Every deal carries its own fraud and money-laundering risk record, separate from anything you've recorded about the people on it - a deal with two low-risk borrowers can still be a high-risk transaction, which a per-person check can't catch. BrokerPlus asks it as one set of twenty-four questions, grouped the way you'd actually work them.
When You'd Use This
Fill this in as part of getting a deal's compliance record ready for submission, alongside identity, PEP, and the information record - it's the deal's own FINTRAC record, not a client's.
What the Groups Cover
Open the deal's compliance record and find "Fraud & AML risk factor assessment," a collapsed card stacked below the Know Your Client (KYC) and PEP check card and the Third party determination card. Its header always shows how many of the twenty-four questions are answered and how many are flagged, so you don't have to open it to know where it stands. Inside are six groups: client identification and interaction (prior relationship, criminal history, face-to-face verification, an intermediary representing the client, concealed identity); transaction behaviour (unknown-source transfers, broad geography in one day, unusual payment methods, unjustified cash, a profile/cash-flow mismatch, unusual for occupation or history, sparse records, anything else unusual); residency and location (Canadian citizenship or residency, a nearby border crossing, an area associated with organized crime, a high-crime area); intermediaries and beneficial ownership; offshore activities and high-risk connections; and PEP and other high-risk indicators.
Answering No to Everything
Every question is written so the answer worth a second look is the one that stands out, which makes "Answer No to All" a safe shortcut for the ordinary file. It's a blunt tool, though: three questions - prior relationship, face-to-face verification, and Canadian residency - are phrased the other way round, where yes is the safe answer and no is flagged. The button sets a literal no on all twenty-four, so if you use it, flip those three back to yes wherever true, or the summary shows flags that don't reflect anything unusual about the client.
The Third Party Determination
A separate card on the same page asks you to describe, in your own words, the methods used to evaluate whether a third party is influencing any borrower on this deal. This is a deal-level note, not the structured determination you record per applicant on their information record - that one names the third party and how you determined it; this one is the methodology behind the file as a whole.
Saving Before You Finish
Nothing here autosaves. The fraud card and the third-party card each keep their own Save changes button, and a floating bar tracks you down the page while the fraud card is dirty, so you're never scrolling back up to save two dozen answers. Discard resets it to whatever was last saved.
Common Gotchas
- The three inverted questions are the trap in "Answer No to All." It sets prior relationship, face-to-face verification, and Canadian residency to no along with everything else - all three read as flagged until you switch them back.
- Leaving the page loses unsaved fraud answers. Nothing writes until you press Save; a warning fires if you navigate away with the card dirty.
- This note and the information record's third-party determination are two different fields. Filling in one doesn't satisfy the other.
What to Do Next
- Complete a Client's Information Record for the per-applicant third-party determination.
- Record a Politically Exposed Person Attestation for the PEP question this card only flags.
- Tour the Compliance Record on a Deal for where this fits among everything else.