FINTRAC at two years: what brokers are still getting wrong
“FINTRAC doesn’t want mortgage brokers to become experts in reporting money launderers,” he said.
“They just wanted to add mortgage brokers because you guys are governed by a regulator and you have an obligation, and it fortifies Canada’s anti-money laundering landscape.”
Know your client — or know the risk
Robinson anchored his anti-money laundering (AML) framework around three questions every broker must be able to answer: who is the applicant, how will they service the mortgage, and where did the down payment come from? The third, he said, is the most exploited vulnerability in the transaction chain.
“In lending and in mortgages, the down payment is usually, in my opinion, the softest spot,” Robinson said.
“If someone’s looking to get a whole bunch of money into the system in one spot, they’ll usually do it through down payment.”
