Section 5: Module 1: Large Cash Transaction Reporting

5.2 Module One: Large Cash Transaction Reporting

1. Core Definitions

1.1 Large Cash Transaction (LCT)

Definition

A cash transaction involving receipt of CAD $10,000 or more in cash from a person or entity, either in a single transaction or through aggregation under the 24-hour rule.  

Key Elements

  • Threshold: CAD $10,000

  • Cash only

  • Single transaction or aggregated transactions

  • Applies to reporting entities

1.2 Cash

Definition

Canadian or foreign currency in the form of bank notes or coins in circulation. Cash does not include cheques, money orders, or similar negotiable instruments.  

Includes

  • Canadian bank notes

  • Foreign bank notes

  • Coins

Does Not Include

  • Cheques

  • Money orders

  • Bank drafts

  • Other negotiable instruments

1.3 Large Cash Transaction Report (LCTR)

Definition

A report submitted to FINTRAC when a reporting entity receives qualifying large cash transactions.  

2. Core Concepts

2.1 Who Must Report

The following reporting entities must report large cash transactions:

  • Financial Entities

  • MSBs

  • Accountants and Accounting Firms

  • Casinos

  • Dealers in Precious Metals and Stones

  • Life Insurance Companies; Brokers; and Agents

  • Mortgage Administrators; Brokers; and Lenders

  • Real Estate Brokers and Sales Representatives

  • Real Estate Developers

  • Securities Dealers

  • British Columbia Notaries

  • Agents of the Crown  

Important Exception

The requirement does not apply to legal counsel or legal firms when providing legal services.  

3. Reporting Requirements

3.1 Single Transaction Rule

Report When

You receive CAD $10,000 or more in cash from the same person or entity in a single transaction.  

3.2 Foreign Currency Transactions

Rule

Foreign currency must be converted to Canadian dollars using the last Bank of Canada rate available at the time of the transaction.  

Important

This conversion is only used to determine whether the CAD $10,000 reporting threshold has been met.  

4. The 24-Hour Rule

4.1 Definition

The requirement to aggregate multiple cash transactions and report them together in a single Large Cash Transaction Report.  

4.2 When the 24-Hour Rule Applies

Transactions must:

  1. Total CAD $10,000 or more

  2. Occur within a consecutive 24-hour window

  3. Have the same aggregation type:

    • Same conductor

    • Same third party (on behalf of)

    • Same beneficiary  

4.3 Transactions Included

The following combinations must be reported:

Example 1

Two or more transactions under $10,000 that together total $10,000 or more.  

Example 2

One or more transactions under $10,000 plus one or more transactions at or above $10,000.  

Example 3

Two or more transactions of $10,000 or more.  

4.4 Static 24-Hour Window

Organizations must establish a static 24-hour reporting window in their policies and procedures. Example:

  • 9:00 AM today

  • 8:59 AM tomorrow

This window must be documented and reported to FINTRAC.  

4.5 Multiple Locations

The 24-hour rule applies across all business locations. Transactions conducted at different branches must still be aggregated when applicable.  

5. Large Cash Transaction Report Content

Required Information

Each report must include:

  • General information section

  • At least one transaction

  • Date and time for each transaction

  • At least one starting action

  • At least one completing action

A report may contain multiple transactions and multiple actions.  

6. Automated Banking Machines (ABMs)

Reporting Requirement

An LCTR is required when:

  • A cash transaction of $10,000 or more occurs at an ABM; or

  • Aggregated ABM transactions meet the 24-hour rule.  

Conductor Identification

For ABM deposits:

  • The account holder must be identified.

  • The person physically making the deposit does not need to be identified.  

Location Information

The complete address of the ABM must be included in the report.  

7. Reporting Methods

7.1 Electronic Reporting

Preferred method when technical capability exists.  

Available Options

FWR

FINTRAC’s secure online reporting portal.  

FINTRAC API

System-to-system automated reporting.  

Paper Reporting

Permitted only when technical capability for electronic reporting does not exist.  

8. Reporting Deadline

LCTR Filing Deadline

Large Cash Transaction Reports must be submitted within 15 calendar days after the transaction occurs.  

9. Penalties for Non-Compliance

Criminal Penalties

Failure to report a large cash transaction may result in:

First Offence

Fine up to $500,000.  

Subsequent Offences

Fine up to $1,000,000.  

Administrative Monetary Penalties

Non-compliance may also result in AMPs.  

Important Rule

A criminal penalty and an AMP cannot be imposed for the same instance of non-compliance.  

10. Exceptions

Financial Entities

A financial entity is not required to file an LCTR when the cash is received from:

  • Another financial entity

  • A public body  

Public Bodies Include

  • Federal government departments

  • Provincial government departments

  • Municipal governments

  • Public hospitals designated under the Excise Tax Act  

11. Additional Considerations

Record Keeping and Client Identification

Large cash transactions trigger associated record-keeping and client identification requirements.  

Multiple Reporting Obligations

The same transaction may require:

  • LCTR

  • EFTR

  • STR

depending on the circumstances.  

Suspicious Transactions

If an LCT creates reasonable grounds to suspect ML or TF:

  • An STR must also be filed.  

Listed Person or Entity Property

If the transaction involves property owned or controlled by a terrorist; terrorist group; or listed person/entity:

  • The transaction must not proceed.

  • Property must be frozen.  

12. Key Takeaways

12.1 LCTR Threshold

Report cash transactions of CAD $10,000 or more.  

12.2 Cash Means Currency

Cash includes bank notes and coins only. It does not include cheques or money orders.  

12.3 Know the 24-Hour Rule

Aggregate transactions when:

  • Total ≥ $10,000

  • Same conductor; beneficiary; or third party

  • Within a consecutive 24-hour period  

12.4 LCTR Deadline

File within 15 calendar days.  

12.5 One Transaction Can Trigger Multiple Reports

The same activity may require:

  • LCTR

  • STR

  • EFTR  

12.6 Key Exam Concepts

Most likely test areas:

  • $10,000 threshold

  • Definition of cash

  • 24-hour rule

  • Same conductor / beneficiary / third party

  • 15 calendar day deadline

  • Financial entity and public body exemptions

  • Multiple reporting obligations

  • LCTR vs STR distinction