FINTRAC Large Cash Transaction Report (LCTR): $10,000 Cash Threshold, Filing Rules and Examples

A FINTRAC Large Cash Transaction Report (LCTR) is the report a reporting entity must submit when it receives $10,000 or more in cash in a single transaction from a person or entity. This is Canada's core cash threshold reporting rule under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA): reach the threshold, and the report is mandatory, regardless of whether anything about the transaction looks unusual.

The $10,000 trigger is not the only path to an LCTR. Several smaller cash receipts that together add up to $10,000 or more within a consecutive 24-hour window can also require a report, if they share a common conductor, third party, or beneficiary. Once a large cash transaction is confirmed, the reporting entity has 15 calendar days to file. And filing an LCTR is a separate obligation from filing a suspicious transaction report (STR); reaching the threshold says nothing on its own about whether a transaction is suspicious. This article sets out exactly when an LCTR is required, what the report contains, and how it interacts with the other reporting and client-identification obligations a Canadian reporting entity carries.

What Is a FINTRAC Large Cash Transaction Report?

A Large Cash Transaction Report is the record a reporting entity files with FINTRAC when it receives $10,000 CAD or more in cash in a single transaction. The obligation attaches to the receipt of cash, not to a withdrawal, and not to every transaction a client conducts; it is triggered by a specific event crossing a specific dollar threshold.

The requirement applies to reporting entities across the sectors covered by the PCMLTFA, not to every Canadian business. A foreign money services business (FMSB) has a narrower version of the same obligation: it must file only when the $10,000 or more in cash is received from a person or entity located in Canada.

Cash Threshold Reporting in Canada: When Does the $10,000 Rule Apply?

A Single Cash Transaction of $10,000 or More

The most straightforward trigger is a single transaction: a reporting entity receives $10,000 or more in cash at one time, from one person or entity. The threshold is $10,000 or more, not more than $10,000; a transaction of exactly $10,000 crosses the line.

Example: a client walks into a currency exchange and hands over $10,000 in cash to purchase US dollars. That single receipt of cash meets the threshold on its own, and an LCTR is required, regardless of how the funds are subsequently used.

Multiple Cash Transactions Within 24 Hours

A reporting entity must also aggregate two or more cash amounts that together total $10,000 or more within a consecutive 24-hour window, where it knows the transactions are conducted by the same person or entity, conducted on behalf of the same person or entity (a third party), or intended for the same beneficiary. Two $6,000 cash deposits from the same client on the same day, for instance, meet this rule even though neither transaction reaches the threshold on its own. The window is a static 24-hour period the reporting entity defines in its own policies, not simply a calendar day, and it applies across branches and locations, not just a single till or counter.

Aggregation logic gets more complex once multiple conductors, third parties, and beneficiaries are involved, and the same set of transactions can sometimes trigger more than one report. For the full set of worked scenarios, including cross-branch and multi-party examples, see ComplyFactor's FINTRAC 24-hour aggregation rules guide.

Cash Received in Foreign Currency

Where cash is received in a foreign currency, convert the amount to Canadian dollars using the exchange rate published by the Bank of Canada in effect at the time of the transaction, to determine whether the $10,000 threshold has been reached. If the Bank of Canada does not publish a rate for that currency, the reporting entity uses the rate it establishes in the normal course of its own business at the time of the transaction. Either way, the method for selecting and sourcing the exchange rate needs to be documented in the entity's compliance policies and procedures, not decided case by case at the counter.

What Counts as Cash for FINTRAC Reporting?

Cash, for LCTR purposes, means coins and bank notes issued by the Bank of Canada that are intended for circulation in Canada, coins and bank notes of countries other than Canada, and fiat currency generally. It does not include cheques, money orders, or other similar negotiable instruments, and it does not include virtual currency.

This distinction matters operationally. A client who pays with a certified cheque or a money order, however large the amount, has not conducted a large cash transaction; that instrument may trigger other obligations, but not an LCTR. Virtual currency is reported under an entirely separate regime with its own $10,000 threshold, its own timeline, and its own form.

For the equivalent reporting obligation on cryptocurrency and other virtual currency receipts, ComplyFactor's dedicated LVCTR guide covers the current requirements; treat large cash transaction reporting and large virtual currency transaction reporting as two separate obligations that are never combined to reach a single threshold.

Who Must File a Large Cash Transaction Report?

All reporting entities covered by the PCMLTFA must comply with large cash transaction reporting requirements. In practice this spans financial entities, money services businesses (MSBs), securities dealers, casinos, dealers in precious metals and stones, and several other regulated sectors, each subject to the same core $10,000 rule. Not every Canadian business is a reporting entity; the obligation applies only to businesses and activities the PCMLTFA and its Regulations actually capture.

Responsibility for filing stays with the reporting entity itself, even where the work is delegated. If a reporting entity's own employee receives the cash, the employer is responsible for the report. If an agent conducts the transaction on behalf of another reporting entity, the principal reporting entity is responsible, not the agent, with one carve-out: this delegation rule does not apply to life insurance brokers or agents, unless they are acting as employees. A service provider can be engaged to submit and correct reports on a reporting entity's behalf, but the underlying legal responsibility cannot be handed off; the reporting entity remains accountable for accuracy and timeliness regardless of who keys in the data.

An FMSB carries the same $10,000 threshold, narrowed to transactions with a person or entity located in Canada, reflecting that an FMSB has no physical place of business in the country.

When Is an LCTR Not Required?

A reporting entity does not need to submit an LCTR for an amount of $10,000 or more in cash received from a financial entity, a public body, or a person acting on behalf of a client that is a financial entity or a public body. This exception exists because those counterparties are themselves regulated or governmental, not because the cash amount is somehow smaller.

Several sector-specific exceptions also apply and should not be generalized beyond the sector they cover. Life insurance companies, brokers, and agents are not required to file for reinsurance dealings, or for specific transaction types such as certain annuity sales funded directly from a registered pension plan, registered annuity policy or RRIF sales, annuities funded entirely by group life insurance proceeds, or reverse mortgages and structured settlements. Financial entities have a narrow exception allowing them to skip LCTR filing on certain corporate clients where they instead provide FINTRAC with specified information about those clients directly. And where a financial entity, life insurance company, or securities dealer operates foreign subsidiaries or branches, the large cash transaction reporting requirement does not extend to those operations outside Canada.

None of this is tax-related cash reporting advice; these exceptions sit entirely within the FINTRAC/PCMLTFA reporting framework and have no bearing on any separate tax reporting obligation a business may carry.

What Is the LCTR Filing Deadline?

An LCTR must be submitted to FINTRAC within 15 calendar days after the day the cash is received. The clock starts on the date of receipt, not the date the transaction is posted to an account, and it runs in calendar days, not business days.

Example: a business receives $14,000 in cash on a Thursday. The 15-calendar-day window runs from that Thursday, meaning the report is due within 15 calendar days of that date, weekends and holidays included. This is a materially different clock from the STR standard of "as soon as practicable," and from the separate, shorter deadline that applies to large virtual currency transaction reports. Treating any of these three timelines as interchangeable is a common source of late filing.

What Information Goes Into a Large Cash Transaction Report?

The LCTR form has four sections: general information, transaction information, starting action, and completing action. A single report can contain multiple transactions, and each transaction can contain multiple starting and completing actions, which is what allows related cash receipts within a 24-hour window to be aggregated into one filing rather than several.

General Report Information

This section captures the reporting entity's own details and contact information, its FINTRAC-assigned reporting entity number, a unique reference number the entity assigns to the report itself, the aggregation type used if multiple transactions are being combined (by conductor, third party, or beneficiary), and the 24-hour period start and end date/time, including time zone, that frames the aggregation window. Any applicable ministerial directive is also indicated here.

Transaction Information

Each transaction within the report needs its own date and time, the method by which the cash was received, the location where the transaction took place, and a threshold indicator confirming whether that specific transaction was, on its own, above or below $10,000 at the time of receipt. A purpose-of-transaction field captures why the client conducted the transaction, which is a different question from what happened to the money afterward; a client depositing cash tips to save toward a home purchase illustrates the distinction between purpose and disposition.

Starting Actions

The starting action describes how the transaction began: the amount and currency of cash actually received, whether information was obtained on how the conductor originally obtained that cash, and, separately, whether information on the source of the cash (a specific person or entity) was obtained. Conductor information (who physically carried out the transaction) and third-party information (who the transaction was actually conducted on behalf of, if anyone) are both captured here when applicable.

Completing Actions

The completing action records what happened to the cash after it was received: one or more dispositions such as a deposit to an account, a foreign currency exchange, an outgoing funds transfer, a purchase of a bank draft or money order, an investment product purchase, or another qualifying disposition type. Beneficiary information, meaning whoever ultimately benefits from that disposition, is captured within the completing action, along with any account or reference details tied to it. A single transaction can have more than one completing action; a client who brings in $12,000 cash and asks for $5,000 deposited and $7,000 exchanged into larger bills has two separate dispositions within the same transaction, each recorded as its own completing action.

This structure exists to let a reporting entity map exactly what a client instructed, rather than forcing a single cash receipt into an artificially simplified summary. It is not necessary to reproduce every individual form field to work with it correctly; the four-section structure above, and the role distinctions in the next section, cover what a compliance program actually needs to build a defensible filing process.

Source of Cash, Conductor, Third Party and Beneficiary: What Is the Difference?

Confusing these four roles is one of the most common sources of LCTR data errors, because in many everyday transactions two or more of them are the same person, which hides the distinction until a more complex transaction exposes it.

Source of Cash

The source of cash is the person or entity the cash actually came from, if that differs from the person conducting the transaction. This is a different question from how the cash was obtained (its origin, such as employment income or a sale of an asset); source of cash asks who provided it, not what economic activity generated it.

Conductor

The conductor is the person or entity who physically carries out the transaction with the reporting entity, the one handing over the cash at the counter or instructing the transaction. The conductor is not automatically the source of the cash, and is not automatically the beneficiary.

Third Party

A third party is the person or entity on whose behalf the transaction is actually conducted, when that differs from the conductor. This mirrors FINTRAC's broader third-party determination concept: the conductor is executing instructions, and the third party is the one giving them.

Beneficiary

The beneficiary is whoever ultimately benefits from the completing action, the recipient of the disposition, whether that is the conductor depositing cash into their own account or an entirely different person receiving a transfer.

A single example can carry all four roles at once. Daniel walks into an MSB with $12,000 in cash. His mother, Elena, gave him the cash and instructed him to send it to her friend Marcus to repay a personal debt. Here, Daniel is the conductor (he physically conducts the transaction), Elena is both the source of cash (the funds came from her) and the third party (the transaction is conducted on her instructions, on her behalf), and Marcus is the beneficiary (he receives the funds). No single person occupies more than one of these roles in this scenario, which is precisely the kind of transaction that exposes a monitoring system built only around "the customer" rather than around each distinct role.

Third-party status carries its own separate determination requirement, with its own questions, records, and escalation path. For the full workflow, see ComplyFactor's FINTRAC third-party determination requirements guide.

Identity Verification for Large Cash Transactions

A large cash transaction can independently trigger a requirement to verify the identity of the person or entity involved, on top of the reporting obligation itself. The precise timing and method depend on the reporting entity's sector and the specific circumstances of the transaction, and are addressed in FINTRAC's dedicated identity verification guidance rather than in the LCTR guidance itself. The point to build into an LCTR workflow is simply that reaching the $10,000 threshold is very often also an identity-verification trigger, so the two checks should run together operationally, not as separate afterthoughts.

Can an LCTR and an STR Be Required for the Same Cash Transaction?

Yes. An LCTR is threshold-based: it is required because the amount received meets or exceeds $10,000, full stop. A suspicious transaction report is suspicion-based: it is required when the reporting entity has reasonable grounds to suspect the transaction is related to money laundering or terrorist financing. Filing one does not substitute for the other, and a large cash transaction is not inherently suspicious simply because it crosses the reporting threshold; most transactions that trigger an LCTR are entirely legitimate.

Where the facts of a transaction do give rise to reasonable grounds to suspect, a separate STR obligation applies regardless of whether an LCTR has also been filed. For how to build a defensible STR narrative once that threshold is reached, see ComplyFactor's FINTRAC Suspicious Transaction Report requirements guide.

When Can an LCTR and an EFTR Both Apply?

If the disposition of a large cash transaction involves a reportable electronic funds transfer, both an LCTR and an Electronic Funds Transfer Report (EFTR) are required for the same underlying activity; one report does not absorb the other. A client who brings in $11,000 cash and instructs $6,000 of it sent internationally, for example, generates a cash receipt reportable on the LCTR and a disposition that may separately need to be reported as an EFT, depending on the transfer's own threshold and international character.

EFTR triggers, thresholds, and the 24-hour aggregation rules that apply specifically to electronic funds transfers are a distinct topic with their own current requirements; a compliance workflow that only checks the LCTR box on a mixed cash-and-transfer transaction risks missing a second, independently reportable event on the same file.

How to Submit an LCTR to FINTRAC

LCTRs must be submitted electronically, using either the FINTRAC Web Reporting System (suited to lower-volume filers entering reports one at a time) or FINTRAC API report submission (a system-to-system transfer suited to higher-volume, automated environments). A reporting entity without the technical capability to file electronically may use the paper form instead, but electronic filing is the default expectation under current FINTRAC rules.

Choosing between the Web Reporting System and API integration is a genuine operational decision that depends on filing volume, technical resources, and existing transaction systems, not a simple preference. For the full comparison, see ComplyFactor's guide to FINTRAC Web Reporting and API submission options.

What Records Must Be Kept After Filing an LCTR?

A reporting entity must keep a copy of every LCTR it submits for at least five years from the date the report was created. This retention obligation is separate from, and additional to, the broader client identification and transaction records a reporting entity keeps under its sector-specific recordkeeping guidance.

Beyond the report copy itself, several categories of supporting evidence are legally required rather than merely good practice, because they are what a compliance program relies on to demonstrate the threshold and aggregation determinations behind the filing: identity verification records tied to the transaction where verification was triggered, third-party determination records where a third party was identified, and the underlying transaction data supporting any aggregation or foreign-currency conversion decision. Retaining only the FINTRAC submission confirmation, without the transaction-level evidence behind it, is not sufficient; the confirmation shows a report was filed, not why it was correct.

Some additional practices sit on the useful-evidence side of the line rather than the strictly-required side: internal notes documenting why a particular exchange-rate source was chosen, a second reviewer's sign-off on the aggregation decision, or a branch-level log cross-referencing related transactions. These strengthen an examination file without being independently mandated by the LCTR guidance itself, and a compliance program should be clear internally about which of its retained records are legal minimums and which are internal controls layered on top.

What If an LCTR Is Late, Incomplete or Incorrect?

Responsibility for the accuracy of an LCTR rests with the reporting entity, even where a service provider or third-party software platform handles submission. Engaging a provider to file reports does not transfer legal accountability; the reporting entity remains responsible for ensuring what gets submitted is accurate and timely.

Where a reporting entity discovers instances of non-compliance with its large cash transaction reporting obligations, such as unfiled, late, or materially incorrect reports, FINTRAC strongly encourages submitting a voluntary self-declaration of non-compliance. A written self-declaration should identify the reporting entity and a contact person, describe the number and type of reports affected and the period involved, explain why the reports were missed, late, or incorrect, and set out a concrete plan and timeline to resolve the issue and submit any outstanding or corrected reports. FINTRAC's stated position is that the goal of the reporting regime is to improve compliance rather than simply to penalize it, and that voluntary, timely, non-repeated self-declarations made before an examination has been announced are treated differently from issues FINTRAC uncovers on its own; this is a meaningful incentive to self-report promptly, though it is not a guarantee against any consequence, and specific outcomes depend on FINTRAC's own assessment of the circumstances.

Current FINTRAC guidance does not publish a fixed correction deadline for an individual LCTR once submitted; the reporting entity's obligation is to identify, disclose, and resolve the issue without undue delay through the voluntary self-declaration process rather than to quietly amend the record. Concealing a known filing gap, rather than disclosing it, is not a defensible response under current guidance.

Common LCTR Reporting Mistakes

Treating the threshold as "more than $10,000" rather than "$10,000 or more," which misses transactions of exactly $10,000

Misclassifying a cheque, money order, or similar negotiable instrument as cash

Missing the foreign-currency conversion step, or applying it inconsistently across branches

Using an undocumented or ad hoc exchange-rate source instead of the Bank of Canada's published rate or a documented internal alternative

Confusing the conductor with the source of cash, particularly when a client hands over cash that visibly belongs to someone else

Confusing the beneficiary of a disposition with the third party on whose behalf the transaction was conducted

Failing to capture available source-of-cash information because the field was treated as optional rather than a reasonable-measures obligation

Leaving the purpose-of-transaction field generic or blank when the information was readily obtainable by asking the client

Treating the 24-hour rule as a simple calendar-day total instead of a static, organization-defined 24-hour window

Missing related cash transactions that occurred at a different branch or location within the same aggregation window

Assuming that filing an LCTR removes the need to separately consider an STR

Missing a related EFTR obligation created by the disposition of a large cash transaction

Inconsistent data capture between front-line staff or agents, producing incomplete starting or completing action records

Retaining only the FINTRAC submission confirmation rather than the underlying transaction and identity records the filing depended on

These are presented as operational risk areas seen across compliance programs generally, not as confirmed FINTRAC examination findings; any claim about a specific enforcement pattern should be checked against FINTRAC's own published penalty decisions before being repeated.

A Practical LCTR Filing Workflow

Detect the cash-receipt event as it occurs, at the point of transaction

Confirm the payment actually meets the definition of cash, not a cheque, money order, or virtual currency

Calculate the Canadian-dollar value, applying the documented exchange-rate process for foreign currency

Test whether the single transaction independently meets or exceeds $10,000

Check whether the transaction combines with others in the applicable 24-hour aggregation window

Verify identity where the transaction or the entity's own procedures require it

Complete the third-party determination for the transaction

Capture source-of-cash, conductor, and beneficiary information as available

Map the transaction into starting and completing actions that reflect the client's actual instructions

Review for a separate STR obligation and for any EFTR overlap arising from the disposition

Quality-check mandatory, mandatory-for-processing, and reasonable-measures fields before submission

Submit the report within the 15-calendar-day deadline

Retain the report and its supporting evidence in an examination-ready format

LCTR Compliance Checklist

Are systems correctly configured to detect the $10,000 or more single-transaction threshold, including transactions of exactly $10,000?

Is a documented, consistent process in place for converting foreign-currency cash receipts to CAD?

Is the organization's static 24-hour aggregation window defined in policy and applied consistently across branches?

Does transaction monitoring have visibility across all locations, not just the branch or till where a transaction occurred?

Are identity-verification triggers linked to LCTR-triggering transactions where applicable?

Is third-party determination completed and documented for large cash transactions where a third party is involved?

Is source-of-cash information captured whenever it is reasonably available, not just when a client volunteers it?

Are conductor and beneficiary information captured separately and correctly, rather than assumed to be the same person?

Is the 15-calendar-day filing deadline tracked from the date of cash receipt, not the posting date?

Is every LCTR-eligible transaction separately assessed for a possible STR obligation?

Is the disposition of large cash transactions checked for a related EFTR trigger?

Is there a documented quality-assurance step before submission, covering mandatory and reasonable-measures fields?

Is submission status tracked through to FINTRAC acknowledgement, not assumed on the basis of a single click?

Is there a documented process for voluntary self-declaration if a filing gap is discovered?

Are LCTR copies and their supporting evidence retained for the full five-year period in an examination-ready format?

How LCTR Controls Fit Into an AML Compliance Program

LCTR detection and filing should not sit as an isolated task assigned to whoever happens to be at the counter. Threshold and aggregation logic belongs in written policies and procedures, and those same procedures need to match what the entity's transaction systems actually do, not describe an idealized process nobody follows. Front-line staff and agents need training specific to recognizing a large cash transaction and capturing the right role information at the point of contact, since data quality problems almost always start there rather than in the reporting step itself. Escalation paths should route ambiguous cases (an unclear third party, a disputed source of cash) to compliance promptly, and quality-assurance testing should sample completed LCTRs the way a FINTRAC examiner would: checking the filing against the underlying transaction record, not just against itself.

An AML compliance program in Canada built around a business's actual transaction types is what connects LCTR detection, training, recordkeeping, and periodic effectiveness review into a single, examinable system rather than a set of disconnected controls.

Frequently Asked Questions

What is the cash reporting threshold in Canada?

$10,000 CAD or more received in cash in a single transaction, or two or more cash amounts totalling $10,000 or more within a consecutive 24-hour window that share a common conductor, third party, or beneficiary.

What is a FINTRAC Large Cash Transaction Report?

The report a reporting entity must file with FINTRAC when it receives $10,000 or more in cash in a single transaction (or an aggregated set of transactions under the 24-hour rule) from a person or entity.

Is the FINTRAC cash threshold $10,000 or more than $10,000?

$10,000 or more. A transaction of exactly $10,000 meets the threshold and requires reporting; the rule is not "more than $10,000."

How long do you have to file an LCTR with FINTRAC?

15 calendar days after the day the cash is received. The deadline runs in calendar days, not business days, and starts on the date of receipt, not the posting date.

Do multiple cash transactions under $10,000 need to be reported?

They can, under the 24-hour rule, if two or more cash amounts received within a consecutive 24-hour window total $10,000 or more and share a known common conductor, third party, or beneficiary.

Does a cheque count as cash for an LCTR?

No. Cheques, money orders, and similar negotiable instruments are explicitly excluded from the definition of cash used for large cash transaction reporting.

Do foreign-currency cash payments count toward the $10,000 threshold?

Yes. Foreign currency cash is converted to CAD using the Bank of Canada's published exchange rate at the time of the transaction (or a documented internal rate if the Bank of Canada does not publish one) to determine whether the threshold is met.

Does filing an LCTR mean the transaction is suspicious?

No. An LCTR is triggered by the dollar amount alone. Reaching the threshold does not, by itself, indicate anything suspicious about the transaction.

Can an LCTR and STR both be filed for the same transaction?

Yes. The two obligations are independent: LCTR is threshold-based, STR is suspicion-based. Facts that meet the suspicion standard require an STR regardless of whether an LCTR is also filed for the same transaction.

How long must an LCTR be retained?

At least five years from the date the report was created, in addition to the reporting entity's other client identification and transaction recordkeeping obligations.

Keeping Large Cash Transaction Reporting Defensible

A defensible LCTR program comes down to a short list of things done consistently: detecting the $10,000 threshold correctly, including exact-threshold transactions; applying 24-hour aggregation as a static window rather than a calendar-day total; capturing source of cash, conductor, third party, and beneficiary as the distinct roles they are; tracking the 15-calendar-day deadline from the date of receipt; separately assessing every large cash transaction for STR and EFTR overlap; and retaining the transaction-level evidence behind every filing, not just the submission confirmation.

None of this requires guesswork once the threshold, aggregation, and role distinctions are built correctly into a compliance program's policies and systems. If your current LCTR process cannot demonstrate these controls for a sample of filed reports, ComplyFactor's Canadian AML advisory team can help test and rebuild the workflow before FINTRAC does it for you.