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?
Correct Answer
C) File an STR if the facts give reasonable grounds to suspect
Contradictory identity and source-of-funds information is a money laundering indicator that must be assessed. If the facts, context and indicators give reasonable grounds to suspect the transaction is related to money laundering or terrorist financing, the brokerage must submit a Suspicious Transaction Report to FINTRAC as soon as practicable, whatever the amount. Refusing to proceed is a business choice, not a FINTRAC requirement.
Why This Is the Correct Answer
This answer is correct because the STR obligation turns on reasonable grounds to suspect, not on the amount. The brokerage assesses the contradictory information in context and, if the threshold is met, submits a Suspicious Transaction Report to FINTRAC as soon as practicable.
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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?
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A client provides identification that appears authentic but the real estate professional has concerns about its validity during FINTRAC client identification procedures. What is the most appropriate course of action?