FINTRAC Large Cash Transaction Report: Filing, Deadlines, Penalties

A FINTRAC large cash transaction report is required whenever a reporting entity receives $10,000 or more in physical currency, either in a single transaction or through two or more linked transactions within a 24-hour window. The report must be filed electronically with FINTRAC within 15 calendar days of receiving the cash.1Financial Transactions and Reports Analysis Centre of Canada. Reporting Large Cash Transactions to FINTRAC The obligation is automatic once the threshold is met. It does not depend on whether the transaction looks suspicious, whether the customer is a regular, or whether the money is clearly legitimate.

What Triggers a Report

The trigger is the receipt of $10,000 or more in cash. FINTRAC defines cash narrowly: physical coins and bank notes issued by the Bank of Canada and intended for circulation, plus coins and bank notes issued by foreign countries.1Financial Transactions and Reports Analysis Centre of Canada. Reporting Large Cash Transactions to FINTRAC Cheques, money orders, bank drafts, other negotiable instruments, and virtual currency are not cash for this purpose. A $10,000 cheque does not trigger a report. Ten thousand dollars in paper bills does.

When the cash is foreign currency, convert it to Canadian dollars to test the threshold and record both the exchange rate and its source in the report.2Financial Transactions and Reports Analysis Centre of Canada. Record Keeping Requirements for Money Services Businesses and Foreign Money Services Businesses

The 24-Hour Rule

The threshold is not just per transaction. Two or more cash transactions that occur within any consecutive 24-hour window must be aggregated when they total $10,000 or more and share a common link: the same person conducting them, the same third party on whose behalf they are made, or the same beneficiary.3Financial Transactions and Reports Analysis Centre of Canada. Reporting Transactions to FINTRAC: The 24-Hour Rule

A $6,000 deposit at 10 a.m. and a $5,000 deposit at 3 p.m. the same day from the same customer total $11,000 and require a single LCTR. Catching those patterns is a systems problem, not a memory problem. Expecting front-line staff to recognize the second half of a split transaction hours later is not a compliance strategy.

Exemptions

Some large cash receipts are exempt. You do not have to file an LCTR when the cash comes from another financial entity, a public body such as a federal, provincial, or municipal government, or a person acting on behalf of one of those.1Financial Transactions and Reports Analysis Centre of Canada. Reporting Large Cash Transactions to FINTRAC The exemption does not extend to private individuals or businesses, regardless of size or reputation.

Who Has to File

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act designates a broad list of reporting entities. The main categories are:4Financial Transactions and Reports Analysis Centre of Canada. Who Must Report to FINTRAC

  • Financial entities, including banks, authorized foreign banks, credit unions, caisses populaires, trust companies, loan companies, and financial services cooperatives.
  • Life insurance companies, brokers, and agents when handling loans, prepaid payment products, or related accounts.
  • Money services businesses, including currency exchange providers, money transfer operators, and foreign MSBs serving Canadian clients.
  • Casinos, both private and government-run.
  • Real estate brokers, sales representatives, and developers when conducting property transactions.
  • Dealers in precious metals and precious stones.
  • Securities dealers.
  • Accountants and accounting firms when performing specified activities such as receiving or paying funds.
  • Mortgage administrators, brokers, and lenders.
  • British Columbia notaries and notary corporations.
  • Armoured car businesses.
  • Agents of the Crown that sell money orders or accept deposit liabilities.

Several new categories took effect in 2025: cheque cashers, factors, financing or leasing entities, title insurers, and acquirer services for private automated banking machines.4Financial Transactions and Reports Analysis Centre of Canada. Who Must Report to FINTRAC If your business fits any of these descriptions, the reporting obligation applies even if large cash receipts are rare.

What Goes in the Report

An LCTR captures information about the transaction, the person who conducted it, and any third party on whose behalf the cash was received. That information must be gathered before or at the time of the transaction.1Financial Transactions and Reports Analysis Centre of Canada. Reporting Large Cash Transactions to FINTRAC

Identifying the Individual

For the person conducting the transaction, the report requires full name, date of birth, home address, and occupation. Identity must be verified using government-issued photo identification, and the report records the type of ID, its number, issuing jurisdiction, and expiry date. If a dual-process method is used instead (two independent sources rather than one photo ID), both sources must be documented.1Financial Transactions and Reports Analysis Centre of Canada. Reporting Large Cash Transactions to FINTRAC

If the person at the counter is acting for a third party, the same level of identifying information is required for that third party. The person handing over the cash is not always the person who controls it, and the report has to capture both.

Beneficial Ownership for Corporate Clients

When a corporation is involved, the reporting entity must obtain the names of all directors and identify every individual who directly or indirectly owns or controls 25% or more of the corporation’s shares. Beneficial owners must be real individuals, not other corporations, trusts, or holding entities.5Financial Transactions and Reports Analysis Centre of Canada. Beneficial Ownership Requirements

You must also take reasonable measures to confirm that information is accurate. That can mean reviewing articles of incorporation or shareholder agreements, checking federal or provincial business registries, or obtaining a signed client declaration. High-risk entities and complex ownership structures require more.5Financial Transactions and Reports Analysis Centre of Canada. Beneficial Ownership Requirements

Since October 2025, corporations incorporated under the Canada Business Corporations Act that are assessed as high-risk carry an added step: the reporting entity must consult the Corporations Canada database and compare its beneficial ownership information against the listed individuals with significant control. Material discrepancies must be reported to Corporations Canada within 30 days.5Financial Transactions and Reports Analysis Centre of Canada. Beneficial Ownership Requirements

Transaction Details

The report also captures the exact date and time the cash was received, the amount and currency, any account numbers involved, the branch or location, the purpose of the transaction, and how the funds were received. Every field must be completed. An incomplete report can draw its own penalty, even when the transaction was properly flagged and filed on time.

How and When to Submit

LCTRs are submitted electronically through the FINTRAC Web Reporting System, a secure online portal for creating and sending individual reports.6Financial Transactions and Reports Analysis Centre of Canada. Using the FINTRAC Web Reporting System Access requires contacting FINTRAC by email to obtain login credentials.

High-volume filers can use the FINTRAC API for system-to-system transfers. A single API submission can include up to 500 transactions, and the bulk endpoint accepts up to 5,000 reports containing up to 5,000 transactions each, with a maximum file size of 300 MB.7Financial Transactions and Reports Analysis Centre of Canada. FINTRAC API Report Submission For any business processing meaningful cash volume, the API is far more workable than the web form.

Paper reporting is available only when a reporting entity genuinely lacks the technical capability to submit electronically.8Financial Transactions and Reports Analysis Centre of Canada. Paper Reporting Forms Most businesses will not qualify.

The 15-Day Deadline

Every LCTR must reach FINTRAC within 15 calendar days after the day the cash is received.1Financial Transactions and Reports Analysis Centre of Canada. Reporting Large Cash Transactions to FINTRAC Calendar days include weekends and holidays. A Friday transaction is counted from that Friday, not from the following Monday. Late filing is treated as a violation in its own right, separate from any problem with the content of the report.

Large Cash Reports Are Not Suspicious Transaction Reports

The LCTR and the Suspicious Transaction Report (STR) are separate obligations. The LCTR is mechanical: $10,000 or more in cash triggers it. The STR is judgment-based and must be filed whenever there are reasonable grounds to suspect a transaction is related to money laundering, terrorist financing, or sanctions evasion, regardless of the dollar amount.9Financial Transactions and Reports Analysis Centre of Canada. Financial Transactions Reported to FINTRAC

A $15,000 cash deposit that looks entirely normal still requires an LCTR. A $500 cash transaction with genuine red flags requires an STR. A $12,000 cash transaction that both crosses the threshold and looks connected to criminal activity requires both. Filing one never excuses the other.

Splitting the Cash Is a Crime

Breaking a large cash payment into smaller amounts to keep any of them below $10,000 is a criminal offence under section 77.3 of the PCMLTFA. The section captures any series of transactions that would have triggered a report if combined and were carried out with the intent to avoid that report.10Justice Laws Website. Proceeds of Crime (Money Laundering) and Terrorist Financing Act – Section 77.3

On summary conviction, the penalty is a fine or up to two years less a day in prison, or both. On indictment, the maximum is five years of imprisonment or a fine, or both.10Justice Laws Website. Proceeds of Crime (Money Laundering) and Terrorist Financing Act – Section 77.3 A customer who asks you to split a deposit “so there’s no paperwork” is asking you to help them commit that offence.

The Compliance Program Behind Every Report

Filing individual reports is only part of what FINTRAC expects. Every reporting entity must maintain a formal compliance program with five mandatory elements:11Financial Transactions and Reports Analysis Centre of Canada. Compliance Program Requirements

  • A designated compliance officer. In a small business the owner can serve; in larger organizations the role should sit with a senior-level person with access to management.
  • Written policies and procedures, kept current and, for entities other than sole proprietors, approved by a senior officer.
  • A documented risk assessment of how the business’s specific activities could be exploited for money laundering or terrorist financing.
  • A written ongoing training program for all employees, agents, and authorized persons who handle transactions or compliance functions.
  • A documented effectiveness review of the program, conducted at least every two years.

Record Retention

Records related to large cash transactions must be kept for at least five years from the date the record was created.2Financial Transactions and Reports Analysis Centre of Canada. Record Keeping Requirements for Money Services Businesses and Foreign Money Services Businesses Beneficial ownership records must be kept at least five years from the date of the last business transaction with the entity.5Financial Transactions and Reports Analysis Centre of Canada. Beneficial Ownership Requirements Those records must be available for examination during FINTRAC compliance audits.

Penalties for Missing or Botched Reports

FINTRAC enforces the reporting rules along two parallel tracks: administrative monetary penalties and criminal prosecution. They are not mutually exclusive.

Administrative penalties are set by violation category:12Financial Transactions and Reports Analysis Centre of Canada. Administrative Monetary Penalties

  • Minor violation: $1 to $1,000 per violation.
  • Serious violation: $1 to $100,000 per violation.
  • Very serious violation: $1 to $100,000 per violation for an individual, or $1 to $500,000 per violation for an entity.

The caps apply per violation, and multiple violations are penalized separately.13Justice Laws Website. Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations A single compliance examination that uncovers 50 unfiled LCTRs can produce 50 separate penalties. FINTRAC also publishes the names of entities that receive serious or very serious penalties.

On the criminal side, knowingly providing false or misleading information to FINTRAC, or withholding material information, can lead to imprisonment of up to five years on indictment. Failing to report prescribed financial transactions is a separate criminal offence, and employers who pressure staff not to fulfill reporting obligations face criminal liability of their own.14Justice Laws Website. Proceeds of Crime (Money Laundering) and Terrorist Financing Act The March 2026 amendments to the Act raised maximum monetary penalties across all criminal offence categories, with fines for the most serious offences reaching $20,000,000 on indictment.