Ms. Bouchard is selling her house in Trois-Rivières through broker Monsieur Roy. Monsieur Roy's brokerage firm received a Promise to Purchase from a foreign buyer and completed FINTRAC identification using the buyer's foreign passport. The buyer's broker then informs Monsieur Roy that the buyer will be sending the full $300,000 purchase price via wire transfer from an offshore account. What is Monsieur Roy's obligation under FINTRAC regulations?

Question: Ms. Bouchard is selling her house in Trois-Rivières through broker Monsieur Roy. Monsieur Roy's brokerage firm received a Promise to Purchase from a foreign buyer and completed FINTRAC identification using the buyer's foreign passport. The buyer's broker then informs Monsieur Roy that the buyer will be sending the full $300,000 purchase price via wire transfer from an offshore account. What is Monsieur Roy's obligation under FINTRAC regulations?

Answer options:

• Monsieur Roy's brokerage must submit a large cash transaction report (LCTR) to FINTRAC, as an international wire transfer is considered high-risk. ✅ Monsieur Roy's brokerage must submit an electronic funds transfer (EFT) report to FINTRAC for any international wire transfer of $10,000 or more, and assess for suspicious transaction reporting.
• Monsieur Roy has met his obligation by identifying the buyer; no further action is required for the wire transfer itself, as it originates from outside Canada.
• Monsieur Roy should advise the buyer that only bank drafts from Canadian financial institutions are acceptable for payment.

Correct answer: Monsieur Roy's brokerage must submit an electronic funds transfer (EFT) report to FINTRAC for any international wire transfer of $10,000 or more, and assess for suspicious transaction reporting.

Explanation: Under FINTRAC regulations, real estate brokers must submit an Electronic Funds Transfer (EFT) report for international wire transfers of $10,000 or more. Furthermore, the broker must always be vigilant for any indicators of money laundering and, if reasonable grounds to suspect money laundering exist, submit a Suspicious Transaction Report (STR), as per the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).