A real estate brokerage receives a $50,000 deposit by wire transfer on Friday afternoon. The client mentions the funds originated from the sale of cryptocurrency. What FINTRAC obligation applies?
Correct Answer
D) Submit a Suspicious Transaction Report if there are reasonable grounds
While wire transfers don't trigger automatic cash reporting thresholds, cryptocurrency origins may constitute suspicious circumstances requiring a Suspicious Transaction Report. Practitioners must assess whether there are reasonable grounds to suspect money laundering or terrorist financing.
Why This Is the Correct Answer
Under FINTRAC regulations, real estate practitioners must submit a Suspicious Transaction Report (STR) when they have reasonable grounds to suspect money laundering or terrorist financing activities. Cryptocurrency origins can raise red flags due to their potential anonymity and use in illicit activities. The practitioner must assess the circumstances and file an STR if suspicious indicators are present, regardless of the transaction method or amount.
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