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The model aligns with the Financial Transactions and Reports Analysis Centre of Canada’s (FINTRAC) guidance on considering transactions in context, and it was first published in The model uses a holistic approach in reviewing all of the customer’s accounts in a 360-degree view, but only to the breadth, depth and extent necessary to address the risk that the accounts are used for ML or TF.

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Therefore, the trigger should be parked in memory and revisited when adjudicating the investigation in step five of the model.

Findings regarding the trigger event must be specifically addressed in the investigation adjudication notes (i.e., why was the activity found to be suspicious or why was it not? This is arguably the most important step in the model as it provides the foundational context against which the activity (or attempt) is assessed, evaluated and understood.

There is no monetary threshold for reporting a suspicious transaction.

A suspicious transaction may involve several factors that on their own may seem insignificant, but taken together may raise suspicion that the transaction is related to the commission or attempted commission of a money laundering offence, a terrorist activity financing offence, or both.

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