FINTRAC Reporting for Money Services Businesses
Report triggers, deadlines, the 24-hour rule with worked examples, and the penalties for late, incomplete and missing reports.
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As a money services business, you file five kinds of report on four different clocks
Each report has its own trigger, its own deadline and its own required fields. Three of them add transactions together across a 24-hour window you define. One has no threshold at all. A ministerial directive removes the threshold from every transaction touching Iran.
Of the 2,593 violations behind FINTRAC's $176,960,190 penalty on Xeltox Enterprises in October 2025, 2,586 were reports that were never filed.
What you owe
Five reports, four deadlines, and a directive that removes the threshold
Suspicious transaction report (STR)
Any amount · As soon as practicable. Once you reach reasonable grounds to suspect, completed or attempted. The narrative must let another trained person reach the same view. The client is never told.
Large cash transaction report (LCTR)
$10,000 or more in cash · 15 calendar days. Counted from the day the cash arrives. Not owed when it comes from a financial entity or public body. The person handing it over and anyone they act for are both identified.
Large virtual currency transaction report (LVCTR)
Equivalent to $10,000 or more · 5 working days. Each report carries the transaction hash and the sending and receiving addresses. Validation rewards and currency received for your own operations are excluded.
Electronic funds transfer report (EFTR)
International, $10,000 or more · 5 working days. Owed by whoever starts a transfer leaving Canada and whoever pays out one arriving. Doing both, it turns on where sender and beneficiary live.
Transactions touching Iran
Any amount · On the usual form and clock. A ministerial directive in force since 25 July 2020 makes transfers, cash and virtual currency to or from Iran reportable below $10,000. Russia and North Korea are high risk at any amount.
Listed person or entity property report (LPEPR)
Any amount · Immediately. Filed with FINTRAC, and disclosed to the RCMP and CSIS, the moment you find a listed party's property. It replaced the terrorist property report and now covers Criminal Code, UN and Canadian sanctions lists.
A transaction becomes a report in one of two ways, and many trigger both
One is an amount. The other is what you know or suspect, at any amount. One transaction can owe both, each on its own deadline.
Triggered by an amount: threshold reports
Large cash (LCTR), large virtual currency (LVCTR) and electronic funds transfer (EFTR) reports. Each starts at $10,000, in one transaction or several added up under the 24-hour rule.
Triggered by what you know: judgement reports
Suspicious transaction reports (STR) for money laundering, terrorist financing and, since 19 August 2024, sanctions evasion. Listed person or entity property reports (LPEPR).
FINTRAC's 24-hour rule: add up by any of three links
Two or more transactions of the same type that total $10,000 or more inside one 24-hour window are reported together when they share any one of these.
The same conductor
The person physically or digitally carrying out each transaction.
The same third party
The person or entity on whose behalf it was carried out, even through different conductors.
The same beneficiary
The person or entity who ends up with the money, whoever sent it.
The window is consecutive, never longer than 24 hours, and documented in your policies; it can differ by business line. Identical matches on two links may be filed once; partial overlaps are all filed. Virtual currency for a public body, a listed corporation or trust with $75 million in net assets, or a regulated pension fund administrator is not added up. The 24-hour rule does not apply to suspicious transaction reports: every transaction is monitored for suspicion, with no threshold, no window and no direction.
No single transaction crossed $10,000, and the report is still owed
Four worked examples of the 24-hour rule, using one business's window. The amounts are illustrations; the rules applied to them are FINTRAC's.
One client, three visits: one LCTR for $10,500
Monday $4,000 cash at 10:15 a.m., $3,500 at 4:40 p.m., Tuesday $3,000 at 8:30 a.m. Added up by conductor, since Tuesday at 8:30 a.m. still sits in Monday's window (9:00 a.m. to 8:59 a.m.). Due within 15 calendar days.
Three senders, one beneficiary: one EFTR for $10,500
Transfers of $4,000, $3,500 and $3,000 to the same person paid abroad in the same window. Added up by beneficiary, though no sender came near $10,000. Due within five working days.
One deposit, three reports: LCTR, EFTR and STR
$12,000 cash in, sent abroad that day, out of line with the client. Cash within 15 calendar days, the transfer within five working days, the suspicion as soon as practicable.
The same total, two windows: no LCTR, but look again
$6,000 cash at 8:50 a.m. and $6,000 at 9:05 a.m., fifteen minutes apart across the window edge. Each window holds $6,000, so neither reaches $10,000. Splitting around a threshold is a pattern to assess for an STR.
What it costs
Late, incomplete and missing reports have each drawn a penalty Each unfiled report can be its own violation: one month of Xeltox's counted as 2,586.
Maximum per violation for a business: FINTRAC's stated increase of up to 40 times, from 26 March 2026, applied to the previous maximum beneath each figure.
Money services business penalties that cite a reporting failure
Appealed: the business has appealed the penalty to the Federal Court. Amounts are as imposed. In July 2024 alone, Xeltox did not file 1,518 large virtual currency reports or 1,068 suspicious transaction reports, some linked to darknet markets and ransomware.
How ComplyFactor helps
We file these reports every week, so you do not have to learn every rule Money services businesses, payment service providers and fintechs are our core practice, and reporting is most of that work.
Every report, on its own clock
STR, LCTR, LVCTR, EFTR and LPEPR prepared and filed with FINTRAC, each tracked against its own deadline.
Suspicion narratives that hold up
STR grounds written so another trained reader reaches the same view, with the indicators and parties FINTRAC expects.
The 24-hour rule in your monitoring
Windows set and documented, and aggregation by conductor, third party and beneficiary built into the logic that decides what gets filed.
Directive and sanctions reporting
Iran transactions reported at any amount, Russia and North Korea treated as high risk, and listed property disclosed to FINTRAC, the RCMP and CSIS.
Travel rule and missing details
The information that has to move with every transfer, and a written rule for when to allow, hold or reject one that arrives without it.
Backlogs found and filed
Months of unreported or incomplete transfers and cash reconstructed, completed and submitted, with a record of how the gap was closed.
Start with a reporting gap check
We take a month of your transactions, apply your 24-hour window, and compare what should have been filed with what was. You see the gap before FINTRAC counts it.
contact@complyfactor.com · +1 807 806 0444
Sources: FINTRAC guidance on STR, LCTR, LVCTR and EFT reporting and the 24-hour rule; FINTRAC Iran directive guidance; FINTRAC penalty notices; penalty policy and AMP changes page. ComplyFactor Reporting to FINTRAC Leave-Behind, current to 1 October 2026.
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