Video 2 – Understanding reasonable grounds to suspect
From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
The second video (of a series of 3) explaining reasonable grounds to suspect, the required threshold to submit a suspicious transaction report to FINTRAC.
Video
Video length: 4:27 minutes
Catalogue number: FFD4-44/2025E-MP4
ISBN: 978-0-660-75944-9
Descriptive transcript of the video “Video 2 – Understanding reasonable grounds to suspect”
| Slide # | Narration (audio) | On screen description (text or image) |
|---|---|---|
1 |
Music: A music track with a subtle, serious tone begins full volume, then lowers to the background as the narration begins. |
Animation: the FINTRAC logo appears on a white background along with the opening title: Understanding reasonable grounds to suspect The opening scenes unfolds as they did in video one of the series, slowly reveal a dark blue digital realm layered underneath. |
2 |
The Financial Transactions and Reports Analysis Centre of Canada is Canada's financial intelligence unit and anti-money laundering and anti-terrorist financing supervisor. Businesses subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act must report completed or attempted suspicious transactions to FINTRAC when there are reasonable grounds to suspect that the transaction is related to a money laundering, terrorist financing or sanctions evasion offence. This can be done by submitting a suspicious transaction report, commonly referred to as an STR. This video clarifies the concept of reasonable grounds to suspect. |
Animation: the title disappears leaving only the organization’s acronym alongside the logo. Financial Transactions and Reports Analysis Centre of Canada (morphs to) FINTRAC FINTRAC remains as the bands of colour move across the white background, fully revealing the dark blue digital realm. Money laundering and terrorist financing icons appear next to the text: Reasonable grounds to suspect. A collection of high-tech boxes materializes forming a “deconstructed” digital report. It reads: suspicious transaction report. The letters str lift off the report and become capitalized. STR floats in the foreground, then disappears. The text Reasonable grounds to suspect becomes the prominent layer. |
3 |
Several illegal activities, including drug trafficking, tax evasion, corruption, fraud, smuggling, and human trafficking, are linked to money laundering, terrorist financing and sanctions evasions. |
Animation: everything disappears in the digital blue realm except the money laundering and terrorist financing icons. Lines emit from these two icons, connecting to others representing the some of the predicate crimes (icons were suggested by FINTRAC). |
4 |
By tracking the flow of funds to identify unusual transactions and by monitoring unusual client behaviour, you will likely be the first to notice suspicious activity. |
Animation: currency and bitcoin symbols begin to flow across the lines, from these six icons towards the money laundering and terrorist financing icons. A red glow lights up some of the moving currency. |
5 |
However, before you decide to submit a suspicious transaction report to FINTRAC, it is important to understand the different thresholds of suspicion. |
Animation: everything evaporates into particles and disappears. In the dark blue background, one of the see-through triangular shapes begins to enlarge as if it is moving forward through space towards the foreground. As it gets closer, the text written across it becomes visible. It says: Thresholds of suspicion |
6 |
Simple suspicion, the lowest threshold, arises from a hunch or gut feeling without accompanying facts, context, or indicators of money laundering or terrorist financing or characteristics of sanctions evasion. With simple suspicion, the absence of supporting information prompts the search for additional details to substantiate or confirm the initial hunch. |
Animation: the triangle overturns to reveal new text written on the flipside that says: Simple suspicion. A glowing light bulb made up of digital lines hovers above the triangle. Floating around the triangle and light bulb are a money laundering icon, terrorist financing icon, and the words Facts and Context. Lines emit from the light bulb toward these icons and words but as they do, the lines glitch, then disappear. The icons and words disappear. More icons pop up as new lines emit from the lightbulb, this time the lines reach here and there, searching for which icon to connect with. |
7 |
Reasonable grounds to suspect is a step above simple suspicion. This is when, based on an assessment of facts, context, and indicators, there is a possibility that a money laundering, terrorist financing or sanctions evasion offence is occurring. You do not need proof or verification …but in your review, you conclude that a particular transaction is related to the commission of a money laundering, terrorist financing or sanctions evasion offence. Your suspicion must be reasonable and not biased or prejudiced. You must be able to demonstrate and articulate your suspicion in such a way that another individual reviewing the same information with similar knowledge, experience, and training would likely reach the same conclusion. Reasonable grounds to suspect is the required threshold to submit a suspicious transaction report to FINTRAC. |
Animation: everything evaporates into particles and disappears except the triangle which revolves, once again, to reveal new text on the flipside that says: Reasonable grounds to suspect. Below the triangle, the words Facts and Context appear alongside the money laundering and terrorist financing icons. The word Possibility ricochets between the icons until it becomes squeezed into the word Proof which then evaporates, The other words disappear as the money laundering and terrorist financing icons become attached to a square marked Transaction. The icons glow red. The word in the square digitally morph into the word Reasonable then changes to Not biased or prejudiced. The words disappear but the two icons remain, still glowing red. Digital lines begin to branch out from the two icons toward an ever-growing web-like vector map of connected icons featuring currency, crimes (from scene 3) and people (groups and individuals). A high-tech lens moves across the map, magnifying different icons as it goes. The lens glows green. The depiction of the suspicious transaction report floats into the frame. |
8 |
Beyond simple suspicion and reasonable grounds to suspect, there is a higher threshold. It is called reasonable grounds to believe. This is when there are verified facts that support the probability that an offence has occurred. This can occur when you become aware that law enforcement has reached reasonable grounds to believe that a money laundering, terrorist financing or sanctions evasion offence has occurred. If this is the case, you have surpassed the threshold to submit a suspicious transaction report and must begin an assessment of the related transactions. |
Animation: everything disappears and the triangle starts to unfold like parts of an origami model, expanding to reveal several layers. The fold that says: Reasonable grounds to suspect remains in the middle. Below it, a fold appears that says Simple suspicion. And above it, a fold appears that says Reasonable grounds to believe. Together they create a hierarchy diagram of sorts, with the highest threshold at the top and the lowest at the bottom (see diagram to the right). The folds retract, leaving only the triangle marked Reasonable grounds to believe. Below this triangle, glowing green words appear that say Verified facts. The words stretch across the frame. Then the word Probability appears and nestles on top of Verified facts sinking into them as if cradled by them. These words fade to the background as a policeman icon materializes in the foreground next to the words, Reasonable grounds. The money laundering and terrorist financing icons hover on either end of these words. All of the words and icons begin to rearrange and transform into a digital file marked Assessment. On the file are also several icons for money and people. A mouse cursor clicks on the word Assessment and the file light up green as if it has been activated. |
9 |
Money laundering, terrorist financing and sanctions evasion jeopardize our financial system's integrity and damage the Canadian economy. They fuel corruption, eroding public institutions and impacting government revenues and international credibility. By complying with your legal obligations, you are deterring criminals, protecting the legitimate economy and targeting the organized networks threatening Canadians. You are also helping FINTRAC gather insights on patterns, vulnerabilities and emerging threats within Canada’s financial system. And you are helping to enhance the reputation of regulated businesses while building trust with customers, shareholders and regulators. |
Animation: The red lines begin to transform into stock charts that start to break apart, shudder and rematerialize. The money laundering and terrorist financing icons are joined by icons for corruption and government erosion (i.e. an envelope of money and a crumbling government building). The depiction of the suspicious transaction report enters the frame causing all of the icons to disappear as the stock chart stabilizes. The images transform into a digital map of Canada that glows with crisscrossing lines, patterns, and flashing alerts. Instead of icons, text layers across the map, timed to the narrator: Helping to enhance the reputation of regulated businesses Building trust with customers, shareholders, and regulators |
10 |
We all have a role to play in the detection, prevention and deterrence of money laundering, terrorist financing and sanctions evasion. Stay up to date on current money laundering and terrorist financing indicators and sanctions evasion characteristics, emerging risks and threats, news and more by visiting our website at fintrac-canafe.canada.ca |
Animation: the circling shield transforms into a globe. Icons for money laundering and terrorist financing circle the digital globe. Closing motion graphic title: Learn more at: fintrac-canafe.canada.ca Canada wordmark |
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