FINTRAC Compliance for Agents of the Crown

FINTRAC Obligations for Agents of the Crown

Agents of the Crown that sell money orders are reporting entities under the PCMLTFA. If your organization issues or sells money orders on behalf of the government, you have obligations to report certain transactions to FINTRAC, verify client identity, maintain records, and operate a compliance program.

Money orders are a well-known vehicle for money laundering because they can be purchased with cash, are easily transported, and can be deposited or cashed at financial institutions without revealing the original purchaser. FINTRAC oversight of money order sales addresses this risk at the point of purchase.

What You Must Do

• File Large Cash Transaction Reports (LCTR) when you receive $10,000 or more in cash for the purchase of money orders, whether in a single transaction or through aggregated purchases within 24 hours. Deadline: 15 calendar days.
• File Suspicious Transaction Reports (STR) when you have reasonable grounds to suspect a transaction is related to money laundering or terrorist financing. Deadline: as soon as practicable.
• Verify client identity for purchasers at or above prescribed thresholds.
• Maintain records of sales, client identification, and reports for at least five years.
• Operate a compliance program with written policies, a compliance officer, risk assessment, and training.

Common Risk Indicators

Money order sales present specific AML risks:

• Structuring: Clients purchasing multiple money orders in amounts just below the $10,000 threshold to avoid triggering an LCTR.
• Bulk purchases: Large or repeated purchases of money orders by the same individual, particularly when paid in cash.
• Third-party purchases: Individuals buying money orders on behalf of others, especially when the ultimate beneficiary is not identified.
• Sequential numbering requests: Clients requesting money orders with sequential serial numbers, which may indicate bulk conversion of cash.

How Comply+ Helps

Automated LCTR Detection

Upload your sales data. Comply+ identifies all money order purchases at or above the reporting threshold, including aggregated transactions within 24 hours.

STR Detection

Our aiSTR technology flags structuring patterns, bulk purchases, and other suspicious behaviours specific to money order sales.

Client Record Management

Comply+ maintains purchaser identification records linked to their transaction history, satisfying your record-keeping obligations and simplifying examinations.

Direct FINTRAC Submission

Submit all reports directly to FINTRAC from the platform with confirmation receipts and a full audit trail.

Record Keeping Requirements

FINTRAC publishes official guidance on record keeping for departments and agents of the Crown. For full details and current requirements, see: Record keeping requirements for departments and agents of the Crown (FINTRAC).