Garbage In, Garbage Out…
…a reasonably reasonable assessment of the reasonably unreasonable “Reasonable Grounds to Suspect” threshold and its unreasonably definitive ill-defined definition.
Chris Randle, CAMS-Audit, CAMS-FCI
“Reasonable grounds to suspect” is the Canadian regulatory threshold that triggers a reporting entity’s obligation to report suspicious transactions, and their liability for failing to do so. It is an inherently subjective threshold, applicable to all reporting entities, under all of their various operating models, and in all circumstances; by its very nature, scope, and purpose it is an expansive threshold which remains open to a variety of interpretations from a variety of perspectives.
The product of this, the suspicious transaction report, is the primary purpose served by every requirement of the Canadian anti-money laundering/countering terrorist financing (AML/CTF) regime; to provide financial intelligence to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), who can analyze the information and in turn provide actionable intelligence to law enforcement and intelligence agencies in Canada and abroad. All record-keeping, risk scoring, training, and effectiveness testing activities exist to drive the identification and reporting of suspicious transactions.