Most filing errors are not caused by lack of effort. They come from unclear ownership, weak QA, and fragmented workflows.
Policy alone does not prevent repeat errors. When ownership, QA, and records live in different places, the same failure modes come back. The list below maps the gaps we see most often.
These are the most common filing failures we see across MSBs and other reporting entities. Most are not caused by lack of effort, but by gaps in workflow design.
Treating "as soon as practicable" as optional rather than an urgent workflow standard. Delays often happen when handoffs between frontline staff and compliance are undefined or when there is no SLA for escalation. FINTRAC examines timeliness closely; unexplained delays can support AMPs and reputational risk. For a step-by-step workflow, read our STR Filing Guide.
Failing to file when required, especially where suspicion thresholds are met but escalation is delayed. Teams sometimes treat "reasonable grounds to suspect" as a high bar and defer or avoid filing.
Each reporting obligation is independent.
Filing an STR does not satisfy a separate LCTR or EFTR obligation, and vice versa. Missing a required report is among the highest-risk failures and is frequently cited in enforcement actions.
Missing sanctions evasion-related STR triggers due to outdated internal criteria. Sanctions evasion STR triggers became effective August 19, 2024 under Bill C-59. If your policies or training still refer only to ML/TF and not sanctions evasion, you are exposed. Update criteria and escalation paths so sanctions evasion is explicitly included.
Weak suspicion narratives that do not explain facts, indicators, and reasoning clearly. Vague language (e.g. "suspicious activity") fails to show why the filer had reasonable grounds. Reports should include timeline, indicators, context, and explicit reasoning. Poor narrative quality is a common examination finding and drives rework and reputational risk.
Incorrect 24-hour aggregation handling for threshold-based report obligations. LCTR, LVCTR, and EFTR use a $10,000 CAD threshold with 24-hour aggregation. If related transactions are split across systems or shifts, teams often miss the combined total and fail to file. LCTR is due within 15 calendar days; LVCTR and EFTR within 5 working days. Inconsistent aggregation logic is a frequent source of late or missed reports.
Incomplete customer/entity data fields that force rework or create report quality gaps. Missing or inconsistent identifiers, dates, or counterparty details cause rejections or last-minute scrambles. Use a data prep and validation approach by report type so required fields are complete before submission.
No second-review QA gate before submission. Single-review workflows allow errors and inconsistencies to reach FINTRAC. A second reviewer checking consistency, completeness, and narrative quality reduces rework and examination risk.
Inconsistent recordkeeping that cannot be produced cleanly on request. Records must be retained for 5 years and produced to FINTRAC within 30 days when requested. If evidence and decision rationale are scattered across email and local files, compliance cannot meet this obligation. Centralized, searchable records are essential.
Poor report-type separation in prep workflows, causing cross-type field and logic errors. STR, LCTR, LVCTR, EFTR, and LPEPR have different triggers, fields, and deadlines. Mixing them in one workflow leads to wrong fields, wrong deadlines, and duplicate content. Use report-type-specific checklists and prep steps.
No monthly quality review cycle to detect recurring control failures. Without sampling by report type and tracking rework, late filing, and missing-field patterns, the same mistakes repeat. A simple monthly review of metrics and sample quality helps target process fixes.
A remittance team flags a client for repeated near-threshold cash sends. The analyst marks the case suspicious in the system, but the handoff stalls. The failure chain looks like this:
Outcome: rework, stress, and elevated AMP risk. Clear escalation SLAs, aggregation rules, and one system of record for evidence would have broken the chain.
These controls eliminate most repeat filing errors:
Review and enforcement pressure often centers on:
Teams should design workflows directly around these examination realities.
A 15 to 30 minute weekly routine prevents most recurring failures:
These failures are predictable and preventable when workflows are structured correctly. Comply+ helps standardize detection, drafting, QA, and submission so these issues do not recur.
Not filing when required and repeated late filing patterns are among the highest-risk failures.
Teams often split related transactions across systems and fail to apply consolidated logic.
Yes. Simple checklists, clear ownership, and weekly sampling improve quality quickly.
Use structured templates that force facts, indicators, timeline, and rationale alignment.
Yes. This is the fastest way to isolate root causes and target process fixes.
FINTRAC enforcement is intensifying. Recent penalties demonstrate that compliance failures result in significant financial consequences, with Bill C-2 increasing maximum penalties to $20 million for entities.
FINTRAC has imposed significant Administrative Monetary Penalties (AMPs) for compliance failures across multiple sectors.
December 2025 — Toronto, Ontario
Multiple compliance failures including no effective compliance regime, no proper risk assessment, and failures to submit EFT and LCT reports.
Read case studyDecember 2025 — Foreign MSB (Seychelles)
Failed to submit STRs for transactions with exposure to darknet marketplaces, sanctioned entities, and child sexual abuse material.
Read case studyOctober 2025 — British Columbia
2,593 violations including 1,068 unreported STRs, 1,518 unreported LVCTRs, and failure to comply with Ministerial Directive on Iran.
Read case studySeptember 2025 — Foreign MSB (Seychelles)
Unregistered foreign MSB, 2,952 unreported LVCTRs, and 33 unreported STRs linked to darknet marketplaces and illicit chemical trade.
Read case studyUnder Bill C-2 (tabled June 2025), maximum Administrative Monetary Penalties would increase dramatically:
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Disclaimer
This page is provided for general informational purposes only and reflects our interpretation and opinions based on publicly available information at the time of writing. It does not constitute legal advice, financial advice, regulatory guidance, or a substitute for professional counsel. Reporting entities and businesses subject to FINTRAC obligations should consult qualified legal and compliance advisors before making decisions relating to FINTRAC, AML obligations, or compliance requirements.