FINTRAC Reporting & Compliance

FINTRAC Reporting Requirements: Reports, Thresholds, Deadlines & Filing Rules

A complete overview of FINTRAC reporting requirements in Canada β€” every report type, threshold, filing deadline and where to find detailed guidance for each one.

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Key takeaways

  • Canadian reporting entities may have to file up to six FINTRAC report types, depending on their business and the transactions involved: Suspicious Transaction Reports (STR), Large Cash Transaction Reports (LCTR), Large Virtual Currency Transaction Reports (LVCTR), Electronic Funds Transfer Reports (EFTR), Casino Disbursement Reports (CDR), and Listed Person or Entity Property Reports.
  • Most reports have a $10,000 CAD threshold and a 24-hour aggregation rule. STRs and Listed Person or Entity Property Reports have no monetary threshold at all.
  • Deadlines vary by report and by unit of time: STRs are filed "as soon as practicable," LCTRs and CDRs within 15 calendar days, EFTRs within 5 business days, and LVCTRs within 5 working days.
  • Which of these reports actually apply to your business depends on your sector and the transactions you handle β€” the sections below break that down report by report.

FINTRAC reporting requirements set out which transaction reports Canadian reporting entities must submit to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), what triggers each one, and the deadline for filing. The specific report, threshold and timeline depend on your sector and the transaction itself β€” a currency exchange MSB and a casino don't file the same reports, and not every MSB will ever file a Casino Disbursement Report.

This guide gives you the full picture in one place, then points you to ComplyFactor's detailed guide for each report type.

FINTRAC Reporting Requirements at a Glance

Report Type What Triggers It Threshold Filing Deadline Who It Applies To Detailed ComplyFactor Guide
Suspicious Transaction Report (STR) Reasonable grounds to suspect a transaction, completed or attempted, is related to money laundering, terrorist activity financing, or sanctions evasion. None As soon as practicable after completing the measures needed to establish reasonable grounds to suspect. All reporting entities STR narrative guide / No-file decision guide
Large Cash Transaction Report (LCTR) Receipt of $10,000 CAD or more in cash, in a single transaction or aggregated within 24 hours. $10,000 CAD Within 15 calendar days Reporting entities that receive cash, including MSBs, financial entities and casinos. Full LCTR guide
Large Virtual Currency Transaction Report (LVCTR) Receipt of virtual currency equivalent to $10,000 CAD or more, in a single transaction or aggregated within 24 hours. $10,000 CAD equivalent Within 5 working days Reporting entities that receive virtual currency Full LVCTR guide
Electronic Funds Transfer Report (EFTR) Sending or receiving an international electronic funds transfer of $10,000 CAD or more, in a single transaction or aggregated within 24 hours. $10,000 CAD Within 5 business days Financial entities, MSBs and casinos handling international EFTs. Full EFTR guide
Casino Disbursement Report (CDR) A casino disburses $10,000 CAD or more, in a single transaction or aggregated within 24 hours. $10,000 CAD Within 15 calendar days Casinos FINTRAC casino disbursement guidance
Listed Person or Entity Property Report An applicable disclosure obligation concerning terrorist or sanctioned property under the Criminal Code or relevant sanctions legislation. None Immediately upon discovery of the information All FINTRAC reporting entities FINTRAC listed person/entity property guidance

Thresholds and deadlines above reflect FINTRAC's published guidance as of September 2026. Confirm current requirements against FINTRAC's own guidance before relying on them for a filing decision, since regulatory guidance can change.

Who Has to Report Transactions to FINTRAC?

Reporting obligations attach to "reporting entities" β€” a defined list of business types under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), including money services businesses, financial entities, casinos, securities dealers, real estate professionals, and dealers in precious metals and stones, among others.

A currency exchange MSB, for example, may need to file LCTRs when it receives qualifying cash and STRs when the reasonable-grounds-to-suspect threshold is met. If it handles virtual currency, LVCTR obligations may also arise β€” but a Casino Disbursement Report applies only to casinos. Your specific mix of reporting obligations follows from your activities and the transactions you actually process, not from being a reporting entity in general.

For the full picture of who qualifies as a reporting entity and what registration and program obligations follow, see ComplyFactor's PCMLTFA requirements guide.

Suspicious Transaction Reports

As the table above shows, an STR carries no dollar threshold β€” a $50 transaction can trigger one if the suspicion is there. What "as soon as practicable" means in practice is the part worth understanding: it isn't a fixed number of days, but the more the filing is delayed after you've completed the measures needed to establish reasonable grounds to suspect, the more you need a documented, reasonable explanation for that delay.

Two related but separate pieces of ComplyFactor content go deeper on STRs: our guide to writing a defensible STR narrative, and our guide on documenting a decision not to file when you assess a transaction and conclude the reasonable-grounds-to-suspect threshold isn't met.

Large Cash Transaction Reports

The distinction worth flagging on LCTRs: "cash" here means physical currency only. Cheques, money orders and virtual currency are not treated as cash for LCTR purposes; virtual currency has its own LVCTR regime, while other instruments may create different recordkeeping or reporting obligations depending on the circumstances. The 15-calendar-day deadline runs from the day the cash is received, not from when you complete your internal review.

For the full threshold mechanics, required fields, exceptions and worked examples, see ComplyFactor's complete LCTR guide.

Large Virtual Currency Transaction Reports

Because virtual currency valuation shifts by the minute, correctly documenting the valuation method at the moment of receipt matters more here than it does for a cash-based LCTR. That level of detail β€” along with wallet information and aggregation examples β€” is covered in ComplyFactor's full LVCTR guide.

Electronic Funds Transfer Reports

The key distinction on EFTRs is scope: only international transfers are reportable β€” domestic transfers within Canada fall outside this report type entirely. The obligation applies whether you're the entity that initiates the transfer or the entity in final receipt of it, and the initiation-versus-final-receipt distinction, along with aggregation examples across multiple parties, is covered in ComplyFactor's full EFTR guide.

Other FINTRAC Reporting Obligations

Two further report types apply to a narrower set of reporting entities:

Casino Disbursement Reports apply only to casinos, and are triggered when a casino disburses $10,000 CAD or more, in a single transaction or aggregated within 24 hours. The filing deadline is 15 calendar days. If your business isn't a casino, this report type won't apply to you.

Listed Person or Entity Property Reports must be submitted immediately by reporting entities when an applicable disclosure obligation arises concerning terrorist or sanctioned property under the Criminal Code or relevant sanctions legislation. Unlike transaction reports, no transaction or minimum monetary amount is required to trigger this reporting obligation. This is distinct from, and sits alongside, sanctions evasion reporting obligations under Ministerial Directives.

How the 24-Hour Rule Affects Reporting

FINTRAC's 24-hour rule requires you to aggregate multiple transactions of the same type β€” cash, EFTs, virtual currency, or casino disbursements β€” when they total $10,000 or more within a consecutive 24-hour window and are linked by the same conductor, the same person acting on someone's behalf, or the same beneficiary. In practice, this means a series of smaller transactions can still trigger a report even though no single transaction crosses the threshold on its own.

The rule applies slightly differently to each report type and gets more complex with multiple locations, multiple parties, or transactions crossing time zones. ComplyFactor's dedicated 24-hour rule guide walks through the aggregation mechanics and worked examples in detail.

FINTRAC Reporting Deadlines

FINTRAC deadlines aren't calculated the same way across every report type. LCTRs and CDRs use calendar days, EFTRs use business days, and LVCTRs use working days, while STRs follow the "as soon as practicable" standard rather than a fixed count. The master table above summarizes the applicable deadline for each report β€” the practical risk is treating these units of time as interchangeable, since a calendar-day count and a business-day count from the same transaction date won't land on the same deadline.

Information Required When Filing a FINTRAC Report

FINTRAC transaction-report forms generally capture business information, transaction details, and relevant starting and completing actions. STRs also include a free-text narrative section explaining the grounds for suspicion. The exact fields vary by report type, while the Listed Person or Entity Property Report follows a separate property-reporting format.

Fields fall into categories β€” mandatory, mandatory for processing, mandatory if applicable, and reasonable measures β€” and the level of effort required to obtain missing information varies accordingly. Rather than duplicate every field across every report form here, each dedicated ComplyFactor guide linked above covers the specific fields for that report type.

FINTRAC also requires reporting entities to retain a copy of submitted reports for at least 5 years.

Correcting or Updating a Submitted FINTRAC Report

FINTRAC permits previously submitted reports to be changed or corrected where required. The applicable process depends on the report type and circumstances, so see ComplyFactor's FINTRAC report corrections guide for the detailed procedure.

FINTRAC Web Reporting vs API Reporting

Reports can be submitted electronically through the FINTRAC Web Reporting System (FWR) or through FINTRAC API report submission, which allows direct system-to-system transfer. Businesses without the technical capability to report electronically must use paper forms β€” though Listed Person or Entity Property Reports must always be filed on paper, regardless of your electronic capability.

Choosing between FWR and API submission is largely a question of reporting volume and internal systems, not a compliance requirement in itself. ComplyFactor's FINTRAC API vs Web Reporting comparison walks through the practical trade-offs.

Common FINTRAC Reporting Mistakes

Reporting errors tend to repeat across report types rather than being unique to any one of them:

  • Missing deadlines, often from confusing calendar days with working or business days across different report types.
  • Misapplying the 24-hour rule β€” either missing an aggregation trigger entirely, or aggregating transactions that don't actually share a conductor, third party or beneficiary.
  • Incomplete transaction data, particularly around third parties, beneficiaries and source of funds, where "reasonable measures" fields get skipped rather than pursued.
  • Inconsistent internal escalation, where front-line staff flag something unusual but it doesn't reach the person responsible for the reporting decision in time.
  • Filing the wrong report, or filing only one report when a transaction actually triggers two β€” a large cash transaction that's also suspicious requires both an LCTR and an STR.
  • Weak documentation, especially around exchange rates used for virtual currency valuation or the rationale behind an aggregation decision.

For the technical, field-level causes of report rejections and warnings, see ComplyFactor's FINTRAC report validation errors guide.

Building a Reliable FINTRAC Reporting Process

A reporting obligation is only as good as the process behind it. In practice, that means:

  • Clear internal escalation paths from front-line staff to whoever makes the final reporting decision.
  • Documented procedures covering exchange-rate selection, aggregation logic, and third-party determination.
  • Regular training refreshed as your products, customer base or geographies change.
  • Quality assurance sampling of submitted reports to check for consistency and completeness β€” not just after an examination flags a problem.
  • Recordkeeping that can produce a submitted report and its supporting rationale within minutes, not days.

This is where reporting connects to your broader compliance program. If your reporting gaps trace back to weak governance, unclear ownership, or a program that hasn't been reviewed in a while, that's a conversation for ComplyFactor's AML compliance program services or fractional compliance officer support β€” not something a reporting checklist alone will fix.

Automating FINTRAC Reporting Workflows

Manually tracking thresholds, aggregation windows and deadlines across five or six report types gets harder as transaction volume grows. Reporting automation can help streamline report preparation, apply report-specific validation before submission, route reports through review and approval, track acknowledgements and warnings, and preserve a complete audit trail from source data through to FINTRAC's response.

Automation supports the reporting process β€” it does not replace your compliance officer's judgment on whether reasonable grounds to suspect exist, or your organization's legal responsibility for what gets filed. ComplyFactor's FINTRAC Reporting Automation platform is built around that distinction: the software handles aggregation checks, validation and workflow; your compliance team keeps the decisions.

FAQs

Does every $10,000 transaction have to be reported to FINTRAC?

Not automatically. A $10,000 cash transaction triggers an LCTR, a $10,000 international EFT triggers an EFTR, and so on β€” but the report type depends on what kind of transaction it is, and some reporting entities (like casinos, for CDRs) only file certain report types in the first place.

Who is responsible for FINTRAC reporting when a service provider files on your behalf?

The reporting entity, not the service provider. You can contract a third party to prepare or submit reports for you, but the legal responsibility for meeting FINTRAC's requirements β€” including the accuracy and timeliness of what's filed β€” stays with your business and cannot be delegated away.

Can one transaction trigger more than one FINTRAC report?

Yes. Report types aren't mutually exclusive, and a single transaction can meet the criteria for several at once. A large cash deposit that's also suspicious requires both an LCTR and an STR; a large cash transaction that's then wired internationally can trigger an LCTR and an EFTR. Each applicable report must be filed β€” filing one doesn't satisfy the others.

Can one FINTRAC report contain multiple transactions?

Yes, but this is a different concept from the 24-hour aggregation rule. Aggregation is about when you're required to report β€” combining smaller transactions that cross a threshold together within 24 hours. Separately, a single report form can include multiple transactions, starting actions and completing actions where that reflects what actually happened, regardless of whether aggregation applies.

Do attempted transactions need to be reported to FINTRAC?

For STRs, yes β€” an attempted transaction can trigger a suspicious transaction report on the same basis as a completed one. Reporting entities should not assume that a transaction being refused, cancelled or abandoned by the client removes the reporting obligation if reasonable grounds to suspect already existed.

Sources

This article reflects FINTRAC guidance as of September 2026. Reporting requirements are subject to regulatory change β€” confirm current obligations against FINTRAC's official guidance before relying on this content for a filing decision. This article is general information, not legal advice.

ComplyFactor Advisory Team

ComplyFactor specializes in FINTRAC MSB and PSP registration, independent AML effectiveness reviews, and compliance program design for Canadian and foreign money services businesses, payment service providers, fintechs, and virtual asset service providers.

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