FINTRAC Reporting Requirements: Thresholds, Deadlines, and Penalties

FINTRAC reporting requirements apply to businesses in designated sectors under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, and they turn on a handful of transaction triggers. The core threshold is $10,000 in Canadian dollars for large cash, international electronic funds transfers, virtual currency, and casino disbursements. Suspicious transactions have no minimum at all. Each report type carries its own deadline, and every reporting entity must back its filings with a written compliance program.1Financial Transactions and Reports Analysis Centre of Canada. Mandate

Is Your Business a Reporting Entity

The Act reaches further than banking. Reporting entities as of 2025 include financial entities (banks, credit unions, caisses populaires, trust companies), money services businesses (currency dealers, money transfer operators, armoured car companies, crowdfunding platforms, payment service providers, virtual currency dealers, and, as of April 1, 2025, cheque cashers), life insurance companies and brokers, securities dealers, real estate brokers and developers, casinos (including online lottery operators), dealers in precious metals and stones, accountants, British Columbia notaries, mortgage brokers, agents of the Crown, and, newly added on April 1, 2025, factoring companies and financing or leasing entities.2Financial Transactions and Reports Analysis Centre of Canada. FINTRAC Annual Report 2024-25

If your business appears on that list, you must register with FINTRAC and maintain a compliance program. If it does not, the reporting rules below do not attach to your operations, though a suspicious transaction voluntarily reported by anyone can still be received.

The Reports and Their Thresholds

Large Cash Transaction Report

File a Large Cash Transaction Report when you receive $10,000 or more in cash, whether in one transaction or through multiple transactions totalling that amount within a 24-hour period. Cash means Canadian and foreign bills and coins; cheques, money orders, and other negotiable instruments do not count.3Financial Transactions and Reports Analysis Centre of Canada. Financial Transactions Reported to FINTRAC

Electronic Funds Transfer Report

An Electronic Funds Transfer Report is required when you initiate or finally receive an international electronic funds transfer of $10,000 or more in a single transaction. It applies to financial entities, casinos, money services businesses, and foreign money services businesses. Purely domestic electronic transfers do not trigger this report.4Financial Transactions and Reports Analysis Centre of Canada. Reporting Electronic Funds Transfers to FINTRAC

Large Virtual Currency Transaction Report

File a Large Virtual Currency Transaction Report when you receive virtual currency equivalent to $10,000 or more in a single transaction, or when two or more amounts from the same person or entity total $10,000 or more within 24 hours. Receipt is treated as the moment the transaction can no longer be reversed or cancelled.5Financial Transactions and Reports Analysis Centre of Canada. Reporting Large Virtual Currency Transactions to FINTRAC

Casino Disbursement Report

Casinos must file a Casino Disbursement Report on any single disbursement of $10,000 or more, whether paid in cash, chips, or another form. The rule applies to all casinos authorized to operate in Canada, including operators of online lottery schemes.6Financial Transactions and Reports Analysis Centre of Canada. Reporting Casino Disbursements to FINTRAC

Suspicious Transaction Report

Suspicious Transaction Reports have no dollar threshold. File one whenever you have reasonable grounds to suspect a transaction, completed or attempted, relates to money laundering or terrorist financing. A $50 transfer that follows an unusual pattern is reportable on the same basis as a $500,000 wire. The test is deviation from a client’s normal financial behaviour, not size.7Financial Transactions and Reports Analysis Centre of Canada. Reporting Suspicious Transactions to FINTRAC

Listed Person or Entity Property Report

If you possess or control property owned or controlled by a listed terrorist group or a person subject to sanctions under the Criminal Code, the United Nations Act, the Special Economic Measures Act, or the Justice for Victims of Corrupt Foreign Officials Act, file this report immediately.8Financial Transactions and Reports Analysis Centre of Canada. Reporting Listed Person or Entity Property to FINTRAC

The 24-Hour Aggregation Rule

The $10,000 threshold is not just a single-transaction test. Multiple smaller transactions of the same type must be added together when three conditions are all met: they total $10,000 or more in Canadian dollars (or equivalent), they occur within the same 24-hour window, and they share an aggregation link, meaning they were conducted by the same person, on behalf of the same third party, or for the same beneficiary.9Financial Transactions and Reports Analysis Centre of Canada. Reporting Transactions to FINTRAC: The 24-Hour Rule

Your business must define a static 24-hour window (for example, 9:00 a.m. Monday to 8:59 a.m. Tuesday) and document it in your compliance policies. A single transaction cannot span two windows. Aggregated transactions go into one combined report, not separate filings. If you operate multiple locations, the rule applies across all of them, not per branch. Without a system that flags and links transactions across branches, it is easy to miss a reportable combination of deposits or transfers that individually look routine.

Filing Deadlines

Each report type has its own clock, and missing the deadline is itself a violation:

  • Large Cash Transaction Reports: within 15 calendar days after the day you receive the cash.10Financial Transactions and Reports Analysis Centre of Canada. Reporting Large Cash Transactions to FINTRAC
  • Electronic Funds Transfer Reports: within 5 business days after you initiate or finally receive the transfer.
  • Large Virtual Currency Transaction Reports: within 5 working days (Monday to Friday, excluding public holidays) after you receive the virtual currency.
  • Suspicious Transaction Reports: as soon as practicable after you have completed the measures that let you conclude reasonable grounds to suspect exist. FINTRAC treats these as a priority, and delays require justification.
  • Listed Person or Entity Property Reports: immediately upon discovery.

The gap between 15 calendar days for cash and 5 business days for electronic transfers is a common source of missed filings. Track each deadline in your compliance calendar rather than leaving it to memory.

How to Submit

Reporting entities with an internet connection must submit reports electronically through the FINTRAC Web Reporting System. To gain access, contact FINTRAC at F2R@fintrac-canafe.gc.ca to set up your credentials. The web form is intended for lower-volume filers: fill out the standardized form online, validate, and submit.11Financial Transactions and Reports Analysis Centre of Canada. FINTRAC Web Reporting System

High-volume reporters should use the FINTRAC API for batch submission. The web system also supports uploading batch files in XML, JSON, or other supported formats for entities transitioning from the legacy CloudMask system. After submission, save the electronic confirmation of receipt. That confirmation is your proof of compliance during an examination. Paper submissions are allowed only when you genuinely lack the technical capability to file electronically, and they take longer to acknowledge.12Financial Transactions and Reports Analysis Centre of Canada. Methods to Report to FINTRAC

Record Keeping

Keep copies of all submitted reports and underlying transaction records for at least five years. The retention clock starts on different dates depending on the record:13Financial Transactions and Reports Analysis Centre of Canada. Record Keeping Requirements for Money Services Businesses and Foreign Money Services Businesses

  • Suspicious Transaction Reports and Listed Person or Entity Property Reports: five years from the date submitted.
  • Large Cash, Large Virtual Currency, and Electronic Funds Transfer Reports: five years from the date created.
  • Transaction records, including records of transactions of $3,000 or more, remittance records, and foreign or virtual currency exchange tickets: five years from the date created.
  • Service agreement records: five years from the date of the last transaction under that agreement.

Records must be retrievable within 30 days of a FINTRAC request. Electronic storage is fine as long as you can produce a paper copy on demand. If another federal or provincial regulator imposes a longer retention period, the longer one applies.

The Compliance Program Behind the Reports

Filing is only part of the obligation. Every reporting entity must build and maintain a compliance program with five elements:14Financial Transactions and Reports Analysis Centre of Canada. Compliance Program Requirements

  • A compliance officer with the authority and access to resources needed to run the program. Sole proprietors can appoint themselves; larger businesses should choose someone senior with access to the board.
  • Written policies and procedures covering all PCMLTFA obligations, approved by a senior officer and updated as rules change.
  • A documented risk assessment specific to your business, using FINTRAC’s national risk assessment as a starting point and adding sector intelligence.
  • An ongoing training program in writing, with proof that staff, agents, and other authorized persons actually received the training.
  • An independent effectiveness review at least every two years, documented in writing.

Day-to-day tasks can be delegated to staff at other branches, but responsibility for the program stays with the compliance officer. During an examination, FINTRAC will want to see documentation of all five elements, not just filed reports.

Penalties for Non-Compliance

FINTRAC enforces the rules through administrative monetary penalties and, in serious cases, criminal prosecution. Administrative penalties are tiered:15Government of Canada. Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations

  • Minor violations: $1 to $1,000 per violation.
  • Serious violations: $1 to $100,000 per violation.
  • Very serious violations: $1 to $500,000 per violation.

A run of minor violations can escalate: if the penalties on a single notice total $10,000 or more, the combined violations are reclassified as serious. On the criminal side, non-compliance offences carry penalties on indictment of up to $2,000,000 in fines and up to five years in prison; summary conviction carries fines up to $1,000,000 and up to two years less a day.16Financial Transactions and Reports Analysis Centre of Canada. FINTRAC – Criminal Non-Compliance Offences FINTRAC publishes the names of entities that receive administrative penalties.

Fixing Missed or Incorrect Reports

If a review turns up missed, late, or incorrect reports, you can come forward through a voluntary self-declaration of non-compliance. Send a written declaration to VSDONC.ADVNC@fintrac-canafe.gc.ca that includes:17Financial Transactions and Reports Analysis Centre of Canada. Voluntary Self-Declaration of Non-Compliance

  • The name and contact details of the reporting entity.
  • The number and type of reports affected, and the time period during which the issues occurred.
  • An explanation of why the reports were missing, late, or incorrect.
  • A corrective action plan with specific measures and timelines.

FINTRAC will work with you to resolve the issue, but only if the problem is not a repeat of a previously disclosed violation and the disclosure was not made after you were notified of an upcoming examination. Coming forward with a concrete fix puts you in a far better position than waiting for an examiner to find it.