If your business is registered with FINTRAC, you have five categories of reports you may be required to file. Missing any one of them is a compliance violation under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. The reports are: Large Cash Transaction Reports, Suspicious Transaction Reports, Electronic Funds Transfer Reports, Casino Disbursement Reports, and Terrorist Property Reports.
Each has its own trigger, its own threshold, and its own filing deadline. This post breaks all five down so you know exactly what you are required to file, when, and why getting it wrong is costly.
- Why FINTRAC reporting matters more than most operators realize
- Large Cash Transaction Report (LCTR): threshold, 24-hour aggregation, deadline
- Suspicious Transaction Report (STR): what triggers it and when to file
- Electronic Funds Transfer Report (EFTR): international EFTs and the 5-day window
- Terrorist Property Report (TPR) and Casino Disbursement Report (CDR)
- The most common reporting mistakes MSBs make
- What happens when you miss a required filing
- Reporting requirements when buying an MSB
Why FINTRAC Reporting Matters More Than Most Operators Realize
Missed or late transaction reports are one of the most common reasons FINTRAC takes enforcement action against MSBs. Often it is not dramatic non-compliance that triggers a penalty. It is a pattern of missed Large Cash Transaction Reports, or a Suspicious Transaction Report that was identified but never filed.
FINTRAC examines your reporting history when it reviews your business. It compares what you filed against the transactions your records show actually occurred. A gap between the two is a finding. A pattern of gaps is grounds for administrative monetary penalties or, in serious cases, FINTRAC revocation proceedings.
Understanding your filing obligations is how you protect your registration.
The Five FINTRAC Reports Every MSB Should Know
Here is a quick reference before the full breakdown. Each report type, its trigger, threshold, and filing window at a glance:
| Report | Trigger | Threshold | Filing Window |
|---|---|---|---|
| LCTR | Cash received from a client | $10,000+ (incl. 24-hr aggregation) | 15 calendar days |
| STR | Reasonable grounds to suspect ML/TF | No threshold | 30 days (as soon as practicable) |
| EFTR | International electronic funds transfer | $10,000+ (incl. 24-hr aggregation) | 5 business days |
| TPR | Terrorist property identified | Any amount | Immediately |
| CDR | Casino disbursements | Casinos only | Casinos only |
Large Cash Transaction Report (LCTR)
LCTRThe LCTR is the most frequently filed report for most MSBs.
You must file an LCTR when you receive $10,000 or more in cash from a single client in a single transaction, or in two or more related transactions within a 24-hour period.
Cash under the PCMLTFA means physical currency. It includes Canadian dollars and foreign currency. It does not include cheques, wire transfers, or other non-physical payment methods.
The 24-Hour Aggregation Rule
This is the part that catches operators off guard.
If a client conducts multiple cash transactions with your business in a 24-hour window that together total $10,000 or more, you are required to treat them as a single transaction and file an LCTR. It does not matter that no single transaction hit the threshold on its own.
The 24-hour window starts from the first transaction. Your staff need to be tracking this in real time, because the obligation triggers the moment the combined total hits $10,000, not at the end of the business day.
LCTR Filing Deadline
Filing late is a violation. Filing never is worse.
When You Do Not Have to File
There is one limited exception. You are not required to file an LCTR for cash received from a financial entity or a public body, because those entities are themselves regulated under the PCMLTFA. In practice, for most MSBs, this exception rarely applies.
Suspicious Transaction Report (STR)
STRThe STR is the report with the most judgment involved, which also makes it the one most commonly handled incorrectly.
There is no dollar threshold for an STR. You do not need to be certain that money laundering or terrorist financing is happening. You need to have reasonable grounds to suspect it.
What Reasonable Grounds to Suspect Actually Means
This is not the same as a gut feeling, but it is also not the same as having proof.
Reasonable grounds to suspect means you have observed facts or circumstances that would lead a reasonable person with your knowledge and experience to suspect the transaction is related to money laundering or terrorist financing. If you can articulate specific reasons, you likely have reasonable grounds.
FINTRAC publishes indicators to help. Common ones include clients who are unusually secretive about the purpose of a transaction, transactions that have no apparent business rationale, clients who structure transactions just below a reporting threshold, and clients who provide false or inconsistent identification.
You Must Still Complete the Transaction Before Filing
One thing operators get wrong: you generally should not refuse the transaction simply because you plan to file an STR. The PCMLTFA requires you to complete the transaction and then file the report. There are limited exceptions where you may be legally required to stop, but for most suspicious transaction scenarios, completion followed by reporting is what the law requires.
STR Filing Deadline
As soon as practicable is taken seriously. Waiting 29 days for a transaction that raised immediate red flags will not satisfy FINTRAC’s expectations.
Electronic Funds Transfer Report (EFTR)
EFTRThe EFTR applies to international wire transfers, not domestic ones.
You must file an EFTR when you send or receive an electronic funds transfer of $10,000 or more on behalf of a client, where the transfer crosses a Canadian border. That means either leaving Canada to a foreign country or arriving in Canada from abroad.
Incoming vs. Outgoing EFTs
Both directions trigger the reporting obligation. If you receive $10,000 or more in a wire from a client in another country, you file an EFTR. If you send $10,000 or more on behalf of a client to a recipient outside Canada, you file an EFTR.
The 24-Hour Aggregation Rule Also Applies Here
The same aggregation logic from LCTRs applies. If a client initiates multiple international transfers within a 24-hour period that together total $10,000 or more, those must be reported.
EFTR Filing Deadline
Terrorist Property Report (TPR)
TPRThe TPR is different from the other reports in one critical way: there is no threshold and the filing obligation is immediate.
If you know or believe you have property in your possession that belongs to or is controlled by a terrorist group, a listed entity under the Criminal Code, or a person facilitating terrorist activity, you must file a TPR. Immediately.
Most MSBs will never encounter this situation in a straightforward form. The more realistic scenario is where a client or a transaction pattern starts to appear on a watch list or generates suspicion that connects to terrorist financing rather than standard money laundering. In that case, both an STR and a TPR may be required.
Casino Disbursement Report (CDR)
CDRCDRs apply specifically to casinos and are not a filing obligation for most MSBs. If your business does not operate gaming facilities, this report does not apply to you. Knowing it exists matters because your MSB compliance program should clearly identify which of the five report types are relevant to your specific activities.
Third-Party Determination: When a Client Is Acting for Someone Else
When a client conducts a transaction that triggers a reporting obligation, you must determine whether they are acting on behalf of a third party. If they are, collect information about that third party and include it in your report.
This determination must happen at the time of the transaction. Missing it is a separate compliance failure from the filing itself, and FINTRAC treats it as such during examinations.
The Most Common Reporting Mistakes MSBs Make
After working with MSB operators on MSB compliance programs and FINTRAC examinations, the same gaps appear regularly.
How Reporting Connects to Your Compliance Program
Your reporting obligations do not operate in isolation. They are one part of the MSB compliance program your business is required to maintain under the PCMLTFA.
The compliance program must include the written procedures your staff follow when a transaction hits a reporting threshold, the training your employees receive on recognizing suspicious transaction indicators, and the record-keeping practices that document what was filed and when.
When FINTRAC examines your business, it looks at all three together. Strong reporting history with weak training documentation raises questions. Clean records with gaps in actual filings raise different questions. Both lead to findings.
If your MSB compliance program does not specifically address how your business handles each of the five report types, it is not complete. See our overview of FINTRAC and what it does for what a full compliance program must cover.
What Happens When You Miss a Required Filing
FINTRAC does not have a first-offence grace period for missed reports.
A single missed LCTR or STR is a violation of the PCMLTFA. If FINTRAC’s examination uncovers it, it goes into the examination findings. Repeated misses produce a pattern. A pattern is what leads to formal enforcement action.
Administrative monetary penalties for reporting violations can reach significant amounts depending on the nature of the violation and how many instances FINTRAC identifies. In cases where the missed filings are part of a broader compliance failure, FINTRAC has the authority to revoke the MSB’s registration entirely.
If your business has received a notice of examination findings or a proposed penalty, see our guide to FINTRAC revocation and how to respond before the deadline to reply passes.
Reporting Requirements When You Are Buying an MSB
This matters if you are in the process of buying an MSB in Canada.
An MSB’s FINTRAC reporting history transfers with the business. If FINTRAC examines the business after the ownership change and finds reports were systematically missed before the sale, that finding reflects on the business’s record.
More practically, if the seller has missed filings and FINTRAC is already investigating, you as the new owner can walk into an active enforcement situation. A full compliance and reporting history review before signing is part of any proper due diligence process. See our guide to buy an MSB in Canada for what that review must cover.
Frequently Asked Questions
How often does FINTRAC examine MSBs for reporting compliance?
What is the penalty for missing a Large Cash Transaction Report?
Am I allowed to tell a client I filed a Suspicious Transaction Report about them?
Does the 24-hour aggregation rule apply to electronic funds transfers as well as cash?
Do Foreign Money Services Businesses have the same FINTRAC reporting obligations?
Conclusions
FINTRAC reporting requirements are specific, the deadlines are fixed, and there is no version of this where we did not know the rule protects you.
If your MSB does not have clear, written, staff-trained procedures for each of the five report types, that is a gap in your compliance program. If you are unsure whether your current practices meet the standard, a compliance review before your next FINTRAC examination is the right time to find out.
Cloudhaus Law handles MSB compliance program reviews, FINTRAC examination support, and enforcement proceedings for MSBs across Canada. Reach out for a free consultation.
Questions About Your FINTRAC Reporting Obligations?
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