The Tracfin reporter is the person responsible for submitting suspicious activity reports to the agency. The Tracfin liaison serves as the point of contact with the reporter: the liaison receives acknowledgments of receipt and processes the reporter’s requests. Professionals subject to anti-money laundering regulations must specifically designate the individuals who perform these two functions with Tracfin and their supervisory authority. A single person may perform both roles.
Designating a reporter and a Tracfin liaison can be done with a single form, and that’s often where the thought process ends. The practical question arises the very next day: Who submits the report when the account holder is absent? Who responds to a request from the agency? Who updates the designation after someone leaves?
Tracfin Reporter and Correspondent: Who Does What?
| Point of comparison | Tracfin Reporter | Tracfin Liaison Officer |
| Mission | Submit reports of suspicious activity to Tracfin | Serve as the point of contact with Tracfin: receive acknowledgments of receipt and process its requests |
| Reference Text | Monetary and Financial Code and procedures published by Tracfin | Monetary and Financial Code and procedures published by Tracfin |
| Who holds the position | An executive or employee of the institution | An executive or employee of the institution |
| Description | Registered with Tracfin and the supervisory authority | Registered with Tracfin and the supervisory authority |
| Accumulation | Possible: The same person can hold both positions | Possible: The same person can hold both positions |
| In the event of a change | Update Tracfin and, if applicable, the supervisory authority | Update Tracfin and, if applicable, the supervisory authority |
The Reporting Party: Submit the Suspicion Report
The Tracfin reporter is the individual responsible for submitting suspicious activity reports to the agency. He or she acts on behalf of the regulated institution when a transaction or situation shows signs of money laundering or terrorist financing.
The reporting party logs into the ERMES online reporting platform, enters the case details, attaches the supporting documents, and submits the report. The reporting party does not make this decision alone: the report is the result of a collective analysis conducted in accordance with internal procedures. The reporting party’s role is limited to the formal submission of the report. The applicable obligations, criteria, and deadlines are detailed in the guide on the reporting of suspicious activity.
The Correspondent: The Interface with Tracfin
The Tracfin liaison officer serves as the point of contact between the agency and the institution. He or she receives acknowledgments of receipt for reports, responds to requests for additional documentation, processes the information returned by Tracfin, and disseminates general recommendations to the relevant teams.
The correspondent does not forward reports of suspicious activity; this is the responsibility of the reporting entity. According to the reporting requirements published by Tracfin, the same person may perform both roles, which simplifies operations in medium-sized organizations. In that case, designate a substitute to ensure that communication with the agency continues during absences.
Who is required to designate a reporting officer and a Tracfin liaison?
All professionals subject to anti-money laundering and counter-terrorism financing obligations must designate, by name, a reporting officer and a liaison officer to work with Tracfin and their supervisory authority. This obligation is set forth in the provisions of the Monetary and Financial Code.
The entities concerned include, in particular, credit institutions, investment firms, insurers, mutual insurance companies, crypto-asset service providers, real estate agents, notaries, attorneys, certified public accountants, auditors, casinos, and dealers in high-value goods. Your supervisory authority verifies that these designations are in effect and kept up to date. A guide specifies which authority oversees your compliance program AML-CFT based on your profession.
How do you designate the reporting entity and the contact person for Tracfin?
The designation process consists of four steps:
- to formalize the internal decision of the governing body;
- Complete the registration form with the name, position, and contact information for each member and alternate;
- submit the form to Tracfin electronically or by mail, in accordance with the instructions provided on the Tracfin website;
- Notify your supervisory authority in accordance with its own procedures.
Any changes must be reported to Tracfin and your supervisory authority. An outdated designation will be immediately identified during an audit. Incorporate this step into your internal mobility and departure management procedures.
What kind of candidate should we look for to fill these two positions?
Tracfin does not require any specific title or hierarchical level. Choose someone who is familiar with the clients and operations, can quickly access the necessary files and information, remains independent of sales functions, and can respond to the department’s requests in a timely manner.
Formally appoint a deputy who is familiar with ongoing matters and can act in your absence. Holding both positions simultaneously is permitted, particularly when the compliance officer is solely responsible for the compliance program AML-CFT. In this case, organize the handover of sensitive cases and ensure that the alternate can step in immediately.
What are the responsibilities of the reporting party and the institution?
These responsibilities include ensuring the confidentiality of communications, protecting the whistleblower, and ensuring the traceability of decisions made by the institution.
Confidentiality of the Statement
The suspicious activity report, its contents, and communications with Tracfin are strictly confidential. The client must not be made aware of either the existence or the reason for the report. This confidentiality protects the investigation and preserves the business relationship.
Train customer-facing teams, restrict access to the file to those who need it to process it, and ensure that both the reporter and the contact person are familiar with this requirement. To avoid common errors in suspicious activity reports, include these rules in your internal procedure.
Protection of the Good-Faith Reporter
A reporter who submits a suspicious activity report in good faith is entitled to legal protection. The reporter cannot be held liable—civilly, criminally, or disciplinarily—solely on the basis of that report, even if the investigation does not confirm the suspicion.
This protection applies only to reports made in good faith and in accordance with established procedures. The institution remains responsible for fulfilling its obligations regarding due diligence and reporting. Document the decisions made, the analyses conducted, and the trade-offs considered so that everyone can justify their actions in the event of an audit.
What should you do in case of an absence, departure, or emergency?
Appoint a substitute for both the reporting officer and the liaison officer as soon as the system is implemented. Document this appointment in your internal procedures and notify Tracfin. The substitute must be familiar with ongoing cases, have access to the necessary tools, and be able to take immediate action.
If the incumbent leaves or changes positions, update the designation with Tracfin and your supervisory authority as soon as the replacement is confirmed. Organize a handover of sensitive files. The new reporting officer or liaison must be aware of recently submitted reports, Tracfin requests awaiting a response, and files currently under review.
Document these steps so that you can demonstrate the continuity of the system. An auditor will verify that the designations are up to date and that any changes have been reported.
What must you be able to show in the event of an inspection?
| Moment | Action | Document to Keep |
| Implementation of the system | Appoint the reporting officer, the liaison officer, and their alternates | Dated internal decision; form submitted to Tracfin |
| Normal Operation | Report any suspicions to the person filing the report and respond to requests from Tracfin | Escalation Procedure, Tracking of Requests and Responses |
| Absence of the incumbent | Call in the designated alternate | Appointment of the Alternate, Record of Submitted Statements |
| Resignation or Job Change | Update the designation; forward the pending files | Update submitted to Tracfin and the supervisory authority |
| Periodic Review of the System | Verify that the designations are up to date and that the holders have received training | Review reports, training certificates |
Before the audit, verify that the names provided to Tracfin and your regulatory authority match the current account holders. An outdated designation or an unupdated form constitutes a minor violation that may result in consequences. To prepare for all the points expected during an audit AML-CFT, document each step and keep records of updates.
AP Monitoring detects suspicious transactions, continuously analyzes transaction flows, and prioritizes alerts based on the criteria you have defined. This allows the reporter to access the documented records and contextual information needed to submit a structured suspicious activity report.
The tool does not replace either the reporting officer or the liaison officer: these roles continue to be performed by specifically designated individuals. It reduces detection time, minimizes false positives, and tracks each step of the analysis so that you can justify your decisions during an audit by theACPR.
Your anti-money laundering program is based on formal designations, clear procedures, and appropriate monitoring tools. Verify that your reporting officer and liaison are up to date, that their alternates are trained, and that you can provide evidence of any updates.
Frequently Asked Questions
Can the reporting entity and the Tracfin liaison be the same person?
Yes. Tracfin states that, if necessary, both roles may be performed by the same person. This situation is common when the compliance officer is solely responsible for the compliance program.
Be sure to designate a substitute so that reports are submitted and Tracfin requests are answered during absences. Also, make sure this arrangement is reflected in your internal procedures.
Is it necessary to designate a Tracfin reporter if you have never filed a suspicious activity report?
Yes. The designation does not depend on the number of reports. Tracfin requires regulated professionals to designate, by name, a reporting officer and a liaison officer to work with Tracfin and their supervisory authority. Complete this process as soon as you set up your reporting system and update the information whenever there is a change in ownership.
How do I notify Tracfin of a change in the reporting entity or contact person?
Any changes regarding the designated individuals must be reported to Tracfin and, if applicable, to your supervisory authority. The initial designation is made using a dedicated registration form.
Incorporate this approach into your procedures for managing employee departures and internal mobility. An outdated designation is easy to identify during an audit.
Can the reporting party inform the client that a report has been filed?
No. The suspicious activity report and communications with Tracfin are confidential. The customer must not be aware of either the existence or the content of the report. Train customer-facing teams not to reveal anything, and limit access to the file to those who need it to process it.
Is the Tracfin liaison officer necessarily the compliance officer?
No. Tracfin targets the institution’s executives or employees, without limiting the role to a specific position. Choose someone who is familiar with the clients and operations, can quickly access the requested documents, and can relay information from the department to the teams. If that person is not the compliance officer, establish a process for sharing information between the two of them.
