FINTRAC amplifies requirements for Suspicious Transaction Reporting

The Financial Transaction and Reports Analysis Centre of Canada (FINTRAC) has recently updated its industry guidance (Revised Guidance) in relation to the filing of suspicious transaction reports (STRs). The Revised Guidance reflects FINTRAC’s increased expectations as to certain key requirements for filing STRs. Reporting entities, including financial entities, are encouraged to revisit their current approach to filing STRs and ensure their internal processes adhere to the Revised Guidance. Some highlights of the Revised Guidance are as follows: Threshold of suspicion: An STR must be filed with FINTRAC where there are “reasonable grounds to suspect” that a transaction is related to a money laundering or terrorist financing (ML/TF) offence. This is a lower threshold than “reasonable grounds to believe”. Although an STR must still be filed on the basis of “reasonable grounds to believe”, this threshold is more than what FINTRAC requires.…

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