Filing STRs: Timing, Narratives, and No Tipping Off

The suspicious transaction report is the one FINTRAC report that runs on judgment rather than a threshold. Under PCMLTFA s. 7, a reporting entity must report every financial transaction that occurs — or is attempted — in the course of its activities where there are reasonable grounds to suspect the transaction is related to the commission or attempted commission of a money laundering offence, a terrorist activity financing offence, or a sanctions evasion offence. FINTRAC guidance confirms there is no monetary threshold: a $40 transaction can be reportable, and an abandoned or declined transaction can be reportable even though no money moved.

The sanctions-evasion ground is recent. As of August 19, 2024 (PCMLTFA s. 7 as amended by S.C. 2024, c. 15, s. 280, per FINTRAC Special Bulletin FINTRAC-2024-SB002), suspected sanctions evasion must be reported to FINTRAC — via the STR, not a separate report. If a transaction raises both money laundering and sanctions-evasion suspicion, one STR covering each suspected offence is filed.

The STR deadline is not in the Act. It sits in the Suspicious Transaction Reporting Regulations: the report must be sent "as soon as practicable" after the reporting entity has taken measures that enable it to establish that there are reasonable grounds to suspect (SOR/2001-317, s. 9(2)). That wording does two things. It gives you the time genuinely needed to complete your assessment — pulling the transaction history, reviewing the client file, running the checks your procedures call for. And it removes any slack once that assessment is done: when your measures establish reasonable grounds to suspect, filing should follow promptly, not wait for a weekly batch or a month-end cycle.

Contrast this with the threshold reports, which have fixed day counts: 15 days for a large cash transaction report (PCMLTFR s. 132(3)) and five working days for electronic funds transfer and large virtual currency transaction reports (s. 132(1)–(2)) — a common mix-up is assuming the LVCTR gets the LCTR's 15 days; it does not. The STR has no fixed number, which makes your own timestamps the evidence. Log four dates on every case: when the alert or referral arose, when review started, when the reasonable-grounds decision was made, and when the report was transmitted. If the gap between the last two is routinely long, "as soon as practicable" is not being met.

The prescribed contents of an STR are set out in Schedule 1 to SOR/2001-317; the narrative portion is where you explain the grounds for suspicion. The structure that works: facts first — who, what, when, amounts, counterparties, in chronological order — then why those facts are unusual against this client's known profile and your business's normal patterns, then the indicators you matched. State grounds, not conclusions: "client is laundering money" tells an analyst nothing; "client stated the account was for payroll, then received 14 inbound transfers from unrelated individuals over nine days and moved the funds out within hours of each receipt" is usable intelligence.

Expand every internal abbreviation, name the rails involved, and describe the measures you took and what they showed — including client explanations you received and why they did or did not resolve the concern. Avoid boilerplate pasted across reports; a narrative that could describe any client describes none. For current field-level expectations, check FINTRAC's STR guidance before filing.

PCMLTFA s. 8 prohibits disclosing that a report under s. 7 has been, is being, or will be made — or disclosing its contents — with the intent to prejudice a criminal investigation, whether or not one has begun. Note the qualifier: the prohibition is conditioned on that intent, so it is not drafted as a blanket confidentiality rule. In practice, though, no compliance program should ever rely on that nuance. The safe operating rule is simple: STR status is never disclosed to the client, to front-line staff who do not need it, or to anyone outside the reporting process.

That rule gets tested when a client asks why a transaction is delayed or why you are requesting documents mid-review. Handle those conversations in normal-course terms: information requests are framed as routine file updates, and holds are explained by ordinary operational or risk policies — never by reference to a suspicion, a report, or FINTRAC. Front-line staff need a script and training for exactly this moment, because an untrained teller or support agent saying "compliance flagged you" is how tipping off actually happens. If the business later exits the relationship, that decision is made and documented on ordinary risk grounds, separate from the STR file.

Most programs run a two-layer decision: an analyst investigates and writes a recommendation; the compliance officer makes the file-or-no-file call. Some add senior review for sensitive cases — a suspicion touching an employee, a major client, or a director — but governance must never become a queue that defeats "as soon as practicable." If a committee meets monthly, it cannot be the gate on STR filing.

Document both outcomes with equal care. A filed STR is supported by the case file showing the measures taken and dates. A no-file decision needs a written rationale too — it is the decision an examiner will probe hardest, because it is where suspicion was assessed and set aside. Keep the case file separate from the client-facing file so that STR status is invisible to staff who serve the client; that separation is what makes the no-tipping-off rule workable day to day.