Threshold Reports: LCTR and EFTR

Canada's reporting regime has two families of reports. Suspicious transaction reports depend on judgment: PCMLTFA s. 7 requires an STR whenever there are reasonable grounds to suspect a transaction — completed or attempted — is related to money laundering, terrorist activity financing or, since August 19, 2024, sanctions evasion, and there is no monetary threshold. Threshold reports are the opposite: they are mechanical. PCMLTFA s. 9 is the statutory basis for reporting prescribed transactions, and the regulations set a bright line at CAD $10,000. If the amount is met, the report is due — no assessment of the customer, no suspicion, no discretion.

That objectivity is the operational point. A business cannot decide a $10,000 cash deposit from a long-standing, well-understood customer is 'fine' and skip the report. The report is owed because the threshold was crossed. What judgment governs is whether an STR is also needed on top — covered below.

A Large Cash Transaction Report is triggered when a reporting entity receives CAD $10,000 or more in cash in a single transaction. The obligation itself sits in sector-specific provisions of the PCMLTFR — s. 30(1)(a) for money services businesses and s. 33(1)(a) for foreign MSBs, with parallel provisions for financial entities, casinos and other sectors. The deadline is in PCMLTFR s. 132(3): the report must be sent within 15 days after the day the amount is received — FINTRAC's guidance phrases this as 15 calendar days, so weekends and holidays count.

Two receipts can add up to one report. Under the 24-hour rule for cash (PCMLTFR s. 126), two or more cash amounts totalling $10,000 or more received within 24 consecutive hours are deemed a single transaction when the entity knows they were conducted by the same person, on behalf of the same person, or for the same beneficiary. Operationally that means your system needs to look backward across a rolling 24-hour window every time cash comes in, not just evaluate each receipt in isolation.

The EFT report covers international electronic funds transfers of CAD $10,000 or more — and it applies at both ends of the pipe. The entity that initiates an outgoing international transfer reports it, and the entity that finally receives an incoming one reports it too. Domestic transfers within Canada are not reportable regardless of amount; FINTRAC defines the reportable transfer as an electronic funds transfer other than a transfer of funds within Canada. Sector obligations sit in PCMLTFR ss. 30(1)(b)-(c) for MSBs, 33(1)(b)-(e) for foreign MSBs and 7(1)(b)-(c) for financial entities.

The deadline is tighter than the LCTR's: PCMLTFR s. 132(1) requires the report within five working days after the day the transfer is initiated or finally received. The 24-hour rule applies here too, but through two separate provisions — s. 127 aggregates initiated transfers and s. 128 aggregates final receipts, each with carve-outs where the beneficiary is a public body, a large listed corporation with $75M or more in net assets, or a regulated pension-fund administrator. Note that EFT reporting also interacts with the travel rule in PCMLTFA s. 9.5, which requires originator information to accompany transfers — check the current FINTRAC guidance on EFT reporting for how the report fields map.

The deadlines are not uniform, and mixing them up is a common failure. LCTR: 15 days after receipt (PCMLTFR s. 132(3)). EFTR: five working days after initiation or final receipt (s. 132(1)). LVCTR — the virtual-currency analogue, triggered by receiving $10,000 or more in virtual currency with its own 24-hour rule in s. 129 — is five working days under s. 132(2), not 15; teams that learn the LCTR rule first often wrongly assume virtual currency gets the same 15 days. STRs have no fixed day-count at all: SOR/2001-317 s. 9(2) requires submission as soon as practicable after the entity has taken the measures that enable it to establish reasonable grounds to suspect.

One report has no grace period. Where PCMLTFA s. 7.1(1) is engaged — property of a person or entity listed under the Criminal Code, the United Nations Act, the Special Economic Measures Act or the Justice for Victims of Corrupt Foreign Officials Act — the Listed Person or Entity Property Report (which replaced the former Terrorist Property Report, with expanded scope covering sanctioned persons) must be submitted immediately per FINTRAC guidance.

Threshold reports and STRs are independent obligations, so a single transaction can require both. A $10,000-plus cash receipt that also raises reasonable grounds to suspect money laundering generates an LCTR (because of the amount) and an STR (because of the suspicion) — filing one never discharges the other. If the suspicion touches both money laundering or terrorist financing and sanctions evasion, one STR covering each suspected offence is filed rather than two.

The 24-hour rule can also multiply reports on its own. FINTRAC's guidance applies three separate aggregation lenses — same conductor, same third party on whose behalf transactions were conducted, and same beneficiary — and each lens is assessed independently. Where groupings under different lenses overlap but are not identical, each grouping generates its own report; only when all transactions in the groupings are identical may a single report cover them. A practical documentation habit: for every aggregated report, record which lens produced it and which underlying transactions it rolls up, so the file explains itself at examination time.

Attempted-versus-completed status matters differently across the two families. The STR obligation in PCMLTFA s. 7 expressly covers attempted transactions; threshold reports trigger on actual receipt, initiation or final receipt of funds. A customer who walks away before handing over $12,000 in cash may still warrant an STR, but no LCTR is owed because nothing was received.

Three operational pieces make this regime workable. First, deadline clocks keyed to the right start event: day of cash receipt for the LCTR, day of initiation or final receipt for the EFTR, with the five-working-day versus 15-day distinction encoded rather than remembered. Second, a rolling 24-hour aggregation check across all three lenses, run against every cash receipt, virtual-currency receipt and international transfer. Third, a record for each report — and for each near-threshold transaction you decided not to report — showing the amounts, the timing, the aggregation analysis and who made the call. Report volumes and the reasoning behind aggregation decisions are exactly the kind of evidence FINTRAC guidance expects a program to be able to produce; forms, field-level requirements and submission mechanics change, so check the current FINTRAC guidance for each report type before building.