A real estate brokerage in Canada discovers that two separate cash deposits of $6,000 and $5,000 were received from the same client on the same day for different properties. What FINTRAC reporting obligation applies?
Correct Answer
A) File a Large Cash Transaction Report as the total exceeds $10,000
Under FINTRAC regulations, multiple cash transactions totaling $10,000 or more from the same individual within 24 hours must be reported as a Large Cash Transaction Report. The brokerage must aggregate these transactions for reporting purposes.
Why This Is the Correct Answer
Option A is correct because FINTRAC regulations require real estate brokerages to aggregate multiple cash transactions from the same individual within 24 hours. Since $6,000 + $5,000 = $11,000, which exceeds the $10,000 threshold, a Large Cash Transaction Report must be filed. The Proceeds of Crime (Money Laundering) and Terrorist Financing Act specifically requires this aggregation to prevent transaction splitting designed to avoid reporting requirements.
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