A suspicious transaction report (STR) is the report a real estate brokerage submits to FINTRAC when it has reasonable grounds to suspect that a transaction, or an attempted one, is related to a money laundering or terrorist financing offence.
The trigger is a possibility standard, not a certainty one. FINTRAC's own guidance on suspicious transaction reporting is explicit that an agent does not need to verify the underlying facts or prove an offence actually occurred: you weigh the facts, the context and known red-flag indicators, and ask whether “another person with similar knowledge and training would likely reach the same conclusion.”
There is no fixed filing deadline in days — the rule is “as soon as practicable” after grounds for suspicion are established, but FINTRAC's guidance warns that “the greater the delay to submit a Suspicious Transaction Report, the greater the need for a suitable explanation.” A brokerage that sits on a suspicion for weeks needs a documented reason for the gap, not just a completed form.
Filing carries a tipping-off prohibition: an agent is not allowed to inform anyone, including the client, that a report was made or will be made, if doing so would prejudice an investigation — which is also why diligence questions that would tip off a client should not be asked once suspicion has formed. Separately, FINTRAC publishes real-estate-specific red-flag indicators, including a client who “negotiates a purchase for the market value or above the asked price, but requests that a lower value be recorded on documents,” or one who “purchases multiple properties in a short period” with little apparent interest in condition or location — the pattern an STR is built to catch.
A seller insists the agreement of purchase and sale record a price well below what was actually agreed, offering to take the difference in cash outside the transaction. That single fact pattern matches a named FINTRAC red flag on its own. The agent does not need to establish that anything illegal is actually happening before filing — reasonable grounds to suspect is enough, and the STR itself is confidential; the client is never told one was filed.
See also: Receipt of funds record, defined · The National Do Not Call List.
A 30-minute call is enough to tell you whether AI pays for itself here.
