A client gives conflicting identity information, and the salesperson now has reasonable grounds to suspect the transaction is linked to money laundering. What is the brokerage's reporting obligation to FINTRAC?
Correct Answer
B) Submit a Suspicious Transaction Report as soon as practicable
FINTRAC's guidance requires a Suspicious Transaction Report to be submitted as soon as practicable after the reporting entity has completed the measures that establish reasonable grounds to suspect a money laundering or terrorist activity financing offence; the old 30-day deadline no longer applies. There is no monetary threshold, and reasonable measures must be taken to verify the person's identity before the report is sent.
Why This Is the Correct Answer
Submitting a Suspicious Transaction Report as soon as practicable is FINTRAC's current requirement once reasonable grounds to suspect have been established. It applies regardless of the amount and whether or not the transaction completes.
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A client provides a real estate agent with $25,000 in cash as a deposit. What FINTRAC obligation does this trigger?
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During a purchase, a client gives contradictory information about their identity and the source of their funds. Under FINTRAC requirements, what should the real estate brokerage do?