A real estate agent receives a $50,000 cash deposit from a client who claims to be purchasing the property for their elderly parent who doesn't speak English. The client provides minimal documentation and requests the transaction close quickly. What compliance obligations must the agent fulfill under FINTRAC regulations?
Correct Answer
A) Verify identity, identify any third party, file an LCTR and consider an STR
Receiving $10,000 or more in cash requires the brokerage to verify the identity of the person providing it, take reasonable measures to determine whether that person acts for a third party, keep a large cash transaction record and submit a Large Cash Transaction Report within 15 calendar days. The minimal documentation, rush and purchase on another's behalf must also be assessed, and a Suspicious Transaction Report submitted if they give reasonable grounds to suspect.
Why This Is the Correct Answer
This answer is correct because it lists the obligations the facts trigger: verify the identity of the person providing the $50,000 cash, determine and record any third party the person acts for, submit a Large Cash Transaction Report because the cash is $10,000 or more, and assess the red flags for a Suspicious Transaction Report.
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A real estate agent receives a $25,000 deposit that must be held in trust. The client requests the funds be deposited into the agent's personal account temporarily due to banking issues. What should the agent do?
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A real estate agent suspects a client may be involved in money laundering but the transaction appears legitimate on paper. The client has provided all required documentation. What should the agent do?