FAQ
  • Q76. As a sole practicing attorney firm and all the firm’s finances are done either by way of EFT’s or by bank transfers, should I register for the cash threshold report process?

    Cash does not include negotiable instruments as defined in the FIC Act. It also does not include a transfer of funds by means of bank cheque, bank draft, electronic funds transfer, wire transfer or other written order that does not involve the physical transfer of cash, and these methods of transferring funds will not be covered by the cash threshold reporting obligation under section 28 of the FIC Act.

  • Q77. How do I register to file a cash threshold report?

    The Centre has issued a Public Compliance Communication no. 5 which provides detailed information on how to register –

    this information is available here
  • Q78. Who is the Section 43 officer? I’m short staffed and I am the Director can I just appoint anyone to be my Section 43 Officer even if she is a PA?

    • The employees of the accountable institution with the provisions of the FIC Act and the internal rules applicable to them
    • And the accountable institution with its obligations under the FIC Act.

    This would require that the officer is a person at senior level who has access to the entire accountable institution and can implement the necessary changes, processes and procedures to ensure compliance. The officers’ appointment should be ratified by the board and his/her duties set out in an appointment letter.
  • Q79. If a motor vehicle dealer is registered and has login credentials, will the CTR’s be pre-populated with the dealer’s standard information?

    Yes

  • Q80. What measures will a Motor Vehicle Dealer be required to take to determine whether Cash was received by the Bank on behalf of the Dealer?

    Institutions that have a 'bucket account' or agent relationship should jointly explore solutions to the challenge of ensuring that CTR reports are submitted as required. For instance; ensuring that the bank informs the dealer of a cash deposit by virtue of a bank statement, proof of deposit or other acceptable means.

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