A client, Ms. Lee, wires a down payment of $100,000 from an overseas account to her real estate brokerage's trust account for the purchase of a property in Richmond. The managing broker, Mr. Patel, notes that the wire transfer originated from a high-risk jurisdiction and has no clear explanation for the source of funds. What is Mr. Patel's primary obligation under FINTRAC regulations?

Question: A client, Ms. Lee, wires a down payment of $100,000 from an overseas account to her real estate brokerage's trust account for the purchase of a property in Richmond. The managing broker, Mr. Patel, notes that the wire transfer originated from a high-risk jurisdiction and has no clear explanation for the source of funds. What is Mr. Patel's primary obligation under FINTRAC regulations?

Answer options:

• Immediately return the funds to Ms. Lee and refuse to proceed with the transaction. ✅ File a Suspicious Transaction Report (STR) with FINTRAC, regardless of the transaction amount.
• Report the transaction to the PTT office as it constitutes an international transfer.
• Contact the police for potential money laundering activities.

Correct answer: File a Suspicious Transaction Report (STR) with FINTRAC, regardless of the transaction amount.

Explanation: Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations, real estate brokerages are required to file a Suspicious Transaction Report (STR) with FINTRAC if there are reasonable grounds to suspect that a transaction, or an attempted transaction, is related to money laundering or terrorist financing, regardless of the amount.