FINTRAC Compliance for Financial Institutions

Who Qualifies as a Financial Entity Under FINTRAC

The PCMLTFA defines "financial entities" broadly. If your organization falls into any of the following categories, you have full FINTRAC reporting obligations:

• Banks listed in Schedule I or II of the Bank Act, and authorized foreign banks operating in Canada
• Credit unions and caisses populaires
• Credit union centrals when they offer financial services to anyone other than member entities
• Trust companies and unregulated trust companies
• Loan companies
• Financial services cooperatives
• Departments and agents of the Crown that accept deposit liabilities while providing financial services to the public

Each of these entity types processes a high volume of financial transactions daily. That volume, combined with the breadth of FINTRAC's reporting requirements, makes manual compliance impractical for all but the smallest operations.

Reporting Obligations for Financial Entities

Financial institutions carry the broadest set of reporting obligations under the PCMLTFA. Here is what applies:

Large Cash Transaction Reports (LCTR)

File an LCTR when you receive $10,000 or more in cash in a single transaction, or when multiple cash transactions from the same client total $10,000+ within a 24-hour period. For banks and credit unions processing thousands of cash deposits daily, identifying and aggregating these transactions accurately is a core compliance challenge.

Deadline: 15 calendar days.

Electronic Funds Transfer Reports (EFTR)

File an EFTR for international electronic funds transfers of $10,000 or more, whether incoming or outgoing. Domestic transfers within Canada are not reportable. For institutions processing cross-border wire transfers, this report type generates significant filing volume.

Deadline: 5 working days.

Large Virtual Currency Transaction Reports (LVCTR)

If your institution handles virtual currency, file an LVCTR when you receive or transfer $10,000 or more in virtual currency in a single transaction or across aggregated transactions within 24 hours.

Deadline: 5 working days.

Suspicious Transaction Reports (STR)

File an STR when there are reasonable grounds to suspect a transaction is related to money laundering or terrorist financing. No dollar threshold applies. Financial institutions must have systems to detect patterns like structuring (breaking large transactions into smaller amounts to avoid reporting thresholds), rapid movement of funds through accounts with no apparent business purpose, and transactions involving high-risk jurisdictions or sanctioned entities.

Deadline: As soon as practicable.

Challenges Specific to Financial Institutions

• Transaction volume: A mid-sized credit union might process tens of thousands of transactions per month. A Schedule I bank handles millions. Detecting every reportable transaction across that volume requires automation. Manual review is not viable.
• 24-hour aggregation across channels: Clients interact through branches, ATMs, online banking, and mobile apps. A client who deposits $5,000 cash at a branch and another $6,000 at an ATM on the same day has crossed the LCTR threshold. Your systems need to aggregate across all channels in real time.
• Cross-border wire transfer tracking: International EFTs flow through correspondent banking networks. Identifying which transfers meet the $10,000 threshold and capturing all required originator and beneficiary information for EFTR filing requires structured data capture at the point of origination.
• STR detection at scale: Financial institutions must monitor for dozens of suspicious activity indicators across millions of transactions. False positives waste compliance resources. Missed indicators create regulatory exposure. Getting the balance right requires intelligent, calibrated detection systems.
• Regulatory examinations: FINTRAC examines financial institutions regularly. Being able to produce a complete, organized record of all reports filed, decisions made, and compliance actions taken is not optional. It is a core expectation.
• Multi-branch coordination: Credit unions and banks with multiple branches need consistent compliance practices across all locations. A gap at one branch creates risk for the entire institution.

How Comply+ Supports Financial Institutions

High-Volume Batch Processing

Upload transaction data as a CSV or connect your core banking system directly. Comply+ processes thousands of transactions in minutes, automatically classifying each one against LCTR, EFTR, LVCTR, and STR thresholds. Reports are pre-filled and ready for review.

Autopilot Mode for Connected Systems

For institutions with database connectivity, enable autopilot mode. Comply+ continuously monitors your transaction feed and automatically generates and submits LCTRs, EFTRs, and LVCTRs. STRs are flagged for human review before submission, giving your compliance team the final say.

Intelligent 24-Hour Aggregation

The platform automatically aggregates transactions by client across all channels within your configured 24-hour window. When cumulative activity crosses a reporting threshold, the system generates the appropriate report without manual intervention.

AI-Powered STR Detection

Our aiSTR technology applies FINTRAC risk indicators to your transaction data, identifying patterns that warrant further investigation. Each flagged transaction includes a confidence score and a draft narrative aligned with FINTRAC's expectations. Your team reviews, adjusts, and approves before submission.

Direct FINTRAC Submission with Audit Trail

Submit all report types directly to FINTRAC from within Comply+. Every submission is logged with confirmation receipts, timestamps, and a complete audit trail. When FINTRAC conducts an examination, your documentation is organized and ready.

Record Keeping Requirements

FINTRAC publishes official guidance on record keeping for financial entities. For full details and current requirements, see: Record keeping requirements for financial entities (FINTRAC).