Answer:
The Financial Transactions and Reports Analysis Centre of Canada -- FINTRAC in its Guideline 2: Suspicious Transactions mentioned:
Transactions may give rise to reasonable grounds to suspect that they are related to money laundering or terrorist activity financing regardless of the sum of money involved. There is no monetary threshold for making a report on a suspicious transaction. A suspicious transaction may involve several factors that may on their own seem insignificant, but together may raise suspicion that the transaction is related to the commission of a money laundering offense, a terrorist activity financing offense, or both.
As a general guide, a transaction may be connected to money laundering or terrorist activity financing when you think that it (or a group of transactions) raises questions or gives rise to discomfort, apprehension or mistrust.
The context in which the transaction occurs is a significant factor in assessing suspicion. This will vary from business to business, and from one client to another. As a reporting person or entity, or an employee of a reporting person or entity, you should evaluate transactions in terms of what seems appropriate and is within normal practices in your particular line of business, and based on your knowledge of your client. The fact that transactions do not appear to be in keeping with normal industry practices may be a relevant factor for determining whether there are reasonable grounds to suspect that the transactions are related to money laundering or terrorist activity financing.
An assessment of suspicion should be based on a reasonable evaluation of relevant factors, including the knowledge of the customer’s business, financial history, background and behavior. Remember that behavior is suspicious, not people. Also, it could be the consideration of many factors -- not just one factor -- that will lead you to a conclusion that there are reasonable grounds to suspect that a transaction is related to the commission of a money laundering offense, a terrorist activity financing offense, or both. All circumstances surrounding a transaction should be reviewed.
As the reporting person or entity with whom the transaction occurs, you have to assess whether there are reasonable grounds to suspect that a transaction is related to a money laundering offense or a terrorist activity financing offense. The following information concerning indicators is provided to help you with this.
or visit the complete guidelines at:
How to Identify a Suspicious Transaction
First published on BankersOnline.com 12/1/03
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