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?
Correct Answer
A) Request additional identification documents and consider filing an STR
When identification appears suspicious, practitioners should request additional documentation to verify identity and consider whether circumstances warrant a Suspicious Transaction Report. This balanced approach fulfills FINTRAC obligations while allowing legitimate transactions to proceed with proper verification.
Why This Is the Correct Answer
Option A correctly applies FINTRAC's graduated response protocol. When identification raises concerns but isn't definitively invalid, practitioners must request additional documentation to complete proper client identification and verification. The requirement to 'consider' filing a Suspicious Transaction Report (STR) reflects the risk-based assessment approach mandated by FINTRAC regulations. This balanced response fulfills compliance obligations while allowing legitimate clients to complete transactions through enhanced verification procedures, consistent with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act requirements.
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Previous Question
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?
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A real estate professional notices that the same buyer has made a series of cash payments, each under $10,000 and no two within 24 hours of each other, totalling $45,000 over two weeks. The pattern appears designed to avoid FINTRAC reporting thresholds. What reporting obligation exists?