Compliance Questionnaire - Real estate sector

Part A

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Company/Organization's legal name and address:
Please indicate the type of premises for the above address: Commercial / Retail, Residential / Dwelling House, or (If other, specify)
Name of owner/broker/nominee:
Name and title of the individual completing questionnaire:
Contact information:
Business telephone:
Business fax:
E-mail:

A1 - Please indicate which of the following real estate activities your organization is involved in? (Check all that apply):
Residential Sales, Commercial Sales, Property Management, or Other

A2 - Does your company/organization engage in any of the following activities on behalf of any person or entity in the course of a real estate transaction:

• receiving or paying funds (i.e. accepting deposits);
• depositing or withdrawing funds; or
• transferring funds by any means

If you answered yes to A2, please proceed and complete the questionnaire. If you answered no to A2, you are not required to proceed with the rest of the questionnaire. Please return the questionnaire completed to this point to FINTRAC in the prescribed manner. Thank you for your time and cooperation.

A3 - How many brokers _________ and sales representatives ___________ are there in your entire company/organization?

A4 - Does your company/organization operate more than one office?

A5 - If you answered yes to A4, please provide the number of branch offices and their addresses? If there is not enough room below, please attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in Answer A5.

A6 - What best describes your office: Corporate, Franchise, Independent Office, or Other (please specify)

A7 - Please indicate the approximate number of real estate transactions for your last fiscal year:
Please indicate the approximate value of the transactions¹ conducted in your last fiscal year $:
¹ Value of transactions means the changes in assets and liabilities not including charges, fees, commissions, brokerage, or any other service charges; profit
i.e. value of property(s) bought or sold (e.g. 5 properties at $100,000 – value of transactions is $500,000).

A8 - When conducting real estate transactions, does your office accept cash? (All references to cash mean money in circulation in any country (bank notes or coins). In this context, cash does not include cheques, money orders or other similar negotiable instruments).

A9 - Does your company/organization have the electronic capability (ie. computer/internet) to submit files online with FINTRAC?

Part B

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B1 - Have you fully implemented a compliance regime in your company/organization?

B2 - If you answered no to question B1, please explain what aspects of the compliance regime you have not implemented (if any). If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer B2.

Part C

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C1 - Have you appointed a compliance officer responsible for implementing your compliance regime to meet your reporting, record-keeping and client identification obligations?

C2 - If you answered yes to question C1, provide the compliance officer's name.

C3 - Does your compliance officer report directly to the broker/nominee/owner?

C4 - How does your company/organization keep up with any changes in reporting, record-keeping or client identification obligations? FINTRAC's Web site, Web sites other than FINTRAC’s, via industry association, Media (newspaper, television, etc.), Seminars, training or conferences, or Other ways of keeping current.

Part D

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D1 - Do you have policies and procedures to ensure your reporting, record keeping and client identification requirements are being met?

D2 - Are these policies and procedures in writing?

D3 - Has your company/organization conducted financial transactions within the last 12 months with individuals or entities based in any of the countries on the Financial Action Task Force (FATF) List of Non-Cooperative Countries or Territories? For information about this list, please refer to FINTRAC's advisories at http://www.fintrac-canafe.gc.ca/publications/avs/1-eng.asp or go to www.realtorlink.ca and select the "Money Laundering Compliance Centre" link which also links to FINTRAC's advisories.

D4 - If you answered yes to question D3, which countries were involved and approximately how many transactions were conducted with each country? If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer D4.

D5 - Does your company/organization cross-reference the names of clients with any anti-terrorism lists of names published by the Canadian government? For more information about these, please refer to the List of Names Subject to the Regulations Establishing a List of Entities made under subsection 83.05(1) of the Criminal Code or the United Nations Suppression of Terrorism Regulations provided by the Office of the Superintendent of Financial Institutions (OSFI) at http://www.osfi-bsif.gc.ca or go to www.realtorlink.ca and select the "Money Laundering Compliance Centre" link which also links to the OSFI Web site.

Part E

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E1 - Have you implemented a process for reviewing your compliance policies and procedures to determine their effectiveness?

E2 - Has such a review already been conducted for your company/organization?

E3 - If you answered yes to question E2, how often do you plan on conducting a review? More than once a year, Once a year, Less than once a year

E4 - If you answered yes to question E2, the review was conducted by: (Check all that apply) Your Compliance Officer, External Auditor, Other Internal Auditor, Other

E5 - If you answered yes to E2, when was the review completed?

E6 - Are the results of the review documented?

Part F

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F1 - Does your company/organization provide training about your reporting, record keeping and client identification obligations?
If you answered yes to question F1, answer question F2 .

F2 - Describe how your training is delivered. Include information about the mode and frequency of delivery as well as a general description of who is required to take the training. If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs in answer F2.

Mode of training: In a classroom with trainer/Seminar, Self-directed, Computer-based, Other
Frequency of training: Yearly, More often than yearly (e.g., seasonally, quarterly, etc.) , When new staff is hired , In special circumstances
Who receives the training: All Staff, Brokers / Nominees / Managers, Sales Representatives, Other
Type of material: Handouts, Test, Presentation or group discussion, Other