Banks, money services businesses and casinos are among the companies that will be required to flag suspicious transactions related to sanctions evasion in addition to those involving money laundering and terrorist financing. There is no minimum monetary threshold, and the reporting requirements apply to both attempted and completed transactions.
“First, you have to have a good understanding of what the sanctions are prohibiting and then you have to have a secondary understanding of what sanctions evasion is and what it can look like in your particular industry.” Even if companies are up to speed on their new reporting requirements, filing suspicious transaction reports about suspected sanctions evasion could prove challenging for businesses with lower transaction volumes. That’s because FinTRAC is
Specifically, Ottawa is planning to establish mandatory declarations for sanctions evasion that will affect importers and exporters. The goal is to thwart trade-based financial crime, which is believed to be rampant, but there is potential to create confusion for law-abiding businesses because the specifics are still being hashed out behind closed doors.