The 24-Hour Rule: Three Ways to Aggregate

Canada's threshold reports trigger on a single transaction of CAD $10,000 or more: a large cash transaction report (LCTR) on cash received, an electronic funds transfer report (EFTR) on initiating or finally receiving an international transfer, and a large virtual currency transaction report (LVCTR) on virtual currency received. The 24-hour rule closes the obvious gap — splitting one amount into smaller pieces. Two or more transactions of the same kind totalling $10,000 or more within 24 consecutive hours are deemed a single transaction. The statutory basis is PCMLTFA s. 9; the mechanics sit in PCMLTFR s. 126 (cash), s. 127 (EFT initiation), s. 128 (EFT final receipt), s. 129 (virtual currency) and s. 130 (casino disbursements). Only international EFTs are in scope — transfers within Canada are not reportable regardless of amount.

Two boundaries worth fixing early. First, the rule aggregates within a transaction type: cash groups with cash under s. 126, virtual currency with virtual currency under s. 129. Second, it never applies to suspicious transaction reports — the STR obligation in PCMLTFA s. 7 has no monetary threshold at all, so a pattern of sub-$10,000 transactions that looks like deliberate structuring can require an STR on its own, whether or not any 24-hour aggregation fires.

The first grouping asks: do you know these transactions were conducted by the same person or entity? A currency exchange business that receives $6,500 in cash from a customer in the morning and $4,500 from the same customer that evening has, under s. 126, received a single deemed transaction of $11,000 — an LCTR is owed even though neither receipt crossed the threshold alone.

Note the window is 24 consecutive hours, not a calendar day; for how to anchor the window in practice, check the current FINTRAC 24-hour rule guidance. Operationally, this lens is only as good as your ability to recognize the same conductor across locations, tellers and channels — document which identifier your system keys on to match transactions to one person.

The second grouping ignores who sent the money and asks who it is for. A money services business that initiates three international transfers of $4,000 each, from three unrelated senders, all to the same recipient abroad, has initiated $12,000 for one beneficiary within 24 consecutive hours — s. 127 deems that a single transfer and an EFTR is owed. The same logic applies to final receipt under s. 128 and to virtual currency under s. 129.

The beneficiary lens carries carve-outs in ss. 127(2), 128(2) and 129(2): transactions do not aggregate on this basis where the beneficiary is a public body, a listed corporation with net assets of $75 million or more, or a regulated pension-fund administrator. Check the current FINTRAC guidance for the precise conditions before relying on a carve-out.

The third grouping asks whether transactions were conducted on behalf of the same person or entity — whoever physically shows up. If the owner of a cash-heavy business sends two different employees to deposit $5,500 and $6,000 with a money services business on the same day, the conductors differ but the third party is one and the same: $11,500 aggregates under s. 126.

This is why the on-behalf-of determination made at intake matters for reporting, not just for record-keeping. If staff never ask whether a customer is acting for someone else, the third-party lens has nothing to match on. Capture who the third party is at the point of transaction and make that field available to whatever process runs your aggregation checks.

FINTRAC's guidance is explicit that the three lenses are assessed separately over the same set of transactions. Groupings that overlap but are not identical each generate their own report; only where all transactions in the groupings are identical may a single report be filed. So if transactions 1–3 group by conductor and transactions 2–4 group by beneficiary, you file two reports, even though transactions 2 and 3 appear in both.

Deadlines follow the report type, and they are not uniform. An LCTR is due within 15 days after the day the amount is received (PCMLTFR s. 132(3)). An LVCTR is due within five working days (s. 132(2)) — a common trap, since many assume it matches the LCTR's 15 days. An EFTR is due within five working days after initiation or final receipt (s. 132(1)). For a deemed transaction, the clock starts once the aggregate crosses the threshold — which is why detection that runs days later is a deadline problem, not just a data problem. The substantive obligation to file sits in sector-specific provisions (for example PCMLTFR s. 30(1) for money services businesses); the 24-hour rules and deadlines apply across sectors.

What to document for each aggregated report: which lens fired, which transactions were grouped and on what matching key, why the groupings were or were not identical, and the date the deadline clock started. That record is what lets you reconstruct the decision when FINTRAC asks.