la Colombie-Britannique)

British Columbia notary public

A person who is a member of the Society of Notaries Public of British Columbia.Footnote 9 (notaire public de la Colombie-Britannique)

Cash

Coins referred to in section 7 of the Currency Act, notes issued by the Bank of Canada under the Bank of Canada Act that are intended for circulation in Canada or coins or bank notes of countries other than Canada.Footnote 10 (espèces)

Casino

A government, organization, board or operator that is referred to in any of paragraphs 5(k) to (k.3) of the Act.Footnote 11 (casino)

Certified translator

An individual that holds the title of professional certified translator granted by a Canadian provincial or territorial association or body that is competent under Canadian provincial or territorial law to issue such certification. (traducteur agréé)

Clarification request

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 request is usually sent by email. (demande de précisions)

Client

A person or entity that engages in a financial transaction with another person or entity.Footnote 12 (client)

Client identification information

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. (renseignements d’identification du client)

Competent authority

For the purpose of the criminal record check submitted with an application for registration, a competent authority is any person or organization that has the legally delegated or invested authority, capacity, or power to issue criminal record checks. (autorité compétente)

Completed transaction

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. (opération effectuée)

Compliance officer

The individual, with the necessary authority, that you appoint to be responsible for the implementation of your compliance program. (agent de conformité)

Compliance policies and procedures

Written methodology outlining the obligations applicable to your business under the PCMLTFA and its associated Regulations and the corresponding processes and controls you put in place to address your obligations. (politiques et procédures de conformité)

Compliance program

All elements (compliance officer, policies and procedures, risk assessment, training program, effectiveness review) that you, as a reporting entity, are legally required to have under the PCMLTFA and its associated Regulations to ensure that you meet all your obligations. (programme de conformité)

Context

Clarifies a set of circumstances or provides an explanation of a situation or financial transaction that can be understood and assessed. (contexte)

Correspondent banking relationship

A relationship created by an agreement or arrangement under which an entity referred to in any of paragraphs 5(a), (b), (d) and (e) or an entity that is referred to in section 5 of the Act and that is prescribed undertakes to provide to a foreign financial institution services such as international electronic funds transfers, cash management, cheque clearing and any prescribed services.Footnote 13 (relation de correspondant bancaire)

Country of residence

The country where an individual has lived continuously for 12 months or more. The individual must have a dwelling in the country concerned. For greater certainty, a person only has one country of residence no matter how many dwelling places they may have, inside or outside of that country. (pays de résidence)

Credit card acquiring business

A credit card acquiring business is a financial entity that has an agreement with a merchant to provide the following services:

enabling a merchant to accept credit card payments by cardholders for goods and services and to receive payments for credit card purchases;
processing services, payment settlements and providing point-of-sale equipment (such as computer terminals); and
providing other ancillary services to the merchant.

(entreprise d’acquisition de cartes de crédit)
Credit union central

A central cooperative credit society, as defined in section 2 of the Cooperative Credit Associations Act, or a credit union central or a federation of credit unions or caisses populaires that is regulated by a provincial Act other than one enacted by the legislature of Quebec.Footnote 14 (centrale de caisses de crédit)

Current

In respect of a document or source of information that is used to verify identity, is up to date, and, in the case of a government-issued photo identification document, must not have been expired when the ID was verified. (à jour)

Dealer in precious metals and stones

A person or entity that, in the course of their business activities, buys or sells precious metals, precious stones or jewellery. It includes a department or an agent of Her Majesty in right of Canada or an agent or mandatary of Her Majesty in right of a province when the department or the agent or mandatary carries out the activity, referred to in subsection 65(1), of selling precious metals to the public.Footnote 15 (négociant en métaux précieux et pierres précieuses)

Deferred profit sharing plan

Has the same meaning as in subsection 248(1) of the Income Tax Act.Footnote 16 (régime de participation différée aux bénéfices)

Deposit slip

A record that sets out:Footnote 17

(a) the date of the deposit;
(b) the name of the person or entity that makes the deposit;
(c) the amount of the deposit and of any part of it that is made in cash;
(d) the method by which the deposit is made; and
(e) the number of the account into which the deposit is made and the name of each account holder.

(relevé de dépôt)
Directing Services

A business is directing services at persons or entities in Canada if at least one of the following applies:

The business’s marketing or advertising is directed at persons or entities located in Canada;
The business operates a “.ca” domain name; or,
The business is listed in a Canadian business directory.

Additional criteria may be considered, such as if the business describes its services being offered in Canada or actively seeks feedback from persons or entities in Canada.

[Read More] […]

Read More…

FINTRAC has published guidance on reporting large virtual currency transactions.

Accountant

A chartered accountant, a certified general accountant, a certified management accountant or, if applicable, a chartered professional accountant.Footnote 1 (comptable)

Accounting firm

An entity that is engaged in the business of providing accounting services to the public and has at least one partner, employee or administrator that is an accountant.Footnote 2 (cabinet d’expertise comptable)

Act

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).Footnote 3 (la Loi)

Administrative monetary penalties (AMPs)

Civil penalties that may be issued to reporting entities by FINTRAC for non-compliance with the PCMLTFA and associated Regulations. (pénalité administrative pécuniaire [PAP])

Affiliate

An entity is affiliated with another entity if one of them is wholly owned by the other, if both are wholly owned by the same entity or if their financial statements are consolidated.Footnote 4 (entité du même groupe)

Annuity

Has the same meaning as in subsection 248(1) of the Income Tax ActFootnote 5 (rente)

As soon as practicable

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. The completion and submission of the STR should take priority over other tasks. In this context, the report must be completed promptly, taking into account the facts and circumstances of the situation. While some delay is permitted, it must have a reasonable explanation. (aussitôt que possible)

Attempted transaction

Occurs when an individual or entity starts to conduct a transaction that is not completed. For example, a client or a potential client walks away from conducting a $10,000 cash deposit. (opération tentée)

Authentic

In respect of verifying identity, means genuine and having the character of an original, credible, and reliable document or record. (authentique)

Authorized person

A person who is authorized under subsection 45(2).Footnote 6 (personne autorisée)

Authorized user

A person who is authorized by a holder of a prepaid payment product account to have electronic access to funds or virtual currency available in the account by means of a prepaid payment product that is connected to it.Footnote 7 (utilisateur autorisé)

Beneficial Owner(s)

Beneficial owners are the individuals who are the trustees, and known beneficiaries and settlors of a trust, or who directly or indirectly own or control 25% or more of i) the shares of a corporation or ii) an entity other than a corporation or trust, such as a partnership. The ultimate beneficial owner(s) cannot be another corporation or entity; it must be the actual individual(s) who owns or controls the entity. (bénéficiaire effectif)

Beneficiary

A beneficiary is the individual or entity that will benefit from a transaction or to which the final remittance is made. (bénéficiaire)

Branch

A branch is a part of your business at a distinct location other than your main office. (succursale)

British Columbia notary corporation

An entity that carries on the business of providing notary services to the public in British Columbia in accordance with the Notaries Act, R.S.B.C. 1996, c. 334.Footnote 8 (société de notaires de la Colombie-Britannique)

British Columbia notary public

A person who is a member of the Society of Notaries Public of British Columbia.Footnote 9 (notaire public de la Colombie-Britannique)

Cash

Coins referred to in section 7 of the Currency Act, notes issued by the Bank of Canada under the Bank of Canada Act that are intended for circulation in Canada or coins or bank notes of countries other than Canada.Footnote 10 (espèces)

Casino

A government, organization, board or operator that is referred to in any of paragraphs 5(k) to (k.3) of the Act.Footnote 11 (casino)

Certified translator

An individual that holds the title of professional certified translator granted by a Canadian provincial or territorial association or body that is competent under Canadian provincial or territorial law to issue such certification. (traducteur agréé)

Clarification request

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 request is usually sent by email. (demande de précisions)

Client

A person or entity that engages in a financial transaction with another person or entity.Footnote 12 (client)

Client identification information

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. (renseignements d’identification du client)

Competent authority

For the purpose of the criminal record check submitted with an application for registration, a competent authority is any person or organization that has the legally delegated or invested authority, capacity, or power to issue criminal record checks. (autorité compétente)

Completed transaction

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. (opération effectuée)

Compliance officer

The individual, with the necessary authority, that you appoint to be responsible for the implementation of your compliance program. (agent de conformité)

Compliance policies and procedures

Written methodology outlining the obligations applicable to your business under the PCMLTFA and its associated Regulations and the corresponding processes and controls you put in place to address your obligations. (politiques et procédures de conformité)

Compliance program

All elements (compliance officer, policies and procedures, risk assessment, training program, effectiveness review) that you, as a reporting entity, are legally required to have under the PCMLTFA and its associated Regulations to ensure that you meet all your obligations. (programme de conformité)

Context

Clarifies a set of circumstances or provides an explanation of a situation or financial transaction that can be understood and assessed. (contexte)

Correspondent banking relationship

A relationship created by an agreement or arrangement under which an entity referred to in any of paragraphs 5(a), (b), (d) and (e) or an entity that is referred to in section 5 of the Act and that is prescribed undertakes to provide to a foreign financial institution services such as international electronic funds transfers, cash management, cheque clearing and any prescribed services.Footnote 13 (relation de correspondant bancaire)

Country of residence

The country where an individual has lived continuously for 12 months or more. The individual must have a dwelling in the country concerned. For greater certainty, a person only has one country of residence no matter how many dwelling places they may have, inside or outside of that country. (pays de résidence)

Credit card acquiring business

A credit card acquiring business is a financial entity that has an agreement with a merchant to provide the following services:

enabling a merchant to accept credit card payments by cardholders for goods and services and to receive payments for credit card purchases;
processing services, payment settlements and providing point-of-sale equipment (such as computer terminals); and
providing other ancillary services to the merchant.

(entreprise d’acquisition de cartes de crédit)
Credit union central

A central cooperative credit society, as defined in section 2 of the Cooperative Credit Associations Act, or a credit union central or a federation of credit unions or caisses populaires that is regulated by a provincial Act other than one enacted by the legislature of Quebec.Footnote 14 (centrale de caisses de crédit)

Current

In respect of a document or source of information that is used to verify identity, is up to date, and, in the case of a government-issued photo identification document, must not have been expired when the ID was verified. (à jour)

Dealer in precious metals and stones

A person or entity that, in the course of their business activities, buys or sells precious metals, precious stones or jewellery. It includes a department or an agent of Her Majesty in right of Canada or an agent or mandatary of Her Majesty in right of a province when the department or the agent or mandatary carries out the activity, referred to in subsection 65(1), of selling precious metals to the public.Footnote 15 (négociant en métaux précieux et pierres précieuses)

Deferred profit sharing plan

Has the same meaning as in subsection 248(1) of the Income Tax Act.Footnote 16 (régime de participation différée aux bénéfices)

Deposit slip

A record that sets out:Footnote 17

(a) the date of the deposit;
(b) the name of the person or entity that makes the deposit;
(c) the amount of the deposit and of any part of it that is made in cash;
(d) the method by which the deposit is made; and
(e) the number of the account into which the deposit is made and the name of each account holder.

(relevé de dépôt)
Directing Services

A business is directing services at persons or entities in Canada if at least one of the following applies:

The business’s marketing or advertising is directed at persons or entities located in Canada;
The business operates a “.ca” domain name; or,
The business is listed in a Canadian business directory.

Additional criteria may be considered, such as if the business describes its services being offered in Canada or actively seeks feedback from persons or entities in Canada.

[Read More] […]

Read More…

Canada’s AML/ATF regime is stronger today with the coming-into-force of the regulatory amendments.

Regulatory amendments in force as of June 1, 2021

You are here:

Home
Regulatory amendments in force as of June 1, 2021

The changes to the Regulations made under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act announced in the Canada Gazette in July 2019 and June 2020 are in force as of June 1, 2021. These changes help strengthen Canada’s anti-money laundering and anti-terrorist financing regime by closing certain gaps, such as those stemming from technological advances.
At a high level, the changes include, but are not limited to, the following:

Obligations for transactions involving virtual currencies, including to report the receipt of a large amount of virtual currency and to follow associated know-your-client obligations;
The requirement for certain businesses that initiate or finally receive electronic funds transfers to report instead of the businesses that are intermediaries in these transfers, however the intermediaries must keep records of the transactions;
The requirement for new information fields to be reported (for example, online identifiers, email addresses, etc.);
The expansion to all reporting entity sectors of the requirement to obtain and take reasonable measures to confirm the accuracy of information obtained on the beneficial owners of a corporation, trust or other entity that is a client;
The requirement to aggregate on the beneficiary when applying the 24-hour rule to certain transactions;
The requirement for financial entities to treat prepaid payment products and related accounts similarly to bank accounts;
The expansion to all reporting entity sectors of the requirement to determine whether a client is a politically exposed person or the head of an international organization in certain circumstances;
The requirement for the life insurance sector to keep records and verify the identity of a beneficiary before a payout; and
New methods that reporting entities can use to verify the identity of person and entities.

FINTRAC’s guidance has been updated to reflect these requirements.  
FINTRAC expects reporting entities (REs) to comply with the amendments, but understands that many may face challenges in meeting these obligations. For further information on how FINTRAC will assess compliance with the new requirements, please consult the May 18, 2021 Notice on the assessment of obligations coming into force on June 1, 2021. Furthermore, additional flexibilities that are being provided by FINTRAC on an exceptional and transitionary basis can be found by consulting the November 16, 2020 Notice on forthcoming regulatory amendments and flexibility.
FINTRAC would like to thank the businesses that have provided input on the implementation of the new requirements and on the related guidance. With their feedback, FINTRAC has been able to create better products that support our common goal of having a strong anti-money laundering and anti-terrorist financing regime that keeps our financial system secure.

[Read More] […]

Read More…

FINTRAC has published guidance on reporting large virtual currency transactions.

Accountant

A chartered accountant, a certified general accountant, a certified management accountant or, if applicable, a chartered professional accountant.Footnote 1 (comptable)

Accounting firm

An entity that is engaged in the business of providing accounting services to the public and has at least one partner, employee or administrator that is an accountant.Footnote 2 (cabinet d’expertise comptable)

Act

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).Footnote 3 (la Loi)

Administrative monetary penalties (AMPs)

Civil penalties that may be issued to reporting entities by FINTRAC for non-compliance with the PCMLTFA and associated Regulations. (pénalité administrative pécuniaire [PAP])

Affiliate

An entity is affiliated with another entity if one of them is wholly owned by the other, if both are wholly owned by the same entity or if their financial statements are consolidated.Footnote 4 (entité du même groupe)

Annuity

Has the same meaning as in subsection 248(1) of the Income Tax ActFootnote 5 (rente)

As soon as practicable

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. The completion and submission of the STR should take priority over other tasks. In this context, the report must be completed promptly, taking into account the facts and circumstances of the situation. While some delay is permitted, it must have a reasonable explanation. (aussitôt que possible)

Attempted transaction

Occurs when an individual or entity starts to conduct a transaction that is not completed. For example, a client or a potential client walks away from conducting a $10,000 cash deposit. (opération tentée)

Authentic

In respect of verifying identity, means genuine and having the character of an original, credible, and reliable document or record. (authentique)

Authorized person

A person who is authorized under subsection 45(2).Footnote 6 (personne autorisée)

Authorized user

A person who is authorized by a holder of a prepaid payment product account to have electronic access to funds or virtual currency available in the account by means of a prepaid payment product that is connected to it.Footnote 7 (utilisateur autorisé)

Beneficial Owner(s)

Beneficial owners are the individuals who are the trustees, and known beneficiaries and settlors of a trust, or who directly or indirectly own or control 25% or more of i) the shares of a corporation or ii) an entity other than a corporation or trust, such as a partnership. The ultimate beneficial owner(s) cannot be another corporation or entity; it must be the actual individual(s) who owns or controls the entity. (bénéficiaire effectif)

Beneficiary

A beneficiary is the individual or entity that will benefit from a transaction or to which the final remittance is made. (bénéficiaire)

Branch

A branch is a part of your business at a distinct location other than your main office. (succursale)

British Columbia notary corporation

An entity that carries on the business of providing notary services to the public in British Columbia in accordance with the Notaries Act, R.S.B.C. 1996, c. 334.Footnote 8 (société de notaires de la Colombie-Britannique)

British Columbia notary public

A person who is a member of the Society of Notaries Public of British Columbia.Footnote 9 (notaire public de la Colombie-Britannique)

Cash

Coins referred to in section 7 of the Currency Act, notes issued by the Bank of Canada under the Bank of Canada Act that are intended for circulation in Canada or coins or bank notes of countries other than Canada.Footnote 10 (espèces)

Casino

A government, organization, board or operator that is referred to in any of paragraphs 5(k) to (k.3) of the Act.Footnote 11 (casino)

Certified translator

An individual that holds the title of professional certified translator granted by a Canadian provincial or territorial association or body that is competent under Canadian provincial or territorial law to issue such certification. (traducteur agréé)

Clarification request

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 request is usually sent by email. (demande de précisions)

Client

A person or entity that engages in a financial transaction with another person or entity.Footnote 12 (client)

Client identification information

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. (renseignements d’identification du client)

Competent authority

For the purpose of the criminal record check submitted with an application for registration, a competent authority is any person or organization that has the legally delegated or invested authority, capacity, or power to issue criminal record checks. (autorité compétente)

Completed transaction

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. (opération effectuée)

Compliance officer

The individual, with the necessary authority, that you appoint to be responsible for the implementation of your compliance program. (agent de conformité)

Compliance policies and procedures

Written methodology outlining the obligations applicable to your business under the PCMLTFA and its associated Regulations and the corresponding processes and controls you put in place to address your obligations. (politiques et procédures de conformité)

Compliance program

All elements (compliance officer, policies and procedures, risk assessment, training program, effectiveness review) that you, as a reporting entity, are legally required to have under the PCMLTFA and its associated Regulations to ensure that you meet all your obligations. (programme de conformité)

Context

Clarifies a set of circumstances or provides an explanation of a situation or financial transaction that can be understood and assessed. (contexte)

Correspondent banking relationship

A relationship created by an agreement or arrangement under which an entity referred to in any of paragraphs 5(a), (b), (d) and (e) or an entity that is referred to in section 5 of the Act and that is prescribed undertakes to provide to a foreign financial institution services such as international electronic funds transfers, cash management, cheque clearing and any prescribed services.Footnote 13 (relation de correspondant bancaire)

Country of residence

The country where an individual has lived continuously for 12 months or more. The individual must have a dwelling in the country concerned. For greater certainty, a person only has one country of residence no matter how many dwelling places they may have, inside or outside of that country. (pays de résidence)

Credit card acquiring business

A credit card acquiring business is a financial entity that has an agreement with a merchant to provide the following services:

enabling a merchant to accept credit card payments by cardholders for goods and services and to receive payments for credit card purchases;
processing services, payment settlements and providing point-of-sale equipment (such as computer terminals); and
providing other ancillary services to the merchant.

(entreprise d’acquisition de cartes de crédit)
Credit union central

A central cooperative credit society, as defined in section 2 of the Cooperative Credit Associations Act, or a credit union central or a federation of credit unions or caisses populaires that is regulated by a provincial Act other than one enacted by the legislature of Quebec.Footnote 14 (centrale de caisses de crédit)

Current

In respect of a document or source of information that is used to verify identity, is up to date, and, in the case of a government-issued photo identification document, must not have been expired when the ID was verified. (à jour)

Dealer in precious metals and stones

A person or entity that, in the course of their business activities, buys or sells precious metals, precious stones or jewellery. It includes a department or an agent of Her Majesty in right of Canada or an agent or mandatary of Her Majesty in right of a province when the department or the agent or mandatary carries out the activity, referred to in subsection 65(1), of selling precious metals to the public.Footnote 15 (négociant en métaux précieux et pierres précieuses)

Deferred profit sharing plan

Has the same meaning as in subsection 248(1) of the Income Tax Act.Footnote 16 (régime de participation différée aux bénéfices)

Deposit slip

A record that sets out:Footnote 17

(a) the date of the deposit;
(b) the name of the person or entity that makes the deposit;
(c) the amount of the deposit and of any part of it that is made in cash;
(d) the method by which the deposit is made; and
(e) the number of the account into which the deposit is made and the name of each account holder.

(relevé de dépôt)
Directing Services

A business is directing services at persons or entities in Canada if at least one of the following applies:

The business’s marketing or advertising is directed at persons or entities located in Canada;
The business operates a “.ca” domain name; or,
The business is listed in a Canadian business directory.

Additional criteria may be considered, such as if the business describes its services being offered in Canada or actively seeks feedback from persons or entities in Canada.

[Read More] […]

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Canada’s AML/ATF regime is stronger today with the coming-into-force of the regulatory amendments.

Regulatory amendments in force as of June 1, 2021

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Regulatory amendments in force as of June 1, 2021

The changes to the Regulations made under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act announced in the Canada Gazette in July 2019 and June 2020 are in force as of June 1, 2021. These changes help strengthen Canada’s anti-money laundering and anti-terrorist financing regime by closing certain gaps, such as those stemming from technological advances.
At a high level, the changes include, but are not limited to, the following:

Obligations for transactions involving virtual currencies, including to report the receipt of a large amount of virtual currency and to follow associated know-your-client obligations;
The requirement for certain businesses that initiate or finally receive electronic funds transfers to report instead of the businesses that are intermediaries in these transfers, however the intermediaries must keep records of the transactions;
The requirement for new information fields to be reported (for example, online identifiers, email addresses, etc.);
The expansion to all reporting entity sectors of the requirement to obtain and take reasonable measures to confirm the accuracy of information obtained on the beneficial owners of a corporation, trust or other entity that is a client;
The requirement to aggregate on the beneficiary when applying the 24-hour rule to certain transactions;
The requirement for financial entities to treat prepaid payment products and related accounts similarly to bank accounts;
The expansion to all reporting entity sectors of the requirement to determine whether a client is a politically exposed person or the head of an international organization in certain circumstances;
The requirement for the life insurance sector to keep records and verify the identity of a beneficiary before a payout; and
New methods that reporting entities can use to verify the identity of person and entities.

FINTRAC’s guidance has been updated to reflect these requirements.  
FINTRAC expects reporting entities (REs) to comply with the amendments, but understands that many may face challenges in meeting these obligations. For further information on how FINTRAC will assess compliance with the new requirements, please consult the May 18, 2021 Notice on the assessment of obligations coming into force on June 1, 2021. Furthermore, additional flexibilities that are being provided by FINTRAC on an exceptional and transitionary basis can be found by consulting the November 16, 2020 Notice on forthcoming regulatory amendments and flexibility.
FINTRAC would like to thank the businesses that have provided input on the implementation of the new requirements and on the related guidance. With their feedback, FINTRAC has been able to create better products that support our common goal of having a strong anti-money laundering and anti-terrorist financing regime that keeps our financial system secure.

[Read More] […]

Read More…

Canada’s AML/ATF regime is stronger today with the coming-into-force of the regulatory amendments.

Regulatory amendments in force as of June 1, 2021

You are here:

Home
Regulatory amendments in force as of June 1, 2021

The changes to the Regulations made under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act announced in the Canada Gazette in July 2019 and June 2020 are in force as of June 1, 2021. These changes help strengthen Canada’s anti-money laundering and anti-terrorist financing regime by closing certain gaps, such as those stemming from technological advances.
At a high level, the changes include, but are not limited to, the following:

Obligations for transactions involving virtual currencies, including to report the receipt of a large amount of virtual currency and to follow associated know-your-client obligations;
The requirement for certain businesses that initiate or finally receive electronic funds transfers to report instead of the businesses that are intermediaries in these transfers, however the intermediaries must keep records of the transactions;
The requirement for new information fields to be reported (for example, online identifiers, email addresses, etc.);
The expansion to all reporting entity sectors of the requirement to obtain and take reasonable measures to confirm the accuracy of information obtained on the beneficial owners of a corporation, trust or other entity that is a client;
The requirement to aggregate on the beneficiary when applying the 24-hour rule to certain transactions;
The requirement for financial entities to treat prepaid payment products and related accounts similarly to bank accounts;
The expansion to all reporting entity sectors of the requirement to determine whether a client is a politically exposed person or the head of an international organization in certain circumstances;
The requirement for the life insurance sector to keep records and verify the identity of a beneficiary before a payout; and
New methods that reporting entities can use to verify the identity of person and entities.

FINTRAC’s guidance has been updated to reflect these requirements.  
FINTRAC expects reporting entities (REs) to comply with the amendments, but understands that many may face challenges in meeting these obligations. For further information on how FINTRAC will assess compliance with the new requirements, please consult the May 18, 2021 Notice on the assessment of obligations coming into force on June 1, 2021. Furthermore, additional flexibilities that are being provided by FINTRAC on an exceptional and transitionary basis can be found by consulting the November 16, 2020 Notice on forthcoming regulatory amendments and flexibility.
FINTRAC would like to thank the businesses that have provided input on the implementation of the new requirements and on the related guidance. With their feedback, FINTRAC has been able to create better products that support our common goal of having a strong anti-money laundering and anti-terrorist financing regime that keeps our financial system secure.

[Read More] […]

Read More…

FINTRAC has published guidance on reporting large virtual currency transactions.

Accountant

A chartered accountant, a certified general accountant, a certified management accountant or, if applicable, a chartered professional accountant.Footnote 1 (comptable)

Accounting firm

An entity that is engaged in the business of providing accounting services to the public and has at least one partner, employee or administrator that is an accountant.Footnote 2 (cabinet d’expertise comptable)

Act

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).Footnote 3 (la Loi)

Administrative monetary penalties (AMPs)

Civil penalties that may be issued to reporting entities by FINTRAC for non-compliance with the PCMLTFA and associated Regulations. (pénalité administrative pécuniaire [PAP])

Affiliate

An entity is affiliated with another entity if one of them is wholly owned by the other, if both are wholly owned by the same entity or if their financial statements are consolidated.Footnote 4 (entité du même groupe)

Annuity

Has the same meaning as in subsection 248(1) of the Income Tax ActFootnote 5 (rente)

As soon as practicable

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. The completion and submission of the STR should take priority over other tasks. In this context, the report must be completed promptly, taking into account the facts and circumstances of the situation. While some delay is permitted, it must have a reasonable explanation. (aussitôt que possible)

Attempted transaction

Occurs when an individual or entity starts to conduct a transaction that is not completed. For example, a client or a potential client walks away from conducting a $10,000 cash deposit. (opération tentée)

Authentic

In respect of verifying identity, means genuine and having the character of an original, credible, and reliable document or record. (authentique)

Authorized person

A person who is authorized under subsection 45(2).Footnote 6 (personne autorisée)

Authorized user

A person who is authorized by a holder of a prepaid payment product account to have electronic access to funds or virtual currency available in the account by means of a prepaid payment product that is connected to it.Footnote 7 (utilisateur autorisé)

Beneficial Owner(s)

Beneficial owners are the individuals who are the trustees, and known beneficiaries and settlors of a trust, or who directly or indirectly own or control 25% or more of i) the shares of a corporation or ii) an entity other than a corporation or trust, such as a partnership. The ultimate beneficial owner(s) cannot be another corporation or entity; it must be the actual individual(s) who owns or controls the entity. (bénéficiaire effectif)

Beneficiary

A beneficiary is the individual or entity that will benefit from a transaction or to which the final remittance is made. (bénéficiaire)

Branch

A branch is a part of your business at a distinct location other than your main office. (succursale)

British Columbia notary corporation

An entity that carries on the business of providing notary services to the public in British Columbia in accordance with the Notaries Act, R.S.B.C. 1996, c. 334.Footnote 8 (société de notaires de la Colombie-Britannique)

British Columbia notary public

A person who is a member of the Society of Notaries Public of British Columbia.Footnote 9 (notaire public de la Colombie-Britannique)

Cash

Coins referred to in section 7 of the Currency Act, notes issued by the Bank of Canada under the Bank of Canada Act that are intended for circulation in Canada or coins or bank notes of countries other than Canada.Footnote 10 (espèces)

Casino

A government, organization, board or operator that is referred to in any of paragraphs 5(k) to (k.3) of the Act.Footnote 11 (casino)

Certified translator

An individual that holds the title of professional certified translator granted by a Canadian provincial or territorial association or body that is competent under Canadian provincial or territorial law to issue such certification. (traducteur agréé)

Clarification request

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 request is usually sent by email. (demande de précisions)

Client

A person or entity that engages in a financial transaction with another person or entity.Footnote 12 (client)

Client identification information

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. (renseignements d’identification du client)

Competent authority

For the purpose of the criminal record check submitted with an application for registration, a competent authority is any person or organization that has the legally delegated or invested authority, capacity, or power to issue criminal record checks. (autorité compétente)

Completed transaction

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. (opération effectuée)

Compliance officer

The individual, with the necessary authority, that you appoint to be responsible for the implementation of your compliance program. (agent de conformité)

Compliance policies and procedures

Written methodology outlining the obligations applicable to your business under the PCMLTFA and its associated Regulations and the corresponding processes and controls you put in place to address your obligations. (politiques et procédures de conformité)

Compliance program

All elements (compliance officer, policies and procedures, risk assessment, training program, effectiveness review) that you, as a reporting entity, are legally required to have under the PCMLTFA and its associated Regulations to ensure that you meet all your obligations. (programme de conformité)

Context

Clarifies a set of circumstances or provides an explanation of a situation or financial transaction that can be understood and assessed. (contexte)

Correspondent banking relationship

A relationship created by an agreement or arrangement under which an entity referred to in any of paragraphs 5(a), (b), (d) and (e) or an entity that is referred to in section 5 of the Act and that is prescribed undertakes to provide to a foreign financial institution services such as international electronic funds transfers, cash management, cheque clearing and any prescribed services.Footnote 13 (relation de correspondant bancaire)

Country of residence

The country where an individual has lived continuously for 12 months or more. The individual must have a dwelling in the country concerned. For greater certainty, a person only has one country of residence no matter how many dwelling places they may have, inside or outside of that country. (pays de résidence)

Credit card acquiring business

A credit card acquiring business is a financial entity that has an agreement with a merchant to provide the following services:

enabling a merchant to accept credit card payments by cardholders for goods and services and to receive payments for credit card purchases;
processing services, payment settlements and providing point-of-sale equipment (such as computer terminals); and
providing other ancillary services to the merchant.

(entreprise d’acquisition de cartes de crédit)
Credit union central

A central cooperative credit society, as defined in section 2 of the Cooperative Credit Associations Act, or a credit union central or a federation of credit unions or caisses populaires that is regulated by a provincial Act other than one enacted by the legislature of Quebec.Footnote 14 (centrale de caisses de crédit)

Current

In respect of a document or source of information that is used to verify identity, is up to date, and, in the case of a government-issued photo identification document, must not have been expired when the ID was verified. (à jour)

Dealer in precious metals and stones

A person or entity that, in the course of their business activities, buys or sells precious metals, precious stones or jewellery. It includes a department or an agent of Her Majesty in right of Canada or an agent or mandatary of Her Majesty in right of a province when the department or the agent or mandatary carries out the activity, referred to in subsection 65(1), of selling precious metals to the public.Footnote 15 (négociant en métaux précieux et pierres précieuses)

Deferred profit sharing plan

Has the same meaning as in subsection 248(1) of the Income Tax Act.Footnote 16 (régime de participation différée aux bénéfices)

Deposit slip

A record that sets out:Footnote 17

(a) the date of the deposit;
(b) the name of the person or entity that makes the deposit;
(c) the amount of the deposit and of any part of it that is made in cash;
(d) the method by which the deposit is made; and
(e) the number of the account into which the deposit is made and the name of each account holder.

(relevé de dépôt)
Directing Services

A business is directing services at persons or entities in Canada if at least one of the following applies:

The business’s marketing or advertising is directed at persons or entities located in Canada;
The business operates a “.ca” domain name; or,
The business is listed in a Canadian business directory.

Additional criteria may be considered, such as if the business describes its services being offered in Canada or actively seeks feedback from persons or entities in Canada.

[Read More] […]

Read More…

Canada’s AML/ATF regime is stronger today with the coming-into-force of the regulatory amendments.

Regulatory amendments in force as of June 1, 2021

You are here:

Home
Regulatory amendments in force as of June 1, 2021

The changes to the Regulations made under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act announced in the Canada Gazette in July 2019 and June 2020 are in force as of June 1, 2021. These changes help strengthen Canada’s anti-money laundering and anti-terrorist financing regime by closing certain gaps, such as those stemming from technological advances.
At a high level, the changes include, but are not limited to, the following:

Obligations for transactions involving virtual currencies, including to report the receipt of a large amount of virtual currency and to follow associated know-your-client obligations;
The requirement for certain businesses that initiate or finally receive electronic funds transfers to report instead of the businesses that are intermediaries in these transfers, however the intermediaries must keep records of the transactions;
The requirement for new information fields to be reported (for example, online identifiers, email addresses, etc.);
The expansion to all reporting entity sectors of the requirement to obtain and take reasonable measures to confirm the accuracy of information obtained on the beneficial owners of a corporation, trust or other entity that is a client;
The requirement to aggregate on the beneficiary when applying the 24-hour rule to certain transactions;
The requirement for financial entities to treat prepaid payment products and related accounts similarly to bank accounts;
The expansion to all reporting entity sectors of the requirement to determine whether a client is a politically exposed person or the head of an international organization in certain circumstances;
The requirement for the life insurance sector to keep records and verify the identity of a beneficiary before a payout; and
New methods that reporting entities can use to verify the identity of person and entities.

FINTRAC’s guidance has been updated to reflect these requirements.  
FINTRAC expects reporting entities (REs) to comply with the amendments, but understands that many may face challenges in meeting these obligations. For further information on how FINTRAC will assess compliance with the new requirements, please consult the May 18, 2021 Notice on the assessment of obligations coming into force on June 1, 2021. Furthermore, additional flexibilities that are being provided by FINTRAC on an exceptional and transitionary basis can be found by consulting the November 16, 2020 Notice on forthcoming regulatory amendments and flexibility.
FINTRAC would like to thank the businesses that have provided input on the implementation of the new requirements and on the related guidance. With their feedback, FINTRAC has been able to create better products that support our common goal of having a strong anti-money laundering and anti-terrorist financing regime that keeps our financial system secure.

[Read More] […]

Read More…