Suspicious Transaction Reports (STRs) — When to File, What to Include, and Practical STR Writing Tips for Canadian Businesses
For many reporting entities, whether you’re an MSB, a real estate brokerage, or a mortgage brokerage, the requirement to file a Suspicious Transaction Report (STR) with FINTRAC is one of the most consequential compliance obligations. It’s also one where hesitation or uncertainty can create regulatory risk. Platino Consulting’s expert team has filed STRs for many organizations and are consistently brought on to help remediate critical issues. Platino Consulting has provided on-going support to organizations for the STR filing, including conducting STR Masterclasses to provide a complete understanding of what is required, why it is required and how to provide actionable intelligence.
The two non-negotiables: “reasonable grounds to suspect” and timing
You must file an STR whenever you have reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering, terrorist financing or sanctions evasion. Critically, FINTRAC has removed any monetary threshold for STRs, even very small transactions may need reporting if circumstances justify suspicion. The statutory timing standard is that STRs must be submitted “as soon as practicable” after you complete the measures that enable you to form that suspicion. That phrase sits between “immediately” and “as soon as possible”, it means make STRs a priority and do not let routine monitoring tasks push them to the back burner.
What FINTRAC expects in the narrative
FINTRAC wants a clear narrative that explains what led you to suspect wrongdoing. The web reporting system includes a “Details of suspicion” field for this purpose and FINTRAC guidance tells reporting entities to explain the facts, the indicators observed, the timing, and the specific steps taken to investigate internally. Useful elements are: who the client is (and any beneficial owners), the series of transactions, payment methods, counterparties and any source-of-funds evidence (or absence of such evidence). Avoid speculation, stick to verifiable facts and connect them logically to the red flags you observed.
Cross-reporting (EFTs, virtual currency, casino disbursements)
If the suspicious activity also triggers a different mandatory report, for example an Electronic Funds Transfer Report (if a reportable EFT is involved), a Large Virtual Currency Transaction Report, or a Casino Disbursement Report, you must file those reports in addition to the STR. Don’t assume an STR alone covers those statutory obligations. FINTRAC’s guidance outlines these cross-reporting duties to ensure investigators have all relevant feeds.
How to write an STR that investigators can use
Lead with the facts: date/time, amounts, parties, transaction channels.
Tell the sequence: arrange transactions chronologically and explain how they relate.
Identify specific red flags: e.g., unusual payment methods, layered transfers, inconsistent explanations, third-party payer arrangements, or sudden activity from dormant accounts.
Explain steps taken: what KYC, source-of-fund checks or reviews were done, and what gaps remain.
Attach docs or reference file IDs: where possible, attach bank statements, communications, identification documents, contracts, or screenshots, either directly in an e-report or as referenced file names in your system. FINTRAC values documentation that can be used to triage and investigate quickly.
Real-world examples (brief)
A purchaser deposits multiple partial cash payments under the cash threshold but the pattern and rapid resales suggest layering. Even though each payment is below a threshold, the cumulative behaviour and timing can create reasonable grounds to suspect laundering.
A corporate buyer refuses to disclose the ultimate beneficial owner and uses a complex trust structure with urgent closing timelines and last-minute wire routing to high-risk jurisdictions. If your source-of-funds checks do not resolve who benefits, file an STR.
These examples underline that suspicion often arises from context and patterns, not just single red flags.
Documenting your decision & “as soon as practicable”
FINTRAC expects that reporting entities treat STR production as a compliance priority. If you delay reporting, document why (the steps you took, who you consulted, and why further information was needed). FINTRAC’s interpretation guidance warns that long delays without a credible explanation will be questioned during examinations. In short: escalate quickly, document everything, and submit the STR when you’ve reasonably satisfied the internal due diligence that produced the suspicion.
Practical tips for firms
Train frontline staff to escalate any red flag immediately.
Build STR templates in your case-management system that map to FINTRAC’s web fields (it speeds drafting and ensures essential items aren’t missed).
Keep a central file index of attachments and a versioned log of internal inquiries.
Conduct periodic sampling of STRs to review quality and consistency.
STRs are both a legal duty and a protective measure for your business. Being conservative about reporting, and precise in what you report, reduces regulatory risk and helps law enforcement and financial intelligence units do their job. Contact Platino Consulting for any support you require relating to filing an STR. Our experts are seasoned professionals with years of experience in training and coaching on the STR process.
