Terrorist financing is different from money laundering. In money laundering, the money comes from illegal activity. Terrorist financing often comes from legitimate sources including charitable donations, but will be used for illegal activity. As such, it is much more difficult to identify.
Bottom Line Tip:
If you have reason to suspect that terrorists are buying or
financing one of your sales, file a Suspicious Transaction
report with FINTRAC
If you know you have terrorist property in your possession
(money, goods or an agreement giving rights to real estate),
stop the deal immediately.
Not only do you have to file a Terrorist Property report
with FINTRAC, you (and anyone else in Canada who finds
themselves in a similar situation) must immediately
inform the RCMP and CSIS. It is a criminal offence
to deal with such property.
Who is a terrorist?
The government of Canada keeps lists of people and groups that have been flagged by the international community as being associated with terrorism. If you suspect that one of your properites is being bought or financed by terrorists, you should check whether their names appear on these lists:
- www.osfi-bsif.gc.ca - click Terrorist Listings and Sanctions, then (Under Terrorism Financing, United Nations Code and Criminal Code) List of Names. This links to one list of ‘entities’ (corporations, groups, trusts, partnerships, funds, unincorporated associations, etc.) and another list of individuals
- www.psepc-sppcc.gc.ca, click National Security, then Listed Entities, then Currently Listed Entities
What do you have to do (known Terrorist Property)?
- stop the transaction
- inform the Royal Canadian Mounted Police, Financial Intelligence Branch by fax at 613-993-9474
- inform the Canadian Security Intelligence Service, Financing Unit, by fax at 613-231-0266
- file a paper ’Terrorist Property’ report with FINTRAC as soon as possible by fax or registered mail. This will include:
- information about how you know the property is owned or controlled by terrorists
- name, address and contact information for the terrorist or terrorist group
- name, adress and contact information for the person who owns or controls the property for the terrorist or terrorist group (if different from above)
- description of the property
- details of the transaction (Offer to Purchase, deposit payments, etc.)
When do you have to make the report to FINTRAC?
- ”Without delay.”
How do you file the report?
- in paper format
- print a copy of the report form from www.fintrac-canafe.gc.ca (Click Publications, then Reporting Forms, then Terrorist Property Report Forms), or call FINTRAC at 1-866-346-8722 to have a copy faxed or mailed to you
- fax the completed report to FINTRAC at 1-866-226-2346 (you will receive a receipt) or
- send the report by registered mail to FINTRAC Section A, 234 Laurier Ave. W., 24th Floor, Ottawa, ON K1P 1H7 (no receipt will be sent)
- click here for more information
Do you have to stop dealing with the buyer?
Yes. It is illegal to conduct further dealings or transactions relating to property you know is owned or controlled by known terrorists.
In its 2008 Annual Report, FINTRAC says that through its analysis of suspicious transactions, including third party deposits of cash, cheques and bank drafts, payments to credit card accounts or lines of credit, and electronic funds transfers to individuals and non-profit organizations, both in Canada and abroad, it identified several new individuals and entities as part of a known terrorist group.
See FINTRAC Annual Report 2008:
Financial Intelligence and Public Safety
available online at http://www.fintrac-canafe.gc.ca/publications/ar/2008/ar-eng.pdf