FINTRAC Compliance for Financing & Leasing Entities

New FINTRAC Obligations for Financing and Leasing Entities

This change brings a significant segment of the non-bank financial sector under FINTRAC oversight for the first time. Whether you provide equipment leasing, vehicle financing, consumer lending, or commercial lease arrangements, the new rules apply.

What You Must Do

• Register with FINTRAC as a reporting entity.
• File Large Cash Transaction Reports (LCTR) when you receive $10,000 or more in cash from a single client in one transaction or across aggregated transactions within 24 hours. Deadline: 15 calendar days.
• File Electronic Funds Transfer Reports (EFTR) for international transfers of $10,000 or more related to your financing or leasing activities. Deadline: 5 working days.
• File Suspicious Transaction Reports (STR) when you have reasonable grounds to suspect money laundering or terrorist financing. No dollar threshold. Deadline: as soon as practicable.
• Verify client identity using government-issued identification and independent source documents.
• Maintain records of all transactions, client identification, and filed reports for a minimum of five years.
• Establish a written compliance program including policies, procedures, a compliance officer, risk assessment, and ongoing staff training.

AML Risks in Financing and Leasing

Financing and leasing transactions can be exploited for money laundering in several ways:

• Asset-based laundering: Purchasing high-value assets (vehicles, equipment, real estate) through financing arrangements can be used to integrate illicit funds into the legitimate economy. The asset provides a veneer of legitimacy for the underlying cash.
• Early repayment schemes: Clients who take out financing and then repay the full balance in cash shortly after are a classic indicator of money laundering. The loan creates a paper trail that makes the cash appear to be a legitimate repayment.
• Lease-to-own arrangements: Lease arrangements where the lessee eventually takes ownership can be used to transfer value without direct purchase scrutiny.
• Cash payments on leases: Regular cash payments toward lease obligations, particularly at or near reporting thresholds, require monitoring for both LCTR triggers and structuring patterns.

How Comply+ Supports Financing and Leasing Compliance

Transaction Monitoring

Upload your payment and transaction data. Comply+ automatically monitors for LCTR and EFTR triggers across your financing and leasing portfolio, including 24-hour aggregation for clients with multiple payments.

STR Detection

Our aiSTR technology identifies suspicious patterns in your transaction data: early repayments, cash-heavy payment patterns, unusual client profiles, and other risk indicators relevant to the financing and leasing sector.

Client Identification

Comply+ stores and organizes client identification records alongside their transaction history. When a client triggers a reporting obligation, their identification data is already available to populate the report.

Direct FINTRAC Submission

Submit LCTRs, EFTRs, and STRs directly to FINTRAC from the platform. Every submission includes confirmation receipts and a complete audit trail.

Record Keeping Requirements

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