Jane, a mortgage broker in Alberta, is assisting a new immigrant, Li, who is looking to purchase a home in Calgary using funds transferred from overseas. The amount of the down payment is $300,000, and the total purchase price is $800,000. What is Jane's primary obligation under FINTRAC regulations concerning this transaction?

Question: Jane, a mortgage broker in Alberta, is assisting a new immigrant, Li, who is looking to purchase a home in Calgary using funds transferred from overseas. The amount of the down payment is $300,000, and the total purchase price is $800,000. What is Jane's primary obligation under FINTRAC regulations concerning this transaction?

Answer options:

• To send a Suspicious Transaction Report (STR) to FINTRAC immediately because the funds are from overseas. ✅ To identify Li as a client and keep detailed records of the transaction, including the origin of the funds, if suspicious.
• To advise Li that large international transfers are generally not acceptable for down payments.
• To confirm Li has been a Canadian resident for at least two years before accepting the down payment funds.

Correct answer: To identify Li as a client and keep detailed records of the transaction, including the origin of the funds, if suspicious.

Explanation: Under FINTRAC's client identification and record-keeping requirements, mortgage brokers must verify the identity of their clients and keep records. If there are reasonable grounds to suspect that a transaction is related to a money laundering or terrorist financing offence, an STR must be submitted, but simply being from overseas does not automatically trigger an STR without other indicators of suspicion.