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?
Correct Answer
C) File a Suspicious Transaction Report due to potential structuring
Structuring amounts to avoid identification or reporting thresholds is one of FINTRAC's money laundering indicators, and a Suspicious Transaction Report has no dollar threshold. Once the professional has reasonable grounds to suspect, the report must go to FINTRAC as soon as practicable. Because no two payments fall within 24 consecutive hours, the 24-hour rule does not combine them into a large cash transaction report.
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