A repo of Anti-Money Laundering (AML) and Counter Terrorist Financial (CTF) compliance jargon.
Greetings AML Nerds, AML Haters and everyone in between! We (the team at Outlier) have put together this repo to document, clarify and grow the insane amount of acronyms, definitions and other related jargon that exists. Please feel free to submit Pull Requests for additional definitions where you do, or more importantly don't, know the answer.
This has been designed with a North American focus, but if you are so inclined to provide European, Asian or Moon related PRs, we can evolve this repo into something really powerful.
The Association of Certified Anti-Money Laundering Specialists. ACAMS is the largest international membership organization dedicated to advancing the professional knowledge, skills and experience of those dedicated to the detection and prevention of money laundering around the world, and to promote the development and implementation of sound anti-money laundering policies and procedures.
Association of Certified Financial Crime Specialists
Autorite's canadiennes en valeurs mobilieres
Civil penalties that may be issued to reporting entities by FINTRAC for non-compliance with the PCMLTFA and related regulations.
http://www.fintrac-canafe.gc.ca/pen/2-eng.asp
An entity is affiliated with another financial entity (Bank, Credit Union, Securities Dealer) 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. NOTE: This does not apply to an MSB or DPMS
A individual or entity that a regulated entity may rely on to provide services on its behalf including client identification. A written agreement is required to ensure the responsibilities are clearly stated.
Autorité des marchés financiers
Anti-Money Laundering
Administrative Monetary Penalties
Advance Notice of Proposed Rule Making - An ANPRM is a published notice in the Federal Register used by the agency to test out a proposal or solicit ideas before it drafts its Notice of Proposed Rulemaking. An agency is not required to publish an ANPRM but may choose to do so.
Actions taken to detect, deter and prevent money laundering from occurring through our business.
A time period that falls in-between immediately and as soon as possible within which a suspicious transaction report (STR) be submitted to FINTRAC. In this context, the report must be completed promptly, taking into account the facts and circumstances of the situation. While some amount of delay is permitted, it must have a reasonable explanation. The completion and submission of the report should take priority over other tasks.
The prescribed methods to identify individuals and confirm the existence of entities.
http://www.fintrac-canafe.gc.ca/guidance-directives/client-clientele/Guide11/11-eng.asp
Attempted Suspicious Transaction Report
Anti-Terrorist Financing (this means the same thing as Counter Terrorist Financing and is often used interchangeably).
Occurs when an individual initiates a transaction and it does not result in the movement of funds or purchase of an asset because the transaction is not completed. For example, a potential client walks away from conducting a $10,000 cash deposit because they do not want to provide their identification.
http://www.fintrac-canafe.gc.ca/guidance-directives/transaction-operation/Guide2/2-eng.asp
In respect of a government-issued photo identification document that is used to verify identity, is genuine and has the character of an original, credible, and reliable document issued by the competent authority (federal, provincial, territorial government).
The Autorité des marchés financiers is the organisation responsible for financial regulation in the Canadian province of Québec. It regulates the province's financial markets and provides assistance to consumers of financial products and services.
https://lautorite.qc.ca/en/general-public/
A U.S. law requiring financial institutions in the United States to assist U.S. government agencies in detecting and preventing money laundering.
https://www.ffiec.gov/bsa_aml_infobase/pages_manual/manual_online.htm
Beneficial owners are the actual 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 a corporation or an entity other than a corporation or trust, such as a partnership. The ultimate beneficial owners cannot be another corporation or entity; they must be the actual individuals who are the owners or controllers of the entity.
http://www.fintrac-canafe.gc.ca/guidance-directives/client-clientele/bor-eng.asp
A beneficiary is the individual or entity who will ultimately benefit from a transaction and be the final recipient of the funds.
Bank Secrecy Act
A business relationship is a relationship established between you, as a reporting entity, and a client to conduct financial transactions or provide services related to those transactions.
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Account-based business relationship: You are automatically in a business relationship with a client that holds an account with you. A business relationship begins as soon as you open an account for a client. Under the business relationship you must consider all transactions and activities relating to that account, as well as any other accounts that the client might have with you.
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Non-account-based business relationship: If a person or entity does not have an account with you, a business relationship is formed once the customer has conducted two transactions or activities for which you have to:
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verify the identity of the individual; or
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confirm the existence of the entity.
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http://www.fintrac-canafe.gc.ca/guidance-directives/client-clientele/brr-eng.asp
See Canadian Anti-Fraud Centre
https://www.antifraudcentre-centreantifraude.ca/
Chief Anti-Money Laundering Officer.
Certified Anti-Money Laundering Specialist Certification designation from ACAMS.
https://www.acams.org/earn-the-aml-certification-gold-standard/
The Canadian Anti-Fraud Centre collects information on fraud and identity theft.They provide information on past and current scams affecting Canadians. If you think you're a victim of fraud, report it!
https://www.antifraudcentre-centreantifraude.ca/
Customer Due Diligence
Certified Financial Crime Specialist designation from ACFCS.
https://www.acfcs.org/page/certification
Is a form of check fraud, involving taking advantage of the float to make use of non-existent funds in a checking or other bank account. In this way, instead of being used as a negotiable instrument, checks are misused as a form of unauthorized credit.
https://en.wikipedia.org/wiki/Check_kiting
Customer Identification Program
A clarification request is a method used to communicate with money services businesses when FINTRAC needs more information about their registration form. This request is usually sent by email.
This is a KYC record for a customer that is an entity or organization.
Civil Monetary Penalty
The individual you appoint to be responsible for the implementation of your compliance program. Your compliance officer should have the authority and the resources necessary to discharge his or her responsibilities effectively.
All elements that you, as a reporting entity, are legally required to have under the PCMLTFA and associated Regulations to ensure that you meet all of your reporting, record keeping, client identification, and know-your-client requirements.
http://www.fintrac-canafe.gc.ca/guidance-directives/compliance-conformite/Guide4/4-eng.asp
Clarifies a set of circumstances or provides an explanation of a situation or financial transaction that can be understood and assessed.
Actions taken to detect, deter and prevent terrorist financing from occurring through our business.
See Canadian Securities Exchange
Counter Terrorist Financing / Combating the Financing of Terrorism
Currency Transaction Report
A report that is filed with FinCEN for each transaction of more than $USD 10,000 in cash, whether in a single transaction or multiple currency transactions totaling more than $10,000.
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.
Policies, procedures, and controls used to identify individuals or entities that match a baseline for the account activity related to expected transactions.
United States requirement for regulated entities under the provision of the USA Patriot Act/Bank Secrecy Act(BSA) that need to verify the identity (KYC) of individuals or entities wishing to conduct financial transactions with them.
https://www.occ.gov/news-issuances/news-releases/2005/nr-occ-2005-42a.pdf
Convertible Virtual Currencies - as defined by the US regulator FinCen in a guidance release May 9, 2020
https://www.fincen.gov/sites/default/files/2019-05/FinCEN%20Guidance%20CVC%20FINAL%20508.pdf
With regrds to a foreign money services business (FMSB), the services offered by the person or entity take into consideration a Canadian audience (for example, needs, customs, wealth, laws, etc.).
The offence of money laundering that is extended to any type of property, regardless of its value, that is directly or indirectly associated with the proceeds of crime.
Enhanced Due Diligence
Electronic Funds Transfer
A two-year effectiveness review is an evaluation that is conducted every two years (at a minimum) to test the effectiveness of the elements of your compliance program: policies and procedures, risk assessment and ongoing training program. The review must be started no later than 24 months from the start of the previous review and completed prior to the start of the next review.
An informal network of 159 Financial Intelligence Units (FIUs)
According to FINTRAC, an electronic funds transfer (money transfer) means the transmission of instructions for the transfer of funds to or from Canada. An electronic funds transfer does not include the instructions for the transfer of funds from one place in Canada to another in Canada.
According to legislation, an electronic funds transfer means the transmission — through any electronic, magnetic or optical device, telephone instrument or computer — of instructions for the transfer of funds, other than the transfer of funds within Canada. In the case of SWIFT messages, only SWIFT MT 103 messages are included.
FINTRAC - http://www.fintrac-canafe.gc.ca/reporting-declaration/Info/rptEFT-eng.asp
PCMLTFR - https://laws-lois.justice.gc.ca/eng/regulations/SOR-2002-184/page-15.html
An electronic funds transfer report is submitted to FINTRAC upon a transmission of instructions for the transfer of CAD 10,000 or more out of or into Canada in a single transaction or in two or more transactions totaling CAD 10,000 or more made within 24 consecutive hours by or on behalf of the same individual or entity.
http://www.fintrac-canafe.gc.ca/guidance-directives/transaction-operation/Guide8A/nseft-eng.asp
Email Money Transfer
Additional measures taken in identifying and mitigating the risk posed by higher risk customers.
A secure application accessed over the internet that lets reporting entities manually enter and correct reports individually. The reports that can be submitted are:
- Suspicious Transaction Reports(STRs)
- Large Cash Transaction Reports (LCTRs)
- non-SWIFT Electronic Funds Transfer Reports (EFTIs, EFTOs)
- Casino Disbursement Reports (CDRs)
http://www.fintrac-canafe.gc.ca/reporting-declaration/Info/f2r-eng.asp
Actual events, actions, occurrences or elements that exist or are known to have happened or existed. Facts are not opinions. For example, facts surrounding a transaction or multiple transactions could include the date, time, location, amount or type of transaction or could include the account details, particular business lines, or the client’s financial history.
See Foreign Account Tax Compliance Act
Financial Action Task Force
Foreign Bank and Financial Accounts
https://bsaefiling.fincen.treas.gov/NoRegFBARFiler.html
Financial Conduct Authority
Financial Crime Country Risk
See Foreign Financial Institution
The Financial Action Task Force is an intergovernmental organization founded in 1989 on the initiative of the G7 to develop policies to combat money laundering. In 2001 its mandate expanded to include terrorism financing.
The UK regulator responsible for regulating a sector which plays a critical role in the lives of everyone in the UK and without which the modern economy could not function.
A bureau of the United States Department of the Treasury that collects and analyzes information about financial transactions in order to combat domestic and international money laundering, terrorist financing, and other financial crimes.
A central agency that is responsible for receiving, analyzing, and transmitting disclosures on suspicious transactions to the competent authorities. This can be on behalf of a geogrpahic region (Caribbean), a country (Canada) or a Company.
Canada’s financial intelligence unit and our regulator for AML and CTF. We submit reports to FINTRAC and they have the right to examine us to test our compliance with Canadian requirements. All FINTRAC correspondences and inquiries should be passed immediately to the Compliance Officer.
http://www.fintrac-canafe.gc.ca/intro-eng.asp
The Financial Crimes Enforcement Network
Dedicated to protecting investors and safeguarding market integrity in a manner that facilitates vibrant capital markets.
The Financial Transactions and Reports Analysis Centre of Canada
See Financial Industry Regulatory Authority
Financial Intelligence Unit
Fear Of Missing Out - anxiety that an exciting or interesting event may currently be happening elsewhere, often aroused by posts seen on a social media website.
Every year, under the law known as the Bank Secrecy Act, you must report certain foreign financial accounts, such as bank accounts, brokerage accounts and mutual funds, to the Treasury Department and keep certain records of those accounts. You report the accounts by filing a Report of Foreign Bank and Financial Accounts (FBAR) on FinCEN Form 114.
Generally requires that foreign financial Institutions and certain other non-financial foreign entities report on the foreign assets held by their U.S. account holders or be subject to withholding on withholdable payments.
https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca
Means that a Foreign Financial Institution has registered and agreed to adhere to the requirements set forth by FATCA.
https://www.irs.gov/businesses/corporations/irs-ffi-list-faqs
You are considered an FMSB if #all of the following criteria apply:
- You are engaged in the business of providing at least one money services business (MSB) service;
- You do not have a place of business in Canada;
- You direct your MSB services at persons or entities in Canada; and
- You provide these services to clients in Canada.
Fear, Uncertainty, and Doubt - usually evoked intentionally in order to put a competitor at a disadvantage.
The head of an international organization is a person who is either:
- the head of an international organization established by the governments of states; or
- the head of an institution established by an international organization.
http://www.fintrac-canafe.gc.ca/guidance-directives/client-clientele/Guide14/14-eng.asp
Head of an International Organization
International Consortium of Investigative Journalists
Investment Industry Regulatory Organization of Canada
Is a non-profit, national self-regulatory organization. Established through the merger of the Investment Dealers Association of Canada and Market Regulation Services Inc. on June 1, 2008, IIROC oversees all investment dealers and trading activity on debt and equity markets in Canada.
https://www.iiroc.ca/about/Pages/default.aspx
Is a form of check fraud, involving taking advantage of the float to make use of non-existent funds in a checking or other bank account. In this way, instead of being used as a negotiable instrument, checks are misused as a form of unauthorized credit.
https://en.wikipedia.org/wiki/Check_kiting
Know your customer is the process of a business verifying the identity of its clients and assessing potential risks of illegal intentions for the business relationship.
http://www.fintrac-canafe.gc.ca/guidance-directives/client-clientele/1-eng.asp
Know Your Agent (or Mandatary)
Know Your Client/Customer
Know Your Member (this is more common in the Credit Union space where customers are members of the Credit Union)
Any cash transactions valued at CAD 10,000 or more (or the equivalent in a foreign currency) that take place within the same 24 hour period for the same customer. This may include one or several transactions.
http://www.fintrac-canafe.gc.ca/reporting-declaration/Info/rptLCTR-eng.asp
A report that is filed with FINTRAC when a large cash transaction has taken place. This report must be filed with FINTRAC within 15 calendar days of the transaction. Staff are required to report large cash transactions to the Compliance Officer on the day that they occur using our internal Large Cash Transaction Reporting form.
http://www.fintrac-canafe.gc.ca/guidance-directives/transaction-operation/Guide7A/lctr-eng.asp
Large Cash Transaction Report
A listed person means anyone on a list published in the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism issued under the United Nations Act. You can consult that list of names on the Office of the Superintendent of Financial Institutions' Web site:
http://www.osfi-bsif.gc.ca/Eng/fi-if/amlc-clrpc/atf-fat/Pages/default.aspx.
A listed person includes an individual, a corporation, a trust, a partnership or fund or an unincorporated association or organization that is believed to:
- have carried out, attempted to carry out, participated in or facilitated a terrorist activity; or
- be controlled directly or indirectly by, be acting on behalf of, at the direction of, or in association with any individual or entity conducting any of the above activities.
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The authority to issue directives that require reporting entities to apply measures (which this document calls "countermeasures") to transactions originating from or destined to designated foreign jurisdictions and entities; and
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The authority to recommend that the Governor-in-Council issue regulations limiting or prohibiting reporting entities from entering into a financial transaction originating from or destined to designated foreign jurisdictions and entities.
These authorities allow the Minister of Finance to take steps to protect the integrity of Canada's financial system from foreign jurisdictions and foreign entities that are deemed to pose high risks for facilitating money laundering and terrorist financing.
https://www.fin.gc.ca/legislation/pcmltfa-lrpcfat-1-eng.asp
Money Laundering
The process of taking money obtained by committing a crime and disguising the source to make it appear legitimate. Under the Criminal Code of Canada, it is illegal to launder money or to knowingly assist in laundering money. Under the PCMLTFA and Regulations, we must take steps to be sure that our business is not used to launder money and if we suspect that money laundering may be taking place, we must report it.
http://www.fintrac-canafe.gc.ca/guidance-directives/overview-apercu/Guide1/1-eng.asp#s2
A person who transfers money acquired illegally on behalf of others. Typically, the mule is paid for services with a small part of the money transferred. Money mules are often recruited online for what they think is legitimate employment, not aware that the money they are transferring is the product of crime. The money is transferred from the mule's account to the scam operator, typically in another country.
https://en.wikipedia.org/wiki/Money_mule
A business that provides services in Canada: foreign exchange, remittance and/or issuing or redeeming monetary instruments. A business may also be considered a money service business in the province of Québec by providing any of the mentioned services and/or cheque cashing and/or the operation of automated teller machines.
http://www.fintrac-canafe.gc.ca/msb-esm/intro-eng.asp
Money Services Business
The Office of the Comptroller of the Currency (OCC) is an independent bureau of the U.S. Department of the Treasury. The OCC charters, regulates, and supervises all national banks, federal savings associations, and federal branches and agencies of foreign banks.
Office of Foreign Assets Control (US Department of the Treasury)
https://sanctionssearch.ofac.treas.gov/
Means monitoring on a periodic basis based on the risk assessment undertaken by a reporting entity of their business relationship with a client for the purpose of:
- detecting any transactions that are required to be reported to FINTRAC;
- keeping client identification information and KYC information up to date;
- reassessing the level of risk associated with the client’s transactions and activities; and
- determining whether transactions or activities are consistent with the information obtained about the client, including the risk assessment of the client.
http://www.fintrac-canafe.gc.ca/guidance-directives/client-clientele/omr-eng.asp
Ontario Secucrities Commission (OSC) administers and enforces compliance with the provisions of the Securities Act (Ontario) and the Commodity Futures Act (Ontario).
Politically Exposed Person
Politically Exposed Domestic Person
Politically Exposed Foreign Person
Purpose and Intended Nature
Personal Identifiable Information - Any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means.
Purpose and Intended Nature of a Business Relationship
A person entrusted with a prominent position that typically comes with the opportunity to influence decisions and the ability to control resources.
A PEP who is Canadian.
A PEP who is from a country other than Canada.
A judicial order that compels a person or entity to disclose records to peace officers or public officers.
It is a record that documents the purpose and intended nature of a business relationship, and includes information that would help you anticipate the types of transactions and activities your client may conduct. It should best describe your business dealings with a client.
http://www.fintrac-canafe.gc.ca/guidance-directives/client-clientele/brr-eng.asp
Risk-based Approach
Relatives and Close Associates (of PEP or HIO)
Is a step above simple suspicion and is a conclusion you reach based on an assessment of facts, context, and ML/TF indicators associated with the financial transaction. Your suspicion must be reasonable, meaning, for example, that it cannot be biased or prejudiced.
http://www.fintrac-canafe.gc.ca/guidance-directives/transaction-operation/Guide2/2-eng.asp
Means that you must take steps to collect certain information but it is not mandatory. For example, this can include doing one or more of the following:
- asking the client,
- conducting open source searches, or
- consulting commercially available information.
http://www.fintrac-canafe.gc.ca/guidance-directives/recordkeeping-document/record/msb-eng.asp
Industry specific requirements for record keeping that includes Suspicious Activity Reports, Transaction Monitoring, Large Cash Transaction record, FX transactions, Service Agreements, and KYC information.
http://www.fintrac-canafe.gc.ca/guidance-directives/recordkeeping-document/record/msb-eng.asp
Reporting entities are regulated by the PCMLTFA and its regulations, and must report certain transactions to the FINTRAC. This includes the following industries:
- Accountants;
- Agents of the Crown;
- British Columbia notaries;
- Casinos;
- Dealers in precious metals and stones;
- Financial entities;
- Life insurance companies, brokers and agents;
- Money services businesses;
- Real estate; and
- Securities dealers.
http://www.fintrac-canafe.gc.ca/re-ed/intro-eng.asp
Reasonable Grounds to Suspect
A risk assessment is an analysis of potential risks and vulnerabilities that could expose your business to money laundering/terrorist financing (ML/TF) activities. This assessment will allow you to identify your inherent risk and will assist you and those authorized to act on your behalf in developing mitigation measures to deal with these risks.
http://www.fintrac-canafe.gc.ca/guidance-directives/compliance-conformite/rba/rba-eng.asp
This is different terminology used for a Risk Assessment. They are used interchangeably.
Suspicious Activity Report
Strong customer authentication
Sanctions Compliance Program
Specially Designated Nationals And Blocked Persons List
https://www.treasury.gov/resource-center/sanctions/sdn-list/pages/default.aspx
A body that represents a profession (e.g. lawyers, notaries, other independent legal professionals or accountants), and which is made up of members from the profession and has the role of performing certain supervisory/monitoring functions of standards that are maintained by the professions. Also known as a Self-Regulatory Organisation (SRO).
Special Economic Measures Act Sanctions
http://www.osfi-bsif.gc.ca/Eng/fi-if/amlc-clrpc/snc/sema-rmes/Pages/default.aspx
In respect of an entity, means (if applicable):
- a director of the entity who is one of its full-time employees;
- the entity’s chief executive officer, chief operating officer, president, secretary, treasurer, controller, chief financial officer, chief accountant, chief auditor or chief actuary, or any person who performs any of those functions; or
- any other officer who reports directly to the entity’s board of directors, chief executive officer or chief operating officer.
Means a foreign financial institution that does not have a physical presence in a foreign country.
Is a colloquial term ((i)the slang use of “smurf” is purported to have originated to describe Colombian drug cartels’ use of armies of elderly “blue-haired” old ladies(/i)) for a group of individuals who, by breaking up large amounts into smaller transactions, seek to evade identification and/or reporting thresholds. A smurf deposits illegally gained money into bank accounts, keeps a small portion for their troubles and sends the rest to the money launderer.
https://www.investopedia.com/terms/s/smurf.asp
Self-Regulatory Body
Self-Regulatory Organisation (see Self-regulatory Body)
Sectoral Sanctions Identification List
Is a requirement of the EU Revised Directive on Payment Services (PSD2) on payment service providers within the European Economic Area.
Suspicious Transaction Report
Is the practice of executing financial transactions, such as making bank deposits, in a specific pattern, calculated to avoid triggering identification or reporting thresholds. It is worth noting that structuring is illegal in the United States.
https://en.wikipedia.org/wiki/Structuring
A report that is submitted to FinCEN when you detect a known or suspected violation of Federal law or a suspicious transaction related to a money laundering activity or a violation of the Bank Secrecy Act.
A report that is filed with FINTRAC when we have reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing. The Compliance Officer files FINTRAC reports within 30 days of the date that the transaction is deemed to be suspicious. If you suspect that a transaction is related to money laundering or terrorist financing, you must submit an unusual transaction form to the Compliance Officer on the date that the transaction occurs.
http://www.fintrac-canafe.gc.ca/guidance-directives/transaction-operation/Guide2/2-eng.asp
Is any attempt to influence or intimidate a government or the public at large through violent or illegal means or means that are intended to induce fear or panic.
Funding any act of terrorism or committing any act or omission that facilitates the funding of terrorism.
A report that is filed with several government bodies, including FINTRAC, when we believe that we may be in possession of property or funds that are owned or controlled by terrorists. The Compliance Officer files these reports as soon as possible. If you suspect that we are in possession of terrorist property or funds, you must submit a Possible Terrorist Property Report to the Compliance Officer on the same day.
http://www.fintrac-canafe.gc.ca/guidance-directives/transaction-operation/Guide5/5-eng.asp
Terrorist Financing
Any individual or entity that instructs someone to act on their behalf for a financial activity or transaction. The third party is not the person who owns or benefits from the money, or who is carrying out the activity, but rather the entity or individual who gives the instructions to handle the money or conduct a particular activity. For example, a third party may instruct someone to deposit cash into an account.
http://www.fintrac-canafe.gc.ca/guidance-directives/client-clientele/tpdr-eng.asp
Terrorist Property Report
Ultimate Beneficial Owner (See Beneficial Owner)
An internal form that is used to record the details of any transactions (attempted or completed) that is suspected of being related to money laundering or terrorist financing.
Unusual Transaction Report
In respect of a document or information that is used to verify identity, appears legitimate or authentic and does not appear to have been altered or had any information redacted. The information must also be valid according to the issuer, for example if a passport is invalid because of a name change, it is not valid for FINTRAC purposes.
Virtual asset service provider (VASP) means any natural or legal person who is not covered elsewhere under the Recommendations, and as a business conducts one or more of the following activities or operations for or on behalf of another natural or legal person:
i. exchange between virtual assets and fiat currencies;
ii. exchange between one or more forms of virtual assets;
iii. transfer of virtual assets;
iv. safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets; and
v. participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset.
In this context of virtual assets, transfer means to conduct a transaction on behalf of another natural or legal person that moves a virtual asset from one virtual asset address or account to another.
https://www.fatf-gafi.org/glossary/u-z/
A report that is filed, by non-reporting entities, when there is suspicion of money laundering or terrorist financing.
http://www.fintrac-canafe.gc.ca/reporting-declaration/vol/1-eng.asp
Voluntary Information Report
https://www15.fintrac-canafe.gc.ca/vir-drtv/public/
The ultimate goal of the regulatory regime is to enhance compliance, not to impose penalties. FINTRAC strongly encourages reporting entities to voluntarily declare their non-compliance in order to resolve the issues they identify.
http://www.fintrac-canafe.gc.ca/guidance-directives/exam-examen/vsdonc/1-eng.asp
An association of thirteen global banks which aims to develop frameworks and guidance for the management of financial crime risks, particularly with respect to KYC, AML and CTF policies.