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A Suspicious Transaction Report (STR) is a filing a mortgage brokerage, lender, or administrator must submit to FINTRAC once it has reasonable grounds to suspect a transaction is related to money laundering or terrorist financing, submitted as soon as practicable after the suspicion is formed.
FINTRAC defines "as soon as practicable" as a time period that falls in between immediately and as soon as possible: the report must be completed promptly given the facts of the situation, and while some delay is permitted, it needs a reasonable explanation. Filing doesn't require proof — reasonable grounds to suspect is enough to trigger the obligation.
An STR usually follows red flags that surface during ordinary Know Your Client (KYC) work or ongoing file monitoring at a mortgage brokerage — inconsistent information, unusual funding sources, or a client unwilling to explain a transaction. The person who files it is bound by confidentiality: telling the client an STR was submitted is prohibited.
Legal basis: Canada's anti-money-laundering law requires mortgage brokerages, administrators, and lenders, as reporting entities, to file an STR with FINTRAC on reasonable grounds to suspect.
Timing standard: FINTRAC's "as soon as practicable" standard sits between immediate and as soon as possible; some delay is allowed if there's a reasonable explanation for it.
No tipping off: advising the client, directly or indirectly, that an STR has been or will be filed is not permitted.
Follows KYC red flags: an STR most often grows out of information or inconsistencies first noticed during client identification or file review, not a separate process.
Definitions reflect Canadian federal and provincial rules as of the “Updated” date above. Not advice for any specific file.
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