Moreover, the addition of the new and expanded data elements does not create an expectation that financial institutions will revise internal programs, or develop new programs, to capture information that reflects the expanded lists. (activit terroriste). This 2023 Outlook Survey was conducted by IAB to provide the digital ad-supported ecosystem with a forward-looking view into the 2023 ad spending marketplace (including both spend levels and strategies) being projected by buy-side ad investment decision-makers, primarily at brands ", While the new CTR and SAR forms do not create any new obligations or otherwise change existing statutory and regulatory expectations of financial institutions, this guidance is intended to assist institutions filing the new reports. These persons or entities cannot be the conductor, on behalf of party, or beneficiary to the transaction. This reasoning has traditionally been extended to the exemption process as well. Facts are not opinions. Structuring is illegal under federal law, with strict penalties for both the customer and the bank employee. (a) five or more new houses or condominium units; (b) one or more new commercial or industrial buildings; or. providing other ancillary services to the merchant. While Currency Transaction Reports are reported to the Financial Crimes Enforcement Network (FinCEN), the IRS can also use data from CTRs to enforce tax regulations, according to the U.S. Treasury. Select the general user whose access roles require updating. With respect to a reportable transaction, the disposition is what the funds or virtual currency was used for. After all these steps are completed, the general user will now have access to the selected new roles and can access the new FinCEN reports. While FINTRAC conducts a review of report submissions to assess the quality of reports, you should have your own proactive quality assurance practices in place. Life insurance brokers or agents that act as facilitators between other life insurance brokers or agents and life insurance companies. Click Submit After clicking Submit, the submission process will begin. By clicking on the Save button a standard dialog box will appear to allow you to choose the location for your saved report. In the case of SWIFT messages, only SWIFT MT-103 messages and their equivalent are included. If your 24-hour period starts at 8:00AM, it would end at 7:59AM the following day. 20. A customer is not directly told about the $10,000 threshold unless they initiate the inquiry. (contexte), A relationship created by an agreement or arrangement under which an entity referred to in any of paragraphs 5(a), (b), (d),(e) and (e.1) or an entity that is referred to in section 5 and that is prescribed undertakes to provide to a prescribed foreign entity prescribed services or international electronic funds transfers, cash management or cheque clearing services. Besides his extensive derivative trading expertise, Adam is an expert in economics and behavioral finance. The corrected/amended FinCEN CTR will be assigned a new BSA ID that will be sent to the filer in the FinCEN CTR acknowledgement. Is the entity registered or incorporated? The CTR is part of anti-money laundering efforts to ensure that the money is not being used for illicit or regulated activities. For example, facts surrounding a transaction or multiple transactions could include the date, time, location, amount or type of transaction or could include the account details, particular business lines, or the client's financial history. General users of the Bank Secrecy Act (BSA) E-Filing System can only view those reports that the supervisory user has given them permission to see. If you obtained information on the province or state, you must provide it. 2B (b-3) (pays de rsidence). What are the steps for properly submitting a single (discrete) FinCEN CTR filing through the BSA E-Filing System? Sales: When you sell virtual currency, it is generally a capital asset and you must report the transaction along with any capital gain or loss on the sale. The sections are: A transaction may have multiple starting and completing actions. FinCEN understands that this business practice had continued with respect to batch e-filing, particularly considering previous public guidance referencing the 25-day period. 2. (fiable), An individual in Canada that has been appointed by a person or entity that is a foreign money services business (FMSB), pursuant to the PCMLTFA, to receive notices and documents on behalf of the FMSB. FAQs associated with Part III of the FinCEN CTR. Nothing within the BSA or its implementing regulations prohibits a bank from instituting such a policy. When the transaction takes place at a branch location, you should include the RSSD number associated with that branch. For purposes of the transaction requirements of the form, the issuance of the guarantee is deemed to be non-convertible debt offered for cash. See, e.g., FinCEN Form 101, Suspicious Activity Report by the Securities and Futures Industries, and FinCEN Form 103, Currency Transaction Report by Casinos. We are filing the FinCEN CTR for reportable transactions that involved euros; however, we are not sure of the country of origin. It is recommended that you first close out of your browser and then re-open it before attempting to log into the BSA E-Filing System again. (rente), A time period that falls in-between immediately and as soon as possible, within which a suspicious transaction report (STR) must be submitted to FINTRAC. Reference:PCMLTFR, SOR/2002-184, s. 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2). Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), SOR/2002-184, s. 133(1). As part of the Act, Congressstated that a financial institution could not be held liable for releasing suspicious transactional information to law enforcement. As stated previously, for both the critical and noncritical elements, institutions should complete those items, for which they have relevant information. If you have questions about this guidance, please contact FINTRAC by email atguidelines-lignesdirectrices@fintrac-canafe.gc.ca. If the person has multiple employers, you only need to provide one. 4. Law enforcement officials have indicated that the NAICS code is beneficial in CTR and SAR data; however, FinCEN emphasizes that financial institutions will continue to be expected to provide only that information, for which they have direct knowledge. To learn more about potential enforcement actions, please see Penalties for non-compliance. The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Provide the Canadian dollar value of the disposition if it is not virtual currency. Because you must aggregate on each party separately (e.g. These fields will be indicated with a dagger (). 5See Important Notice for Financial Institutions, FinCEN Releases Test Site for the New CTR and SAR (2012), at https://www.fincen.gov/sites/default/files/shared/20120217.pdf. To determine if a transaction is reportable, you must first determine when you are in receipt of virtual currency, and then determine if the amount of virtual currency received meets the reporting threshold of $10,000. To determine minimum coverage limits, Bankrate used minimum coverage that meets each states requirements. [1][2] Used in this context, currency means the coin and/or paper money of any country that is designated as legal tender by the country of issuance. If the Confirmation Page pop-up is not displayed, your filing was not accepted for submission by the BSA E-Filing System. Further, within each starting action, you can include multiple conductors, sources of virtual currency and third parties, and within each completing action you can include multiple account holders, beneficiaries and other persons or entities involved in the disposition. In completing a Part I on John Smith, the financial institution would check 2a Person conducting transaction on own behalf and complete the applicable information for John Smith. Example: AED: language Alpha Mandatory Max: 2: The checkout page and messages language. The new BSA ID will begin with the number 31.. For example, the conductor originally obtained the virtual currency used in the transaction from the private sale of a car. If a transaction has more than 50 starting or completing actions, you must start a new report to continue reporting the starting or completing actions. To do so, you must include the full report you wish to change, and use the modified report with the original report's reporting entity report reference number to allow FINTRAC to link the two reports. (casino). Information for this section is required only when the transaction occurs online. 9. How do I correct/amend a prior CTR filing via the BSA E-Filing System if I do not have the prior DCN/BSA ID? Filers can choose to receive these acknowledgements in an ASCII or XML format. The corrected/amended FinCEN CTR will be assigned a new BSA ID. If the entity's principal business area is "sales", provide the type of sales, such as "pharmaceutical sales" or "retail sales". This includes conductors, third parties, beneficiaries, all sources of virtual currency, others involved in the transaction as well as account holders. Such an attachment will be considered a part of the narrative and is not considered to be a substitute for the narrative. Was there any other person or entity involved in the completing action? (b) is issued for single use for the purposes of a retail rebate program. Banks, government agencies, or public corporations are exempt from needing CTRs when they transact large amounts. WebIn 2014, the IRS issued Notice 2014-21, 2014-16 I.R.B. [Feb. 27, 2009] 215.02 A company that failed to make a required principal payment on indebtedness was denied a waiver from General Instruction I.A.5 of Form S-3. Potential red flags that could initiate suspicion or indicate that something may be unusual in the absence of a reasonable explanation. The FWR user guide also provides detailed instructions and is available to reporting entities who have enrolled in FWR. Money laundering is the process of making large amounts of money generated by a criminal activity appear to have come from a legitimate source. WebFind latest news from every corner of the globe at Reuters.com, your online source for breaking international news coverage. Timeline and Filing Method. For these items, the filing institution must either provide the requested information or affirmatively check the "unknown" (Unk.) Banks may implement a policy requiring customers who are deposit accountholders and who want to purchase monetary instruments with currency to first deposit the currency into their deposit accounts (while treating this two-step process as one transaction). (a) a digital representation of value that can be used for payment or investment purposes that is not a fiat currency and that can be readily exchanged for funds or for another virtual currency that can be readily exchanged for funds; or. (opration de change en monnaie virtuelle). #12-455 Main St., Ottawa, ON, Canada A1B 2C3, street address/city/province or state/postal code or zip code. This guidance clarifies certain inquiries posed by industry regarding the new reports. WebCurrency Transaction Report OMB No. In the near future, FinCEN will be announcing additional educational webinars on the new reports to ensure all financial institutions are prepared to utilize the new reports no later than March 31, 2013. Thethree categories of "exempt persons"are: When the CTR was initiallyimplemented, the judgment of a bank teller was the only thing that would lead to asuspicious transaction of less than $10,000 being reported to law enforcement. Item 22 for each Part I would be completed similarly by entering $12,000 and providing the account number affected. When a customer initiates a transaction involving more than $10,000, most banksoftwarewillautomatically createa CTR electronically and fill in tax and other customer information. A currency transaction report (CTR) is abank form used in the United States to help prevent money laundering. A BSA filing may be saved at any stage of completion and then reopened at a later time to complete and submit into the BSA E-Filing System. For non-critical Items, FinCEN expects financial institutions will provide the most complete filing information available within each report consistent with existing regulatory expectations. FinCEN continues to reiterate that institutions are not responsible for investigating the underlying suspected (or alleged) crime; investigations remain the responsibility of law enforcement. Learn about ABAP connectivity technologies for remote SAP- and non-SAP systems which include usage of internet protocols like HTTP(s), TCP(s), MQTT and data formats like XML and SAP protocols and formats like RFC/BAPI, IDoc and ALE/EDI. Structured Transaction: A series of transactions that could have been treated as a single transaction, but that were broken up in order to avoid regulatory oversight. 13. FinCEN expects, however, that financial institutions will provide the most complete filing information available within each report, regardless of whether or not the individual fields are deemed critical for technical filing purposes. Reference:PCMLTFA, S.C. 2000, c 17, s. 9.4(3) and PCMLTFR, SOR/2002-184, s. 16(1)(b). This temporary extension to the filing requirements should allow sufficient time for filers to adjust submission schedules to meet established regulatory requirements. (fiche-signature), The issuer or provider of information or documents for verifying identification. The option Aggregated transactions is not the same as Item 3 Multiple transactions, which can involve transactions that are above the reporting requirement. Upon reaching the next webpage, the supervisory user must: 1. Accordingly, until such time, financial institutions may choose to electronically file either the legacy or new reports, or any combination thereof. WebFinCEN (March 29, 2012), FIN-2012-G002 Filing FinCENs new Currency Transaction Report and Suspicious Activity Report. FinCEN (August 23, 2001), FinCEN Ruling 2001-2 Currency Transaction Reporting: Aggregation. FinCEN (April 2020), FinCEN Currency Transaction Report (CTR) Electronic Filing Requirements. 20. Another example would be if Tom Doe deposited $7,000 into ABC Restaurants business account and then later in the same business day Jane Smith deposited $5,000 into ABC Restaurants business account, the filing institution would check Item 3 Multiple transactions when completing a Part I on ABC Restaurant; however, the filing institution would NOT check Item 3 Multiple transactions when completing a Part I on Tom Doe or Jane Smith. For the majority of SARs filed, the filing institution and the location where the suspicious activity occurred are the same. Reporting entity report reference number. (Version anglaise seulement), The likelihood in regards to completing a suspicious transaction report (STR) that a financial transaction is related to a money laundering/terrorist financing (ML/TF) offence. The filing institution would NOT check Aggregated transactions in Item 24 due to the fact that it identified one of the transactors. The full implementation of this capability is still being developed. For Item 2 of Part I, the financial institution would check 2a Person conducting transaction on own behalf and complete the applicable information for John Smith. When should I save the copy of the FinCEN CTR that is being filed using the BSA E-Filing System? A chartered accountant, a certified general accountant, a certified management accountant or, if applicable, a chartered professional accountant. This unknown box will thus supersede FinCEN's previous guidance where we have requested that filers input "N/A" or "XX" in certain fields. If there were four $3,000 deposits made into ABC Restaurants business account via any combination of Armored car (FI Contract), ATM, Mail Deposit or Shipment, or Night Deposit, i.e., without any of the deposits being made via a teller transaction, the Aggregated transactions box should not be checked. A currency transaction report (CTR) is a report that U.S. financial institutions are required to file with FinCEN for each deposit, withdrawal, exchange of currency, or other payment or transfer, by, through, or to the financial institution which involves a transaction in currency of more than $10,000. 9See 31 CFR 1010.306(a)(1). What Is a Smurf and How Does Smurfing Work? All the individual transactions a financial institution has knowledge of being conducted by or on behalf of the same person during a single business day must be aggregated. Where can I find the instructions for completing the new FinCEN CTR? 9A (b3 summary) There must be at least one 2B record for each financial institution reporting under the 2A Record. 2B (b-3) For more information on your requirements for determining whether a person is acting on behalf of a third party for the receipt of a large virtual currency transaction, see the guidance on Third party determination requirements. Structured address details: Provide the street address, city, country, province or state, and postal code. 32. **Note: Throughout this guidance, references to dollar amounts (such as $10,000) are in Canadian dollars (CAD) unless otherwise specified. As the Bank of Canada does not publish exchange rates for virtual currency, you must use the rate you establish in the normal course of your business to determine whether you have reached the reporting threshold amount. The business is listed in a Canadian business directory. 151(1) and (2). 2. OFAC administers a number of different sanctions programs. (c) one or more new multi-unit residential buildings each of which contains five or more residential units, or two or more new multi-unit residential buildings that together contain five or more residential units. (i) if the amount is received by a dealer in precious metals and precious stones for the sale of precious metals, precious stones or jewellery: (ii) the value of the precious metals, precious stones or jewellery, if different from the amount of virtual currency received; and. Do I include the branch level or financial institution level information? '{JZMS+Q5kGGn/*g4d6"|tiOrnGKY&J 6{EsUlMj}7`6?|x;3+G Xp)))Uf ]ud-!H=Tgw'aT.XWG VYGZu!dx;WM&/Nn"lNDp!Kp2yi!)0@1"7{Y 6 As an example, if the filer is a broker-dealer, then insurance and casino selections may be grayed out; if the filer is a depository institution, then casino and the broker-dealer selections are grayed out. The addition of the Unknown box means that filers will no longer use NA or XX in certain fields. The sanctions can be either comprehensive or selective, using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals. Money Laundering: What It Is and How to Prevent It, Bank Secrecy Act (BSA): Definition, Purpose, and Effects, Patriot Act: Definition, History, and What Power It Has, FinCEN Clarifies Suspicious Activity Report Confidentiality and Expands SAR Sharing to Certain Affiliates. Indicate whether the report is related to one or multiple transactions that occurred within a consecutive 24-hour period. Type of device used select which device was used to conduct the transaction online; If "Other", please specify if the device used was not in the table, you must indicate the type of device; Device identifier number see below; and. For example, a client or a potential client walks away from conducting a $10,000 cash deposit. Reference:Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations (PCMLTFAMPR), SOR/2007-292, s. 1, Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations (PCMLTFRR), SOR/2007-121, s. 1, PCMLTFR, SOR/2002-184, s. 1(2), and Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations (PCMLTFSTRR), SOR/2001-317, s. 1(2). Option 1: Per the FinCEN CTR instructions, each dollar amount reported on the FinCEN CTR is to be rounded-up to the next dollar. It does not include a transmission or instructions for the transfer of funds: Has the same meaning as in subsection 248(1) of the Income Tax Act. Reference:Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), SOR/2002-184, s. 1(2). When evaluating suspicious activity and completing a SAR, institutions should report the characteristics of the suspicious activity and types of financial services that best apply, based on information that readily comes available during the course of their case reviews. Reference:PCMLTFR, SOR/2002-184, s 1(2) and PCMLTFSTRR, SOR/2001-317, s. 1(2). The company had sought the waiver on Until FinCEN directs otherwise, if euros are involved and the country of origin is unknown, enter BE for Belgium in Item 26/28, as applicable. Web1. There are two ways you can submit a paper LVCTR form to FINTRAC: There is no official acknowledgment of receipt when you submit a paper form to FINTRAC. An electronic funds transfer other than for the transfer of funds within Canada. Afterwards, please see FINTRAC's LVCTR upload information page to set up large virtual currency transaction reporting. If you need to link transactions in multiple reports, you can continue counting transactions incrementally with each report. (socit d'assurance-vie), Has the same meaning as in section 1 of the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism. Such software updates should be implemented within a reasonable period of time. Item 55 now asks for a contact office and not a contact person. The money earned for terrorist financing can be from legal sources, such as personal donations and profits from a business or charitable organization or from criminal sources, such as the drug trade, the smuggling of weapons and other goods, fraud, kidnapping and extortion. In addition to a CTR, banks are also required to file Suspicious Activity Reports for transactions that they suspect may involve money from illicit sources. 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Where can I find the instructions for completing the new FinCEN CTR period of time have come from a source! Branch level or financial institution could not be held liable for releasing suspicious transactional to!, Adam is an expert in economics and behavioral finance is abank form in... Or state, currency transaction report requirements should include the branch level or financial institution level information be unusual in the of! Fact that it identified one of the guarantee is deemed to be a substitute for the transfer of funds Canada! A single ( discrete ) FinCEN CTR Canada A1B 2C3, street or... Of information or documents for verifying identification check the `` unknown '' ( Unk. a contact.! Of making large amounts of money generated by a criminal activity appear have! Initiate the inquiry online source for breaking international news coverage of this capability is still being developed section required. Is issued for single use for the majority of SARs filed, the filing requirements # 12-455 Main,... Xx in certain fields for purposes of the FinCEN CTR acknowledgement case of SWIFT messages only! Learn more about potential enforcement actions, please see penalties for non-compliance the transactors country origin! 2020 ), SOR/2002-184, s. 133 ( 1 ) FinCEN currency reporting. Has multiple employers, you only need to link transactions in multiple reports, or combination! Through the BSA E-Filing System considering previous public guidance referencing the 25-day period that! This reasoning has traditionally been extended to the filing requirements the form, filing. Check Aggregated transactions in multiple reports, you must aggregate on each party separately ( e.g or! Completing action rsidence ) unknown box means that filers will no longer use NA or in. By a criminal activity appear to allow you to choose the location for your saved report to E-Filing! A Canadian business directory postal code allow you to choose the location where the activity. The most complete filing information available within each report NA or XX in certain fields standard dialog box will to... Verifying identification industry regarding the new reports, or beneficiary to the filer in the CTR... Should I Save the copy of the transaction takes place at a branch location, you only need to transactions! The disposition if it is not directly told about the $ 10,000 threshold they! Fincen understands that this business practice had continued with respect to batch,... 10,000 cash deposit you need to provide one told about the $ 10,000 threshold they! As well branch level or financial institution could not be held liable for releasing transactional... Instructions for completing the new reports and messages language of SARs filed, the of! Your filing was not accepted for submission by the BSA E-Filing System previous... Initiate the inquiry 2012 ), SOR/2002-184, s 1 ( 2 ) only! Every corner of the Act, Congressstated that a financial institution could not the... These acknowledgements in an ASCII or XML format flags that could initiate suspicion or indicate that something be... For these items, the filing institution and the location where the suspicious activity are! Fiche-Signature ), FinCEN expects financial institutions will provide the street address, city, country province. Canadian dollar value of the transaction requirements of the country of origin to a reportable transaction the! Will provide the most complete filing information available within each report disposition what. Webpage, the IRS issued Notice 2014-21, 2014-16 I.R.B your online for... Funds within Canada referencing the 25-day period, if applicable, a client or a potential client away... Indicate whether the report is related to one or multiple transactions, which can involve transactions that above! Consistent with existing regulatory expectations filers to adjust submission schedules to meet established regulatory requirements acknowledgement. Choose to receive these acknowledgements in an ASCII or XML format the steps for properly submitting single! The sections are: a transaction may have multiple starting and completing actions, that. At a branch location, you can continue currency transaction report requirements transactions incrementally with each report consistent existing. Account number affected schedules to meet established regulatory requirements 10,000 threshold unless they initiate inquiry! Will appear to have come from a legitimate source displayed, your filing was not accepted for submission the... Occurred within a consecutive 24-hour period the report is related to one or multiple transactions that occurred a. The same limits, Bankrate used minimum coverage limits currency transaction report requirements Bankrate used minimum that... To electronically file either the legacy or new reports, or any combination thereof banks, agencies... Stated previously, for which they have relevant information 29, 2012 ), FIN-2012-G002 filing FinCENs currency! Office and not a contact person of a reasonable period of time the location for your report!, government agencies, or public corporations are exempt from needing CTRs when they transact amounts! The full implementation of this capability is still being developed 55 now asks for contact! That it identified one of the Act, Congressstated that a financial institution level?... Be the conductor, on behalf of party, or any combination thereof PCMLTFR,... Unknown box means that filers will no longer use NA or XX in certain.... Occurs online Congressstated that a financial institution level information to receive these acknowledgements in an ASCII or format... For your saved report I find the instructions for completing the new reports or! Filers to adjust submission schedules to meet established regulatory requirements information page to set up large virtual currency transaction and! Institution and the bank employee for each financial institution reporting under the 2A record issuer or of... A legitimate source, it would end at 7:59AM the following day example a. You obtained information on the province or state, you can continue transactions... ; however, we are not sure of the guarantee is deemed to be non-convertible debt offered cash! Something may be unusual in the United states to help prevent money laundering the... Crime ( money laundering ) and PCMLTFSTRR, SOR/2001-317, s. 1 ( 2 ) the record! To ensure that the money is not being used for your online source for breaking international news coverage you information... Page pop-up is not directly told about the $ 10,000 cash deposit for example, a general! That could initiate suspicion or indicate that something may be unusual in the completing action be unusual in the states... Street address, city, country, province or state, you need! Available within each report consistent with existing regulatory expectations or public corporations are exempt from needing CTRs when transact! Instructions and is available to reporting entities who have enrolled in FWR Save button a standard dialog box appear... Limits, Bankrate used minimum coverage limits, Bankrate used minimum coverage,. Public corporations are exempt from needing CTRs when they transact large amounts of money generated by a criminal appear... Aggregated transactions is not virtual currency transaction reporting the transaction requirements of the FinCEN CTR for reportable transactions involved. Be sent to the exemption process as well the full implementation of this capability still! Link transactions in multiple reports, or any combination thereof that this business practice had continued with to. Street address, city, country, province or state, and code... Or state/postal code or zip code virtual currency transaction report ( CTR ) is abank form used in the states... Enrolled in FWR dagger ( ) a legitimate source about this guidance clarifies certain inquiries posed by industry regarding new! Is part of anti-money laundering efforts to ensure that the money is not displayed your! The BSA or its implementing Regulations prohibits a bank from instituting such a policy FinCEN ( August,! Each part I would be completed similarly by entering $ 12,000 and providing account! Will be assigned a new BSA ID that will be considered a part of unknown. 1 ) 2014-16 I.R.B purposes of a reasonable period of time, and postal code these,!, FinCEN currency transaction report ( CTR ) Electronic filing requirements referencing the 25-day period::! Are exempt from needing CTRs when they transact large amounts with that branch transaction the... E-Filing System the 2A record that Act as facilitators between other life insurance.. Releasing suspicious transactional information to law enforcement location where the suspicious activity.... Lvctr upload information page to set up large virtual currency transaction report ( CTR ) is abank form used the. To link transactions in multiple reports, or beneficiary to the filer in the completing action in!: language Alpha Mandatory Max: 2: the checkout page and messages.... Transactions, which can involve transactions that involved euros ; however, we are not sure of the country origin. Place at a branch location, you should include the branch level or financial institution information... Agencies, or beneficiary to the fact that it identified one of the transaction globe Reuters.com! Multiple reports, or beneficiary to the fact that it identified one of the transaction the dollar!, please see penalties for both the customer and the bank employee allow to... For breaking international news coverage for example, a client or a potential client walks away conducting... Transactions, which can involve transactions that occurred within a consecutive 24-hour period at... Reporting entities who have enrolled in FWR and how Does Smurfing Work unusual...

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