What type of transactions may be reported as suspicious?
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The transaction-based requirements that apply to regulated dealers include, but are not limited to, the following: Show
Transaction-Based Requirements for Precious Stones and Precious Metals Dealers (“PSMD”): Watch the videos to find out more about the transaction-based requirements.  Customer Due DiligenceCDD is the process of obtaining your customers’ identifying information, recording the information and verifying who they are before transacting with them. The objective is to help you determine the money laundering/terrorism financing (“ML/TF”) risks and take appropriate mitigating measures to address them. In the event where you are unable to perform or complete the required CDD, you must not proceed with the transaction. You should terminate any transaction entered into with the customer and consider whether to file a STR. If you suspect that the customer is in the listings for terrorist designation and designated individuals and entities, you must stop the transaction and report to the police. Please refer to the Guidelines for more information. Enhanced Customer Due DiligenceWhere the ML/TF risks are identified to be higher, regulated dealers are expected to take ECDD measures to mitigate and manage those risks. Please refer to the Guidelines for more information. Cash Transaction ReportRegulated dealers who enter into any designated transaction1 must submit a CTR electronically to the STRO within 15 business days via SONAR. As part of record keeping, you are required to keep a copy of the filed CTR for 5 years after the date of submission. (a) a sale of any precious stone, precious metal, precious product or asset‑backed token by a regulated dealer to a customer, for which cash or a cash equivalent exceeding the threshold amount is received as payment; (b) 2 or more sales of any precious stone, precious metal, precious product or asset‑backed token in a single day by a regulated dealer to the same customer, or to customers whom the regulated dealer knows act on behalf of the same person, for which cash or a cash equivalent in total exceeding the threshold amount is received as payment; (c) a purchase of any precious stone, precious metal or precious product from a customer (who is not a regulated dealer) by a regulated dealer (who is a secondhand goods dealer), for which cash or a cash equivalent exceeding the threshold amount is received as payment; (d) a redemption of an asset‑backed token from a customer (who is not a regulated dealer) by a regulated dealer, for cash or a cash equivalent exceeding the threshold amount; (e) 2 or more purchases of any precious stone, precious metal or precious product in a single day by a regulated dealer (who is a secondhand goods dealer), from the same customer, or customers whom the regulated dealer knows act on behalf of the same person (none of whom are regulated dealers), for which cash or a cash equivalent in total exceeding the threshold amount is received as payment; (f) 2 or more redemptions of any asset‑backed token in a single day by a regulated dealer from the same customer, or customers whom the regulated dealer knows act on behalf of the same person (none of whom are regulated dealers), for cash or a cash equivalent exceeding the threshold amount; “threshold amount” means $20,000 or its equivalent in value, or an amount prescribed in substitution. Suspicious Transaction ReportRegulated dealers are required to file a STR when there are suspicions on ML/TF activities in the business transaction. This should be filed electronically via SONAR. Regulated dealers are reminded that it is an offence under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (“CDSA”) to tip off another person on a STR filed with STRO. What type of transactions are suspicious?Any transaction or dealing which raises in the mind of a person involved, any concerns or indicators that such a transaction or dealing may be related to money laundering or terrorist financing or other unlawful activity.
What are the different types of suspicious activity that should be reported?Leaving packages, bags or other items behind. Exhibiting unusual mental or physical symptoms. Unusual noises like screaming, yelling, gunshots or glass breaking. Individuals in a heated argument, yelling or cursing at each other.
What is considered suspicious activity?Suspicious activity is any observed behavior that may indicate pre-operational planning associated with terrorism or terrorism-related crime.
Which of the following are common indicators of suspicious transactions?COMMON INDICATORS OF POTENTIALLY SUSPICIOUS TRANSACTIONS
(1) Excessively obstructive or secretive client a) Client appears to have dealings with several Attorneys-at-Law for no apparent reason. b) Client is accompanied and watched. c) Client presents confusing and inconsistent details about the transaction.
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