This guidance explains the legal requirement for including or obtaining specific information when initiating or receiving electronic funds transfers (EFTs) or virtual currency (VC) transfers. Commonly known as the Travel Rule, this obligation applies to financial entities (FEs), money services businesses (MSBs), foreign MSBs (FMSBs), and casinos operating in or serving clients in Canada.

What the Travel Rule Requires

Under the Travel Rule, reporting entities must ensure that key information travels with the EFT or VC transfer. This includes:

• The name, address, and account or reference number of the person or entity initiating the transfer (the payer)

• The name, address, and account or reference number of the recipient (the payeee)

This requirement applies to both sending and receiving institutions. If acting as an intermediary, the entity must preserve the information and include it when forwarding the transaction.

Although the Travel Rule is not a standalone record-keeping requirement, complying with it assists in meeting broader obligations related to transaction reporting and traceability under Canadian AML/CTF laws.

EFT Transfers: Requirements & Scope

The guidance defines EFTs to include international transfers and certain domestic transfers sent via SWIFT MT-103 or equivalent messaging formats. Entities must:

• Include the full travel rule information when initiating an EFT

• Take reasonable measures to ensure this information is present upon receiving an EFT, whether as final recipient or intermediary

• Not remove the information from a transaction

If the required details are absent, the receiving institution must attempt to obtain the missing data and have written, risk-based procedures on whether to process, suspend, or reject such transactions.

Virtual Currency Transfers: Requirements

FEs, MSBs, and FMSBs must also apply the Travel Rule to VC transfers, which are subject to the same information requirements as EFTs. For VC transfers where a record must be kept, the institution must ensure the inclusion of:

• The name, address, and reference number of the originator

• The name, address, and reference number of the beneficiary

The guidance reinforces that institutions must take reasonable steps to secure this information upon receipt and develop risk-based policies to guide decision-making when such information is missing.

Handling Non-Compliant Transfers

If a transfer (EFT or VC) lacks required information, the institution must:

• Attempt to obtain the missing data using reasonable measures

• Rely on written internal policies to determine whether the transaction should be allowed, suspended, or rejected

• Apply follow-up procedures in line with their compliance programme and FINTRAC expectations

These internal policies must be risk-based, clearly documented, and routinely applied.

Regulatory Foundation & Further Guidance

The obligations set out in this guidance are drawn from Section 9.5 of the PCMLTFA and Sections 124 and 124.1 of its Regulations. FINTRAC also provides complementary documents on record-keeping and reporting obligations specific to:

• Large EFTs

• VC transactions

• Specific entity types (e.g., casinos, FMSBs)

Conclusion: WTR Compliance Integration

Canada’s Travel Rule guidance sets clear expectations for financial entities and VASPs to include originator and beneficiary information with fund transfers. It mirrors FATF Recommendation 16 and strengthens the transparency and traceability of both fiat and virtual asset flows. Institutions must ensure both technical implementation and internal risk governance are aligned with these requirements.