Monthly Suppression of Terrorism and Canadian Sanctions Reporting Obligations
Registrants and exempt international dealers and advisers have certain obligations under federal laws to provide specified monthly reports relating to terrorist financing and United Nations Act sanctions on certain countries to the principal regulator or body that supervises or regulates the registrant or exempt international firm under provincial law.
The regulator, in turn, forwards information derived from these reports to the Office of the Superintendent of Financial Institutions (OSFI).
Further information on these laws and the reporting obligations can be found in Staff Notice 31-352 Monthly Suppression of Terrorism and Canadian Sanctions Reporting Obligations and on the OSFI website.
Since federal reporting requirements may be added, modified or repealed at any time, market participants should refer to the new CSA Guide to Monthly Suppression of Terrorism and Canadian Sanctions Reporting that includes a list of the current legislative provisions in relation to the federal reporting.
Types of Required Reporting
There are two types of reporting to their principal regulator required of registrants, exempt international dealers, and international advisers:
- Reporting against names listed under federal laws relating to terrorist financing
- Providing an updated standardized reporting form and guide that provides summary information on the laws which impose the monthly reporting requirements on registrants
The CSA has consolidated these two types of reports into a single form (Consolidated Reporting Form) that can be used for reporting by email to the appropriate CSA member (i.e., the registrant's principal regulator).
New consolidated forms can be accessed here.
Monthly Suppression of Terrorism and Canadian Sanctions Reporting Obligations FAQs
The new reporting requirements are effective July 30, 2010
Each report should cover a calendar month. For example, May 2010's report will cover the period from May 1, 2010 to May 31, 2010.
You must file each month's report by the 14th of the following month. For example, you must file the May 2020 report by June 14, 2020.
- On at least a monthly basis, the chief compliance officer or designated person at the registered firm must review the lists available at the Office of the Superintendent of Financial Institutions' (OSFI) website at www.osfi-bsif.gc.ca. There are separate lists for those under the Suppression of Terrorism and those under the United Nations Act Sanctions.
- After reviewing the OSFI lists, the chief compliance officer must file, either a NIL or YES (positive) report for both lists to the BCSC.
- Access the report (consolidated) from BCSC Suppression of Terrorism and UN Sanctions Act Report.
- Each report should cover a full month period and be filed no later than the 14th of the following month. For example, a report covering May 1, 2020 to May 31, 2020, must be filed by June 14, 2010.
- For firms with affiliates, only one form is required to be filed to the BCSC. For example, a portfolio manager with a mutual fund subsidiary would file one report with the names of both entities listed in the Name field.
- Reports can be submitted to the BCSC by fax at (604)899-6558 or by email to firstname.lastname@example.org.
- Electronic signatures are acceptable if emailing a reports: faxed reports require a written signature
- If a registered firm is submitting a YES (positive) report of a listed Entity or Designated Person, the firm must also submit the report/s to the Royal Canadian Mounted Police (RCMP) and the Canadian Security Intelligence Service (CSIS):
Anti-terrorist Financing Group
Unclassified fax: (613) 993-9474
Unclassified fax: (613) 231-0266
- For a Yes (positive) Suppression of Terrorism Report (the first report), firms must also file a Terrorist Property Report to the Financial Transactions and Reports Analysis Centre (FINTRAC) of Canada. Instructions for filing this report are available on FINTRAC's website.