AML
A customer deposits $10,000 in cash in a single transaction. What AML reporting threshold has been reached?
Large Cash Transaction reporting threshold (LCTR).
A customer asks you for their spouse’s account balance, but they aren’t authorized on the account. Can you provide it?
No. Being a spouse does not by itself authorize access to another person’s banking information.
A customer says, “I’m unhappy with how the bank handled this.” Do they have to specifically use the word complaint for it to count as one?
No. An expression of dissatisfaction concerning a product or service can constitute a complaint.
What Canadian federal agency supervises banks’ compliance with federal consumer-protection requirements?
FCAC — Financial Consumer Agency of Canada.
A customer deposits $6,000 cash and then $5,000 cash within the applicable 24-hour window. Should the transactions be considered together?
Yes. Under FINTRAC’s 24-hour rule, qualifying transactions are aggregated when they total $10,000 or more and meet the applicable aggregation criteria.
You accidentally hand a customer’s document containing personal information to another customer. What should you do?
Immediately follow TD’s privacy-incident/breach escalation procedure and notify the appropriate leader/team.
What is the maximum legislated period for a bank to resolve or close a consumer complaint?
56 calendar days.
Does FCAC normally resolve an individual customer’s dispute with their bank and award them compensation?
No. FCAC supervises compliance; it does not normally resolve individual disputes or provide compensation.
What should you do if a transaction doesn’t reach $10,000 but the customer’s behaviour or transaction appears suspicious?
Follow the bank’s AML escalation/reporting procedures. The $10,000 LCTR threshold does not mean transactions below $10,000 cannot be suspicious.
Can you look up the account of a friend or family member just because you work at the bank?
No. Customer information should only be accessed for a legitimate business purpose.
True or False: The 56-day complaint timeline can be paused while the bank waits for additional information.
False. The 56-day period is not paused.
Before recommending or discussing a financial product, why is understanding the customer’s needs important?
To help ensure the product or service being discussed is appropriate for the customer’s circumstances and needs and that required processes/disclosures are followed.
A customer repeatedly deposits cash just below $10,000. What AML red flag might this suggest?
Possible structuring / attempts to avoid reporting requirements.
You’re discussing a customer’s financial situation with a coworker. When is that appropriate?
If a customer remains dissatisfied after the bank’s internal complaint process, what independent external organization can review an eligible banking complaint?
A customer says, “I don’t understand this fee.” What should the employee do?
Clearly explain the applicable fee and relevant disclosure, verify the customer’s understanding, and address/escalate any complaint appropriately.
True or False: If you suspect a transaction may be related to money laundering, you should tell the customer that you’re reporting your concern.
False. Do not disclose internal AML reporting/escalation activity to the customer.
A customer leaves confidential documents behind after an appointment. What’s your first responsibility?
Secure the documents immediately and follow the bank’s procedures for protecting/returning customer information.
What should an employee do when they receive a customer complaint instead of simply treating it as normal feedback?
Recognize it as a complaint and follow the bank’s complaint-handling/documentation and escalation procedures.
A customer feels pressured to purchase a product they don’t want. What major regulatory/customer-protection concern does this raise?
Sales-practice / consumer-protection concerns, including ensuring customers aren’t subjected to undue pressure and that appropriate consent/process requirements are followed.
Scenario: A customer comes into the branch and deposits $6,000 cash. Later within the applicable 24-hour window, another $5,000 cash transaction occurs that meets FINTRAC’s aggregation criteria. The customer tells you:
“I didn’t want to deposit $11,000 at once because I heard banks report transactions of $10,000 or more.”
Question: What are two AML concerns in this scenario?
1. The qualifying cash transactions may need to be aggregated under the 24-hour rule because they total $11,000.
2. The customer’s statement and transaction pattern are potential indicators of structuring/reporting avoidance and should be handled according to the bank’s AML procedures.