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http://www.currency-exchange.net/fintrac
Proprietary
FINTRAC Reporting Service
(Fintrac.RS)
Government
Fintrac.RS
Fintrac.RS
Client
© FBE Inc., 2001
Slide 2 of 20
Proprietary
http://www.currency-exchange.net/fintrac
FINTRAC Compliance and Reporting Requirements
Proceeds of Crime (Money Laundering) Act
received Royal Assent on June 29, 2000
Legislates detection and deterrence of money
laundering
All Canadian deposit-taking institutions are subject to
the Act, Regulations and Guidelines
Suspicious transactions reporting starts 2001-Nov-08
Requires:
Immediately report to FINTRAC all suspicious
transactions
Periodically report and keep the prescribed records
Fintrac.RS
© FBE Inc., 2001
Slide 3 of 20
http://www.currency-exchange.net/fintrac
Proprietary
FINTRAC Enforcement
Failure to implement a compliance regime:
Conviction up to 5 years + $500,000 fine
Failure to report a suspicious transaction could
lead to substantial fines and legal actions
Conviction up to 5 years + $2,000,000 fine
No minimum threshold for reporting
Required maintain effective record-keeping
system (penalty: up to 5 years imprisonment and
$500,000)
FINTRAC and external auditors should have
access to all the records in a timely fashion
Fintrac.RS
© FBE Inc., 2001
http://www.currency-exchange.net/fintrac
Slide 4 of 20
Proprietary
FINTRAC Enforcement (con’s)
Employees who reported to their superior are
exempted from being charged under the Act!!!
The ultimate executive responsibility
Need to document to discharge responsibility,
archiving is crucial
For electronic records, an electronic signature of the
signing individual “must be retained”
A special Individual Responsible for
implementing FINTRAC Compliance must be
appointed
Typically reports to the CEO or the Board
Fintrac.RS
© FBE Inc., 2001
Slide 5 of 20
http://www.currency-exchange.net/fintrac
Proprietary
Focus on Service Success!
No paper pushing, easy to use, no training is
required
Rapid approval cycle
Enhanced control, reporting and audit trail
Effectively manages executive participation; Line
management and executives are fully in control
Reduces transaction cost of backroom
administrative cycle from $54 to $8
Substantial saving in development, maintenance
and upgrades
Fintrac.RS
© FBE Inc., 2001
http://www.currency-exchange.net/fintrac
Slide 6 of 20
Proprietary
FINTRAC Processes/Forms Integrated
Suspicious/Prescribed Transaction Report
Transaction type: Account transaction;
Conducted for another entity
Conducted for other individual(s)
Large case transactions
Exceptions to large cash transactions
Electronic funds transfers
Cross-border transactions to CCRA
FINTRAC Schedules (as introduced)
1. Suspicious Transaction Report
2. Large Cash Transaction Report
3. Outgoing Electronic Funds Transfer Report Information
4. Incoming Electronic Funds Transfer Report Information
Fintrac.RS
© FBE Inc., 2001
Slide 7 of 20
http://www.currency-exchange.net/fintrac
Proprietary
A New Level of Accountability
Ensures compliance with all respective
government and corporate policies
Additional Processes/Forms Integrated
Fintrac.RS Executive Reports
Cumulative Reporting (for all participants)
Maintains User Profile and reporting relations
Tracking Inquiries/Requests Archives
Transaction Logs
Service Quality Evaluations
Also FINTRAC compliance training and support
Fintrac.RS
© FBE Inc., 2001
Slide 8 of 20
http://www.currency-exchange.net/fintrac
Proprietary
Fintrac.RS Step-by-Step
1) Suspicious/prescribed transaction report request with required
identity data (without disclosing it to the Client)
Very complex forms with dozens of input fields are required to fill for
every transaction
2)
3)
4)
5)
6)
7)
8)
Request approval by corporate management
Automatic FINTRAC compliance clearance
Transaction reporting within Fintrac.RS
Periodic corporate reporting to FINTRAC
Reporting to CCRA on the import/export of currency
Prescribed effective, safe and secure record keeping
Internal and external auditing
We also implemented numerous interactive enablers that add value to
users and lower overall service costs
Fintrac.RS
© FBE Inc., 2001
Proprietary
http://www.currency-exchange.net/fintrac
Slide 9 of 20
Fintrac.RS: (Un)Cooperating Users
?
?
Supervisor
Compliance
officer
CEO
Internal/External
Auditors
??
Suspicious/
Teller prescribed
Transaction
Report
Fintrac.RS
Fintrac
Schedules
(4)
FINTRAC
Police
PKI
Cross-border
transactions
PKI
CCRA
Client(s)
Fintrac.RS
© FBE Inc., 2001
Slide 10 of 20
http://www.currency-exchange.net/fintrac
Proprietary
Business Platform
Management framework
Integrated Government and corporate policies and
expertise - on a transactional level
Central reporting
Built in user preferences/Feedback
Exception Management
Service Quality Evaluations — user feedback for
every transaction
Archives, Transaction Logs
Fintrac.RS
© FBE Inc., 2001
Slide 11 of 20
http://www.currency-exchange.net/fintrac
Proprietary
Business Platform (con’s)
Enhanced inherently secure processes
intranet solution — same security level as for all
other legacy applications
Reporting relationships built in
Email approval notification/confirmations for every
business cycle
Prescribed by Regulations safe and secure keeping of
the records
Periodic PKI submission of cumulative records to the
Government (batch file reporting starts Jan 2002).
Fintrac.RS
© FBE Inc., 2001
Slide 12 of 20
http://www.currency-exchange.net/fintrac
Proprietary
Software Platform
Almost 1,000,000 lines of code — and growing...
Ubiquitous
W2k
Perl
.asp
Page style templates
Full compliance with Federal Government IT platform
requirements
SMTP-compatible mail server
Compliant with STD0010
RFC821, RFC1651, RFC1869, RFC1870
Fintrac.RS
© FBE Inc., 2001
http://www.currency-exchange.net/fintrac
Slide 13 of 20
Proprietary
Software Platform (con's)
XML
xHTML
Backward compatible with older browsers
Potential for structuring every field
I.e., transparent interface with financial, HR, etc.
legacy systems
SQL engine
MS Access
Implemented as ODBC/SQL compliant database
Upgradable to Oracle
Fintrac.RS
© FBE Inc., 2001
Slide 14 of 20
http://www.currency-exchange.net/fintrac
Proprietary
Software Platform (con's)
No installation on a desktop
Any browser
Any email client
Rich, fully interactive Web site
Mailing list
Stats, Search engine, Guestbook, etc., etc
Workflow engine
Policy shell
AI smarts if required to deliver policy
Full expert system shell can be built in
Fintrac.RS
© FBE Inc., 2001
http://www.currency-exchange.net/fintrac
Slide 15 of 20
Proprietary
Software Platform (con's)
Smart forms
Always change in context, workflow defined
Little writing in
Input field integrity checking, precise error messages
Integrated window warnings and password requests
Precise label links to the help file (Help in context)
Displays only relevant input/output fields
Always Web page acknowledgement at the end
Email acknowledgements after update sent to the
originator and recipients in context
Email notifications in advance (i.e., to request
updates)
Fintrac.RS
© FBE Inc., 2001
Slide 16 of 20
http://www.currency-exchange.net/fintrac
Proprietary
System Architecture
Audit Trail
databases
Client and
Transaction
databases
Corporate
users
Internet
CCRA
Fintrac.RS
Server
Fintrac.RS
Administrator
(Setup/modify
corporate clients,
authorizations
and policy)
Fintrac.RS
Fintrac
© FBE Inc., 2001
Slide 17 of 20
http://www.currency-exchange.net/fintrac
Proprietary
Advantages
Streamlines and expedites:
Internal suspicious transaction reporting
Authorization processes
Preserves interests of front-line workers,
executives and clients
Avoiding false positives and false negatives
Reporting transactions are completed only after
responsible managers authorize them
Government/corporate suspicious transaction
reporting cycle guidelines and approval procedures
available online to guarantee there are no
misunderstandings of organization's policy
Fintrac.RS
© FBE Inc., 2001
http://www.currency-exchange.net/fintrac
Slide 18 of 20
Proprietary
Advantages (con's)
Enhanced controls
Identifying exceptions
Countrywide and worldwide reach
Secure
Savings
No LAN installation
Low cost per online transactions and maintenance
Very fast payback
Customizable
Addresses your organization’s unique requirements
ERP off-ramps
Fintrac.RS
© FBE Inc., 2001
http://www.currency-exchange.net/fintrac
Slide 19 of 20
Proprietary
Future Customization Options
Banking Systems
Optional customization modules for direct access to
Banking Systems
HR Systems
Modules for direct access to HR Systems
i.e., reporting relationships
Financial Systems
Modules for direct access to Financial Systems
e.g. SAP, Oracle, ACCPAC
Comprehensive Reporting
Fintrac.RS
© FBE Inc., 2001
Slide 20 of 20
http://www.currency-exchange.net/fintrac
Proprietary
FINTRAC Reporting Service
(Fintrac.RS)
Government
Fintrac.RS
Fintrac.RS
Client
© FBE Inc., 2001