This development is critical for REALTORS^®, which relies on this system to report suspicious, large cash, and large virtual currency transactions.

During this outage, REALTORS^® are still required to collect the necessary FINTRAC information, including identifying clients, completing necessary forms, and documenting reportable transaction internally.

Despite the outage, it's important to note that no REALTOR^® information was compromised during the cyber incident, as confirmed by FINTRAC and the Canadian Real Estate Association (CREA). However, the unavailability of the web reporting system affects the reporting process for specific transactions.

Key Points for REALTORS^®:

• Continue Usual Client Identification Practices

  The primary change due to the outage is the inability to report suspicious, large cash and large virtual currency transactions through the Web Reporting System. However, REALTORS^® must continue to identify their clients as usual and complete all additional FINTRAC forms, such as the Receipt of Funds Record.

• Document Transactions Internally

  REALTORS^® should maintain a meticulous internal record of all reportable transactions during the system outage. This includes suspicious transactions, large cash transactions, and large virtual currency transactions. These transactions must be reported promptly once FINTRAC’s systems are back online.

• Handling Priority Suspicious Transactions

Certain transactions, deemed "priority" suspicious transactions, require immediate attention and should be reported directly to FINTRAC. These situations include:

• Transactions related to the commission or attempted commission of a terrorist activity financing offence.
• Transactions involving direct law enforcement engagement.
• Suspicious transactions related to online sexual exploitation of children.
• Transactions indicating the trafficking of an underage individual.

In such cases, REALTORS^® should contact FINTRAC directly through the following channels:

• Email: STR-DOD@fintrac-canafe.gc.ca
• Telephone: 1-866-346-8722 (toll-free)

Monitoring and Compliance

REALTORS^® should keep a close watch on FINTRAC's website for any updates regarding the status of the Web Reporting System and further instructions. Ensuring compliance during this period is crucial for maintaining the integrity and security of financial transactions within the real estate sector.

While the outage of FINTRAC's Web Reporting System presents challenges, the essential practices for REALTORS^® remain unchanged. For suspicious transactions with priority, use the direct reporting methods FINTRAC provided above.

Staying informed and prepared will help navigate this period of disruption effectively, ensuring that all regulatory requirements are met once the reporting system is restored.

To learn more, visit the Liability Awareness page in the CREB^®Link webinar library and watch the Anti-Money Laundering and FINTRAC with CREA webinars.