If you are a mortgage broker, agent or administrator in Canada, you must submit a suspicious transaction report (STR) to FINTRAC when a transaction is completed or attempted and you have reasonable grounds to suspect it is related to money laundering, terrorist activity financing or sanctions evasion. There is no dollar threshold. You do not need proof. You need facts, context and indicators that you can explain, and you must file as soon as practicable after you reach that point.
This guide walks through the test, the timing, the form, the tipping off trap and the records you keep, with the mortgage-specific indicators that tend to show up in real files.
TL;DR
- An STR is required when a transaction happens or is attempted and you have reasonable grounds to suspect a link to money laundering, terrorist financing or sanctions evasion. No minimum amount applies, and attempted deals count.
- Reasonable grounds to suspect sits above a gut feeling and below verified belief. You do not have to prove an offence.
- File as soon as practicable. FINTRAC expects the report to take priority over routine processing, and a longer delay needs a reasonable explanation.
- Never tell the client, or anyone else, that you have filed or are considering filing. Keep a copy of every STR for at least five years.
Table of Contents
- What counts as a suspicious transaction in a mortgage file
- The reasonable grounds to suspect test
- Indicators that matter for mortgage work
- When to file: as soon as practicable
- How to submit the report
- Writing the narrative that FINTRAC can use
- Tipping off: the part brokers underestimate
- Keeping the records
- Building the program around the report
- Our perspective: suspicion is a paperwork problem first
- How Autowrite fits into your workflow
- FAQ
- Sources
What counts as a suspicious transaction in a mortgage file
FINTRAC defines the obligation around a financial transaction that is completed or attempted in the course of your activities. The key phrase is reasonable grounds to suspect that the transaction relates to the commission or attempted commission of a money laundering offence, a terrorist activity financing offence, or sanctions evasion.
Three things follow from that wording.
- Attempts count. A borrower who withdraws after you ask a routine question about the source of a down payment has still attempted a transaction. If your grounds to suspect are met, the report is still owed.
- There is no monetary threshold. Unlike large cash reports, the STR has no minimum amount. A modest deal with troubling features can require a report.
- The duty is personal as well as corporate. FINTRAC's guidance states that all reporting entities and their employees must report suspicious transactions under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, as set out in its overview of suspicious transaction reporting.
Mortgage administrators, brokers and lenders are listed by FINTRAC as reporting entities, and its page for the mortgage sector lists the STR among the reports you must submit.
The reasonable grounds to suspect test
Most hesitation about filing comes from a misunderstanding of the threshold. FINTRAC describes three levels of certainty. Simple suspicion, a hunch with nothing behind it, is too low. Reasonable grounds to believe, which rests on verified facts, is higher than you need. Reasonable grounds to suspect sits between them, as FINTRAC explains in its STR guidance.
In practice, ask yourself this: could another mortgage professional with similar training, looking at the same facts, context and indicators, reach the same conclusion? If yes, you are likely at the threshold. FINTRAC's video on what to consider when submitting an STR also makes clear that you do not need to verify the facts or prove criminal activity, and that a report made in good faith does not expose you to prosecution.
Facts, context and indicators
FINTRAC's guidance describes establishing the threshold by linking money laundering and terrorist financing indicators to your assessment of the facts and context. An indicator alone rarely settles it. A client who pays a large down payment is not suspicious. A client who pays a large down payment from an account in a third party's name, with a story that changes between calls, and a lawyer's letter that does not match the numbers, is a different file.
Before you decide, FINTRAC expects you to take reasonable measures to understand the situation. That includes verifying identity: you must take reasonable measures to verify the identity of every person or entity that conducts or attempts a suspicious transaction, whatever the amount.
Indicators that matter for mortgage work
FINTRAC emphasizes that mortgage professionals are often well placed to see a transaction unfold. Its mortgage sector video on STRs points to the ways criminals exploit the sector: shell companies, nominee buyers and fraudulent documentation. Its video on submitting reports adds unusual transactions, dealings with sanctioned entities, questionable sources of funds, atypical client behaviour, and unclear or overly complex ownership structures.
Here is how those categories tend to look on a Canadian mortgage file. These are working examples to prompt your thinking, not an official list.
| Area | What you might see | Why it matters |
|---|---|---|
| Source of funds | Down payment arrives from an unrelated third party, or from an account that does not match the applicant | Possible nominee buyer or funds of unclear origin |
| Ownership | Purchase through a numbered company or layered corporate structure with no clear business reason | Possible shell company hiding the true owner |
| Documents | Pay stubs, T4s, notices of assessment or bank statements with inconsistent fonts, dates or totals | Possible fraudulent documentation |
| Client behaviour | Reluctance to provide identification, urgency with no explanation, or an applicant who seems unaware of the deal's details | Atypical behaviour for the profile |
| Transaction pattern | Early or lump-sum payoff of a mortgage with no logical source, or repeated purchase and sale at odd values | Atypical for the stated income and purpose |
| Sanctions | Parties or funds linked to a sanctioned person or jurisdiction | Possible sanctions evasion, which is also reportable |
FINTRAC also flags clients who appear knowledgeable about reporting thresholds or who try to stay beneath them. Our own list of 12 mortgage fraud red flags covers the application-fraud side in more depth, and our piece on detecting document tampering covers what to ask of any tool that screens documents.
When to file: as soon as practicable
Once you have established reasonable grounds to suspect, you must submit the report as soon as practicable. FINTRAC's guidance says this does not mean immediately, but that preparing and sending the STR should take priority over other routine administrative work. Day-to-day processing should not be allowed to hold it up.
The longer the gap, the more you may have to justify. FINTRAC's self-assessment tool for the mortgage sector says some delay is allowed but needs a reasonable explanation. So write down, in your file, when the grounds crystallized and what you did next.
The practical rule: the clock is tied to the moment your suspicion meets the threshold, not to the moment the deal funds or falls through.
How to submit the report
STRs go to FINTRAC electronically, either through the FINTRAC Web Reporting System or by API. The web system is geared to reporting entities with lower volumes, which describes most brokerages. The paper form says plainly that you should not use it if you are able to report electronically.
FINTRAC updated the STR form and published resources to help reporting entities prepare for the changes, so always work from the current version of the form and the validation rules on FINTRAC's site rather than a saved template.
What the form asks for
The form is organized into sections, as shown in the STR guidance:
- General information: your reporting entity details, a report reference number and contact information.
- Transaction information: whether the transaction was completed or attempted, why it was not completed if applicable, date and time, method, location and purpose.
- Starting action: how the funds came in or out, the amount, the source of funds and who conducted or attempted the transaction, including any third party.
- Completing action: what happened to the funds, and the related details.
- Details of suspicion: your narrative.
- Action taken: what you did as a result.
For a mortgage file, much of this information already sits in your application, your identification records and your source-of-funds documents. The work is collecting it quickly and consistently, which is where good file organization pays off.
Writing the narrative that FINTRAC can use
The Details of suspicion section is where reports succeed or fail. FINTRAC asks for a clear, concise narrative without jargon, covering the factors, context and indicators that led to your conclusion. Its STR form and guidance make clear you do not need to prove the offence.
A strong narrative usually answers five questions in plain sentences:
- Who is involved, and what is their role (applicant, co-borrower, gift giver, lawyer, third party)?
- What was the transaction, and was it completed or attempted?
- Why is it out of line with what you know about the client, the property or the market?
- Which indicators apply, tied to specific facts, such as a shell company or inconsistent documents?
- What did you do about it, for example verifying identification or declining to proceed?
Compare two openings. Weak: the client seemed odd and the funds looked unusual. Stronger: the applicant, a salaried employee with declared income of a stated amount, proposed to close with a down payment wired from a numbered company with no stated connection, and provided two versions of a gift letter with different amounts. The second one gives an analyst something to work with. As FINTRAC's own training notes, vague reports hinder analysis, while context-rich ones help protect the integrity of the financial system.
Tipping off: the part brokers underestimate
You are legally prohibited from telling a client, or anyone else, that you have submitted or are considering submitting an STR. FINTRAC's training on STR considerations stresses that this reaches your ongoing assessment too, so take care when asking clients for unusual information.
A few habits help:
- Ask for the same categories of document you would request on any comparable file, framed as ordinary lender requirements.
- Keep your suspicion out of emails and client portals. Record it in a restricted internal note.
- Limit who in the brokerage knows. Brief your compliance officer, not the whole office.
- If a client asks why you are asking, give the normal explanation you would give for any file. If you are unsure what you can say, speak to your compliance officer or counsel before replying.
This is where your brokerage's written procedures earn their keep. A new agent who is not sure what to say on the phone is the usual source of accidental tipping off.
Keeping the records
When you submit an STR, you must keep a copy. The retention period is at least five years from the day the STR was submitted. Keep with it the supporting material that shaped your narrative, such as identification records, source-of-funds documents and your dated notes.
Ontario brokerages face provincial retention rules as well, and the periods differ. We compare them in our article on FINTRAC's five year rule and FSRA's six year rule, and set out the Ontario proofs in FSRA mortgage compliance. Check your own provincial regulator's requirements too, whether you work in British Columbia, Alberta, Quebec or elsewhere.
Building the program around the report
Filing is one part of compliance. FINTRAC encourages periodic self-assessments, reviewing previous reports for consistency, and sharing knowledge within the sector, as described on its website. A sound program for a brokerage usually includes:
- a written risk assessment and compliance policies that your staff have read;
- training for everyone who touches a file, with a clear internal route to escalate concerns;
- consistent client identification, using methods FINTRAC recognizes (see our summary of the five client ID methods);
- a standard checklist for the file, such as our FINTRAC compliance package checklist;
- a review cycle to test whether the program works.
For a wider look at the obligations, see our guide to anti-money laundering compliance for mortgage brokers and our article on passing FINTRAC audits with automation.
Our perspective: suspicion is a paperwork problem first
We build Autowrite for Canadian mortgage brokers, and the pattern we see is consistent: suspicion rarely fails because a broker lacks judgment. It fails because the signs are buried. An inconsistent date sits on page nine of a bank statement. A third-party deposit hides in a long transaction list. A gift letter says one amount while the lender package says another. When files are heavy with paper, the broker who is racing to a deadline can miss the very detail that matters.
That is why we focus on document intelligence. Automated intake, classification and data extraction, with line-level confidence on what was read, put the numbers in one place, so mismatches between documents become visible sooner. Income and down payment analysis helps you see whether the funds fit the story. And a file that is already organized, with identification and source-of-funds records in order, lets you write a clear narrative quickly if you do have to report.
We want to be clear about the limits. Software does not decide whether you have reasonable grounds to suspect, and it does not file the report for you. That judgment belongs to a licensed professional who knows the client. What a good system does is shorten the distance between noticing something and being able to act on it, and keep the supporting records tidy for the five years that follow.
— Anant Bawa
How Autowrite fits into your workflow
Autowrite is an AI-powered operating system for Canadian mortgage brokers. It handles document intake, classification and data extraction, auto-fills underwriting forms, syncs with mortgage software, assembles e-sign and compliance packages, and supports Canadian data residency. Plans on our pricing page are Starter at $99 per month, Pro at $199 per month and Legend at $399 per month, with Enterprise available on request. Additional deals cost $20 each, and pay as you go is $35 per deal. Paid plans come with a 14-day free trial, so you can test it on a live file before you commit.
FAQ
Is there a minimum dollar amount for an STR?
No. FINTRAC's guidance sets no monetary threshold for suspicious transaction reports. A small or even attempted transaction must be reported if you have reasonable grounds to suspect a link to money laundering, terrorist financing or sanctions evasion.
Do I have to be certain a crime happened before I file?
No. The test is reasonable grounds to suspect, which is lower than reasonable grounds to believe. You describe the facts, context and indicators you observed, and you do not need to prove the offence or verify every fact. FINTRAC's training also notes that good-faith reports are protected from prosecution.
Can I tell the client I filed a report?
No. You may not tell the client or anyone else that you have submitted, or are considering submitting, an STR. If you are unsure how to respond to a client question while a concern is open, talk to your compliance officer or legal counsel before you reply.
How long do I keep a copy of an STR?
At least five years from the day you submitted it, according to FINTRAC's record keeping requirements. Your provincial regulator may require longer retention for the mortgage file itself, so check both.
Sources
- Reporting suspicious transactions to FINTRAC
- Video 3: What to consider when submitting a suspicious transaction report
- Video: Mortgage sector suspicious transaction reports
- Suspicious Transaction Report (STR) form
- Mortgage administrators, brokers and lenders
- When to verify the identity of persons and entities: mortgage sector
- Self-assessment tool for the mortgage sector
- Record keeping requirements for financial entities
- FINTRAC