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?

Q: What is the correct answer to: 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?

The correct answer is File a Large Cash Transaction Report as the total exceeds $10,000. Option B 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.

Q: What background knowledge is needed for this Regulatory Compliance question?

FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) requires real estate professionals to report large cash transactions exceeding $10,000. The Proceeds of Crime (Money Laundering) and Terrorist Financing Act establishes the 24-hour aggregation rule, meaning multiple cash transactions from the same individual must be combined. Real estate brokerages are reporting entities under this legislation and must file Large Cash Transaction Reports (LCTRs) within 15 days. This prevents money launderers from structuring transactions below thresholds to avoid detection.

Q: What is a good way to remember the answer to this Regulatory Compliance question?

Think of FINTRAC as a '24-hour cash collector' that gathers all cash from the same person in one day. Just like collecting coins in a jar, you count ALL the cash together, not each coin separately. If the total jar exceeds $10,000, you must report it. When you see multiple cash transactions from the same client, immediately think 'cash collector jar' and add them up. If the total exceeds $10,000 within 24 hours, you need an LCTR, regardless of individual amounts.

Q: What exam tip applies to this Regulatory Compliance question?

Always aggregate multiple cash transactions from the same client within 24 hours. Don't look at individual amounts - add them together first, then check if the total exceeds $10,000 for LCTR requirements.

Q: How does this Regulatory Compliance concept apply in real world practice?

A real estate agent receives two cash deposits from Mr. Chen: $7,500 for a condo purchase and $4,200 for a rental property deposit, both on Tuesday. Even though each amount is under $10,000, the total $11,700 triggers FINTRAC reporting. The brokerage must file an LCTR within 15 days, documenting both transactions as part of the same reporting event to comply with anti-money laundering regulations.

Question

Regulatory ComplianceFINTRAC Anti Money LaunderingBCMEDIUM

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?

Answer Options

A

No reporting required as each transaction is under $10,000

B

File a Large Cash Transaction Report as the total exceeds $10,000

C

File a Suspicious Transaction Report only

D

Report only the $6,000 transaction