Starting August 19, 2024, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) requires all reporting entities, including Brokers and sales representatives, to report any suspicious transactions that might involve sanctions evasion.
Understanding Sanctions
Sanctions are measures used to address international peace and security concerns, human rights violations, and significant corruption. They restrict certain activities between Canadians and foreign states, individuals, or entities. Canadian sanctions can be issued under laws like the Special Economic Measures Act (SEMA), United Nations Act (UNA), and the Justice for Victims of Corrupt Foreign Officials Act (JVCFOA).
Brokers are advised to inform their agents to review the Special Bulletin on financial activity associated with suspected sanctions evasion to ensure understanding of characteristics that may indicate that a sanction evasion is occurring in a purchase or sale transaction.
Your Responsibility
As of August 19, 2024, Brokers and sales representatives must report any transaction that may be related to sanctions evasion. This is in addition to the existing obligation to comply with Canadian sanctions.
How to Report to FINTRAC
If you suspect a transaction is related to sanctions evasion, you must report it to FINTRAC, similar to how you report other suspicious transactions. However, as CREA previously reported, FINTRAC’s Web Reporting System is currently down due to a cyber incident and may be unavailable for several months.
In the meantime, you should identify and document any suspicious transactions related to sanctions evasion and be ready to report them once the Web Reporting System is back online.
Brokers and their agents should continue to monitor FINTRAC’s website for updates.
Thank you for your attention and cooperation in this matter, which supports the FVREB’s continuing commitment to compliance.