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Reporting transactions to FINTRAC: The 24‑hour rule : FINTRAC’s compliance guidance

Updated on October 23, 2023

From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)

Overview

This guidance came into effect on June 1, 2021.

This guidance describes when reporting entities must consider multiple transactions made within a 24‑hour period as a “single transaction”. This concept is referred to as “the 24‑hour rule”.

Currently, this guidance applies only to:

For electronic funds transfers or casino disbursements, reporting entities should continue to apply the 24‑hour rule as outlined in FINTRAC policy interpretation 4 – The 24‑hour rule (pre-June 1, 2021) until the new reporting forms become available.

Further details can be found in the Notice on forthcoming regulatory amendments and flexibility.

Note

In this guidance

Related links

Related acts and regulations
Related guidance
Related resources

1. Who must comply

All reporting entities must comply with the 24‑hour rule as required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations.

2. The 24‑hour rule explained

The 24‑hour rule applies to these transaction types:

The 24‑hour rule is the requirement to aggregate multiple transactions that are the same transaction type when they:

For more information on the specific aggregation types for each transaction type, please refer to 4. Reporting under the 24‑hour rule.

Note: The 24 hours that make up the period must be consecutive. The period cannot exceed 24 hours.

Legal references

Transaction amounts

You must aggregate transactions of any amount (at, below or above $10,000), under the 24‑hour rule, if together these transactions:

You must aggregate and submit all transactions that meet the 24‑hour rule in the same report.

Before June 1, 2021, you were required to aggregate transactions less than $10,000 each that totalled $10,000 or more within a 24‑hour window in the same report. For transactions at or above $10,000 or more in this same 24‑hour period, you were required to report these separately. The table below compares this difference.

Comparison of the aggregation of transaction amounts before and as of June 1, 2021
Transactions in a 24‑hour window that total $10,000 or more Aggregate transactions in a single report
Before June 1, 2021 As of June 1, 2021
2 or more transactions under $10,000 Yes Yes
1 or more transactions under $10,000 and 1 or more transactions at $10,000 or more No Yes
2 or more transactions at $10,000 or more No Yes

Note: Although the regulatory change came into effect on June 1, 2021, reporting entities are not able to apply this change until the new reporting forms are available on the following dates:

Multiple locations

If you have multiple locations (for example, various locations in cities or provinces across Canada), you should consider the 24‑hour rule broadly across your business. When transactions occur at multiple business locations in a 24‑hour window, you must report them in accordance with the 24‑hour rule.

Your business process

Your business must have a process in place to review and aggregate transactions in accordance with the 24‑hour rule requirement. This process should be documented in your Compliance policies and procedures to ensure consistent aggregation, including if the same person or entity has multiple roles in a transaction. Specifically, there may be transactions where:

For example, when a person deposits cash into their own account, this person is both the conductor and beneficiary. This may result in some reports having the same transactions.

For more information:

3. Determining the 24‑hour window

You must determine the beginning and the end of your 24‑hour window to identify the transactions that need to be aggregated and reported under the 24‑hour rule. This window is called a static 24‑hour window. For example, 9 am Monday to 8:59 am Tuesday.

You are not limited to one 24‑hour window for all of your business lines. You have the option of using different static 24‑hour windows for different transaction types or different business lines. For example, you may determine that for operational purposes you will use a 12 am Monday to 11:59 pm Monday static 24‑hour window for wire transfers, but for cash transactions you choose to use a different 24‑hour window, such as 8 pm Monday to 7:59 pm Tuesday.

Each transaction that falls under the 24‑hour rule within a static 24‑hour window will have to be viewed independently from the previous or subsequent static 24‑hour window. This means that one transaction cannot overlap multiple 24‑hour windows.

It is important to note that while you will monitor transactions for the applicability of the 24‑hour rule within a static 24‑hour window, you must also monitor all transactions, regardless of the static 24‑hour window, to identify suspicious transactions that could relate to money laundering or terrorist activity financing. For more information, refer to What is a Suspicious Transaction Report.

Your policies and procedures should include the time when your 24‑hour windows begin and end. You will also need to indicate the times that your 24‑hour window begins and ends in a mandatory field when you submit a report to FINTRAC.

4. Reporting under the 24‑hour rule

The 24‑hour rule applies to all reports that have a reporting threshold of $10,000. The requirements for each type of report are outlined below.

Large Cash Transaction Report

Reporting entities have the obligation to report large cash transactions to FINTRAC in accordance with the 24‑hour rule when 2 or more amounts in cash are received that total $10,000 or more within a static 24‑hour window, and the reporting entity knows that those transactions:

Other requirements and exceptions apply. For more information, refer to:

Legal reference

Large Virtual Currency Transaction Report

Reporting entities have the obligation to report large virtual currency transactions to FINTRAC in accordance with the 24‑hour rule when 2 or more amounts are received in virtual currency that total $10,000 or more within a static 24‑hour window, and the reporting entity knows that those transactions:

Other requirements and exceptions apply. For more information, refer to:

Legal reference

Electronic Funds Transfer Report

Financial entities, money services businesses, foreign money services businesses and casinos must report electronic funds transfers to FINTRAC in accordance with the 24‑hour rule when they:

Other requirements and exceptions apply. For more information, refer to:

Legal reference

Casino Disbursement Report

Casinos must report a casino disbursement to FINTRAC in accordance with the 24‑hour rule when 2 or more disbursements are made that total $10,000 or more, within a static 24‑hour window, and the casino knows that those disbursements are:

Other requirements and exceptions apply. For more information, refer to:

Legal reference

Reports where all transactions are the same

This occurs when 2 or more reports contain transactions that are all the same. The reports contain the exact same transaction information and only the aggregation type is different.

When this occurs, you may choose to send only 1 of the reports to FINTRAC.

Example

In a static 24‑hour window, the following 2 transactions occur:

Report 1 – Aggregation by conductor (Henry): This report includes transaction reference number 101 for $8,000 and transaction reference number 102 for $6,000 totaling $14,000.

Report 2 – Aggregation by beneficiary (Henry): This report includes transaction reference number 101 for $8,000 and transaction reference number 102 for $6,000 totaling $14,000.

Reports 1 and 2 can both be submitted to FINTRAC—one aggregated by “conductor” and the other aggregated by “beneficiary”. However, because reports 1 and 2 contain the exact same transactions, ABC Bank may choose to send only 1 of these reports to FINTRAC. ABC Bank should document their chosen process to ensure consistent reporting.

Only when the transactions are all exactly the same but have different aggregation types (conductor and beneficiary for example) can a reporting entity choose to submit only 1 report based on 1 aggregation type.

Note: Depending on your business systems and processes, the transaction reference number (the unique number you assign to each transaction) may help you recognize the same transactions occurring in multiple reports. In the example above, transaction reference numbers 101 and 102 occur in both reports, indicating that there may be the same transactions in reports 1 and 2.

Reports where some transactions are the same

This happens when 2 or more reports contain some transactions that are the same, but not all are the same. These reports have different aggregation types and contain some transactions, but not all, which overlap.

When this happens, you cannot choose which report to submit. You must submit all reports to FINTRAC.

Example

In a static 24‑hour window, the following 3 transactions occur:

Report 1 – Aggregation by conductor (Ted): This report includes transaction reference number 103 for $8,000 and transaction reference number 104 for $6,000 totaling $14,000.

Report 2 – Aggregation by beneficiary (Ted): This report includes transaction reference number 103 for $8,000 and transaction reference number 105 for $5,000 totaling $13,000.

Reports 1 and 2 must both be submitted to FINTRAC—one aggregated by “conductor” and the other aggregated by “beneficiary”. Although both reports include 1 transaction that is the same (transaction reference number 103), report 1 contains an additional transaction (transaction reference number 104) that is not in report 2. Report 2 contains an additional transaction (transaction reference number 105) that is not in report 1. Both reports contain a transaction that is the same, but each report also contains a transaction that is different. You must submit both reports to ensure FINTRAC receives information on all 3 transactions.

Note: Depending on your business systems and processes, the transaction reference number (the unique number you assign to each transaction) may help you recognize the same transactions occurring in multiple reports. In the example above, transaction reference number 103 occurs in both reports, indicating that there may be the same transaction in reports 1 and 2.

Single transaction(s) of $10,000 or more in a 24‑hour window

When you are reviewing transactions to determine if they have the same aggregation type (for example, conductor) and you come across a single transaction in the amount of $10,000 or more in a 24‑hour window, you must report this transaction in its own report to FINTRAC unless it can be aggregated with any other transaction(s).

However, if a transaction in the amount of $10,000 or more is being aggregated and reported with other transactions, then you do not need to report this transaction in its own report. That is, you do not need to report the transaction of $10,000 or more on its own in a separate report if it is included in another report that is being submitted to FINTRAC under the 24‑hour rule.

For examples, refer to:

Instances where you must not aggregate

When a person or entity has different roles (conductor/requestor, on behalf of, or beneficiary) in different transactions, the requirement to aggregate transactions is not triggered.

For example, you must not aggregate transactions:

This is because both transactions are not conducted by the same person nor are they conducted on behalf of the same person. Instead, Bob is the conductor of the first transaction and the on behalf of party in the second transaction. If these transactions happened to be for the same beneficiary and the transactions totalled $10,000 or more, then these transactions would have to be aggregated based on the beneficiary.

Example 1

In a static 24‑hour window, the following transactions occur:

Aggregation is not triggered
Conductor On behalf of (third party) Beneficiary Aggregation type Amount ($)
Martha None Mike Not applicable 9,000
Iris Martha Tom Not applicable 4,000

In this example, the 24‑hour rule is not applicable as none of the aggregation types are the same.

Example 2

In a static 24‑hour window, the following transactions occur:

Aggregation is triggered
Conductor On behalf of (third party) Beneficiary Aggregation type Amount ($)
Martha None Mike Beneficiary 9,000
Iris Martha Mike Beneficiary 8,000

In this example, the 24‑hour rule is applicable and you would submit a report with both transactions with the beneficiary as the aggregation type.

For more 24‑hour rule examples, refer to the annexes at the end of this guidance.

5. Exceptions to the 24‑hour rule

Large Virtual Currency Transaction Report

You do not have to submit a Large Virtual Currency Transaction Report when you receive 2 or more amounts of virtual currency for the same beneficiary that total $10,000 or more under the 24‑hour rule, if the beneficiary is:

You cannot apply this exception to amounts of virtual currency received for 1 of these beneficiaries under the 24‑hour rule, if 1 or more of the amounts is individually equivalent to $10,000 or more. In this scenario you must submit a separate Large Virtual Currency Transaction Report to FINTRAC for each amount that is individually equivalent to $10,000 or more, as the reporting threshold has been met with the individual transaction.

Note: Other obligations and related exceptions may apply. For more information, refer to your sector-specific guidance (“reporting” and “record keeping” requirements).

Legal references

Electronic Funds Transfer Report

Initiation of international electronic funds transfers

You do not have to submit an Electronic Funds Transfer Report for the initiation of 2 or more international electronic funds transfers that total $10,000 or more under the 24‑hour rule if the electronic funds transfers are initiated at the request of or on behalf of:

You cannot apply this exception to international electronic funds transfers you initiate under the 24‑hour rule at the request of, or on behalf of, 1 of these entities, if 1 or more of the international electronic funds transfers is individually in an amount of $10,000 or more. In this scenario, you must submit a separate Electronic Funds Transfer Report to FINTRAC for each international electronic funds transfer that is individually in an amount of $10,000 or more, as the reporting threshold has been met with each individual transaction.

Note: Other obligations and related exceptions may apply. For more information, refer to your sector-specific guidance (“reporting” and “record keeping” requirements).

Legal references

Final receipt of electronic funds transfers

You do not have to submit an Electronic Funds Transfer Report for the final receipt of 2 or more electronic funds transfers that total $10,000 or more under the 24‑hour rule if the beneficiary is:

You cannot apply this exception to electronic funds transfers that you finally receive for 1 of these beneficiaries under the 24‑hour rule, if 1 or more of the electronic funds transfers is individually in an amount of $10,000 or more. In this scenario, you must submit a separate Electronic Funds Transfer Report to FINTRAC for each electronic funds transfer that is individually in an amount of $10,000 or more, as the reporting threshold has been met with each individual transaction.

Note: Other obligations and related exceptions may apply. For more information, refer to your sector-specific guidance (“reporting” and “record keeping” requirements).

Legal references

Annex A – Examples of the 24‑hour rule applied to electronic funds transfers

Note: Examples for Annex A will be provided closer to the implementation of the new reporting form for electronic funds transfers.

Annex B – Examples of the 24‑hour rule applied to large cash transactions

Note: The examples used in this guidance are meant to help explain your reporting requirements. All details described in these examples such as names of persons, names of entities, addresses, phone numbers and email addresses are fictitious.

In this annex

Example B.1: Receipt of cash – 24‑hour rule – Aggregation on the conductor and beneficiary where transactions are above $10,000

Scenario

The 24‑hour window for the Large Cash Transaction Report process is from 12 am to 11:59 pm the same day.

Summary table of scenario: Receipt of cash – 24‑hour rule – Aggregation on the conductor and beneficiary where transactions are above $10,000
24‑hour window Transaction reference number Time of transaction Disposition type Amount ($) Conductor Beneficiary Third party Aggregation type
12:00 am to 11:59 pm 01 11:30 am Purchase of Jewellery 14,000 Jeremy Jeremy None Conductor and beneficiary
02 1:40 pm Purchase of Jewellery 13,000 Jeremy Jeremy None Conductor and beneficiary

Large Cash Transaction Report requirement

In this scenario, Fancy Jewels Limited would review all transactions that fall within the 24‑hour window to check if multiple transactions occurred for the same aggregation type that together total $10,000 or more. The dealer in precious metals and precious stones would notice:

Fancy Jewels Limited submits 2 reports:

Both reports 1 and 2 can be submitted to FINTRAC—one where the aggregation type is “conductor” and the other where the aggregation type is “beneficiary”. However, because the transactions included in reports 1 and 2 are the same, Fancy Jewels Limited may choose to send only 1 of these reports to FINTRAC. Fancy Jewels Limited should document their chosen process to ensure consistent reporting.

Infographic summarizing example B.1

Infographic summarizing the scenario and report requirement for example B.1: Receipt of cash – 24-hour rule – Aggregation on the conductor and beneficiary where transactions are about $10,000Infographic summarizing the scenario and report requirement for example B.1: Receipt of cash – 24-hour rule – Aggregation on the conductor and beneficiary where transactions are about $10,000
Infographic summarizing the scenario and report requirement for example B.1: Receipt of cash – 24‑hour rule – Aggregation on the conductor and beneficiary where transactions are about $10,000

Example B.2: Receipt of cash – 24‑hour rule – Aggregation on the conductor and beneficiary where transactions are above and below $10,000

Scenario

The 24‑hour window for the Large Cash Transaction Report process is from 12:00 am to 11:59 pm the same day.

Summary table of scenario: Receipt of cash – 24‑hour rule – Aggregation on the conductor and beneficiary where transactions are above and below $10,000
24‑hour window Transaction reference number Time of transaction Disposition type Amount ($) Conductor Beneficiary Third party Aggregation type
12:00 am to 11:59 pm 01 9:20 am Exchange to fiat currency 5,000 Eve Eve None Conductor
02 12:08 pm Outgoing international funds transfer 4,000 Eve Sam None Conductor and beneficiary
03 2:39 pm Outgoing international funds transfer 11,000 Eve Sam None Conductor and beneficiary
04 4:55 pm Outgoing international funds transfer 12,000 Eve James None Conductor

Large Cash Transaction Report requirement

In this scenario, Money Business Limited would review all transactions that fall within their 24‑hour window to check if multiple transactions occurred for the same aggregation type that together total $10,000 or more. Money Business Limited would notice:

These 2 reports contain some transactions that are the same (transactions 02 and 03)—but some that are different. The first report aggregated by conductor also contains 2 additional transactions (transaction 01 and 04) that are not in the second report aggregated by beneficiary.

Transaction 03 (in the amount of $11,000) is over $10,000 but does not need to be reported in its own report, as this transaction has been included in report 1 that is aggregated by conductor and in report 2 that is aggregated by beneficiary.

Transaction 04 (in the amount of $12,000) is over $10,000 but does not need to be reported in its own report, as this transaction has been included in report 1 that is aggregated by conductor.

A transaction in the amount of $10,000 or more must be reported in its own report if the transaction has not been aggregated with other transactions in a 24‑hour window.

For more information, refer to:

Infographic summarizing example B.2

Infographic summarizing the scenario and report requirement for example B.2: Receipt of cash – 24-hour rule – Aggregation on the conductor and beneficiary where transactions are above and below $10,000Infographic summarizing the scenario and report requirement for example B.2: Receipt of cash – 24-hour rule – Aggregation on the conductor and beneficiary where transactions are above and below $10,000
Infographic summarizing the scenario and report requirement for example B.2: Receipt of cash – 24‑hour rule – Aggregation on the conductor and beneficiary where transactions are above and below $10,000

Example B.3: Receipt of cash – 24‑hour rule – Aggregation on the conductor and beneficiary with 1 transaction outside of the 24‑hour window

Scenario

The 24‑hour window for the Large Cash Transaction Report process is from 12 am to 11:59 pm the same day.

Summary table of scenario: Receipt of cash – 24‑hour rule – Aggregation on the conductor and beneficiary with 1 transaction outside of 24‑hour window
24‑hour window Transaction reference number Time of transaction Disposition type Amount ($) Conductor Beneficiary Third party Aggregation type
12am to 11:59 pm (Monday) 01 11:55 am Deposit to an account 7,000 Celine James None Beneficiary
02 3:15 pm Deposit to an account 6,000 Eve Irene None Conductor
03 3:20 pm Deposit to an account 4,000 Eve James None Conductor and beneficiary
04 5:08 pm Deposit to an account 3,000 Sam James None Beneficiary
05 6:00 pm Deposit to an account 4,000 Eve James None Conductor and beneficiary
12 am to 11:59 pm (Tuesday) 06 8:30 am Deposit to an account 8,000 Sam James None Not applicable

Large Cash Transaction Report requirement

In this scenario, Golden Bank would review all transactions that fall within the 24‑hour window to check if multiple transactions occurred for the same aggregation type that together total $10,000 or more. The bank would notice:

Golden Bank submits 2 reports:

These 2 reports contain some transactions that are the same (transactions 03 and 05)—but some that are different. The first report aggregated by conductor contains 1 additional transaction (transaction 02) and the second report aggregated by beneficiary contains 2 additional transactions (transactions 01 and 04).

Infographic summarizing example B.3

Infographic summarizing the scenario and report requirement for example B.3: Receipt of cash – 24 hour rule – Aggregation on the conductor and beneficiary with 1 transaction outside of 24-hour windowInfographic summarizing the scenario and report requirement for example B.3: Receipt of cash – 24-hour rule – Aggregation on the conductor and beneficiary with 1 transaction outside of 24-hour window
Infographic summarizing the scenario and report requirement for example B.3: Receipt of cash – 24‑hour rule – Aggregation on the conductor and beneficiary with 1 transaction outside of 24‑hour window

Example B.4: Receipt of cash – 24‑hour rule – Aggregation on the beneficiary – Transactions occurring in different time zones

Scenario

The 24‑hour window for the Large Cash Transaction Report process is from 12 am to 11:59 pm the same day based on Eastern Standard Time (EST).

Summary table of scenario: Receipt of cash – 24‑hour rule – Aggregation on the beneficiary – Transactions occurring in different time zones
24‑hour window Transaction reference number Time of transaction Disposition type Amount ($) Conductor Beneficiary Third party Aggregation type
12 am to 11:59 pm Eastern Standard Time (EST) (Monday) 01 10:08 am EST Deposit to an account 7,000 Celine James None Beneficiary
02 11:43 am EST Deposit to an account 3,000 Sam James None Beneficiary
03 5:10 pm Pacific Standard Time (PST), Monday (which equals to 8:10 pm EST, Monday) Deposit to an account 2,000 Sebastian James None Beneficiary
12 am to 11:59 pm EST (Tuesday) 04 9:12 pm PST, Monday (which equals to 12:12 am EST, Tuesday) Deposit to an account 4,000 Eve James None Not applicable

Large Cash Transaction Report requirement

In this scenario, Golden Bank has locations that are in 2 different time zones:

Because Golden Bank’s time zone for its 24‑hour window is based on Eastern Standard Time, it must convert the time of any transaction that occurs in Pacific Standard Time to Eastern Standard Time to confirm if it falls within its 24‑hour window. Golden Bank would then review all transactions that fall within the 24‑hour window to check if multiple transactions occurred for the same aggregation type that together total $10,000 or more. The bank would notice:

Golden Bank submits 1 report:

Infographic summarizing example B.4

Infographic summarizing the scenario and report requirement for example B.4: Receipt of cash – 24-hour rule – Aggregation on the beneficiary – Transactions occurring in different time zonesInfographic summarizing the scenario and report requirement for example B.4: Receipt of cash – 24-hour rule – Aggregation on the beneficiary – Transactions occurring in different time zones
Infographic summarizing the scenario and report requirement for example B.4: Receipt of cash – 24‑hour rule – Aggregation on the beneficiary – Transactions occurring in different time zones

Example B.5: Receipt of cash – 24‑hour rule – Aggregation on third party

Scenario

The 24‑hour window for the Large Cash Transaction Report process is from 12 am to 11:59 pm the same day.

Summary table of scenario: Receipt of cash – 24‑hour rule – Aggregation on third party
24‑hour window Transaction reference number Time of transaction Disposition type Amount ($) Conductor Beneficiary Third party Aggregation type
12 am to 11:59 pm 01 11:12 am Deposit to an account 12,000 Eve James Celine Third party
02 1:32 pm Deposit to an account 4,000 James Eve Celine Third party

Large Cash Transaction Report requirement

In this scenario, Credit Union Inc. would review all transactions that fall within the 24‑hour window to check if multiple transactions occurred for the same aggregation type that together total $10,000 or more. The credit union would notice:

Credit Union Inc. submits 1 report:

Transaction 01 (in the amount of $12,000) is over $10,000 but does not need to be reported in its own report, as this transaction has been included in report 1 that is aggregated by third party.

A transaction in the amount of $10,000 or more must be reported in its own report if the transaction has not been aggregated with other transactions in a 24‑hour window.

For more information, refer to:

Infographic summarizing example B.5

Infographic summarizing the scenario and report requirement for example B.5: Receipt of cash – 24-hour rule – Aggregation on third partyInfographic summarizing the scenario and report requirement for example B.5: Receipt of cash – 24-hour rule – Aggregation on third party
Infographic summarizing the scenario and report requirement for example B.5: Receipt of cash – 24‑hour rule – Aggregation on third party

Example B.6: Receipt of cash – 24‑hour rule – Aggregation on conductor – Entity or person

Scenario

The 24‑hour window for the Large Cash Transaction Report process is from 12 am to 11:59 pm the same day.

Summary table of scenario: Receipt of cash – 24‑hour rule – Aggregation on conductor – Entity
24‑hour window Transaction reference number Time of transaction Disposition type Amount ($) Conductor Beneficiary Third party Aggregation type
12 am to 11:59 pm 01 1:30 pm Exchange to fiat currency 5,000 The Rosie Kitchen Supply Company The Rosie Kitchen Supply Company None Conductor
02 1:40 pm Exchange to fiat currency 6,000 Yara Yara None Not applicable
03 3:05 pm Outgoing domestic funds transfer 8,000 The Rosie Kitchen Supply Company The Blueberry Company None Conductor

Large Cash Transaction Report requirement

Business practice to treat an entity as the conductor

In this scenario, Golden Bank has a business practice (which is explained in its policies and procedures) to treat an entity as the conductor when the President (or Chief Executive Officer) of an entity conducts a transaction and Golden Bank is aware that the individual is acting as the entity in their capacity as the President. This business practice is in line with FINTRAC’s policy interpretation that an entity can only conduct a transaction by means of a physical person, and when that person is the President, Chief Executive Officer, or someone who holds an equivalent position within the entity, they can be considered to be acting as the entity. Golden Bank would review all transactions that fall within the 24‑hour window to check if multiple transactions occurred for the same aggregation type that together total $10,000 or more. It would notice:

Golden Bank submits 1 report:

Business practice to treat a person (individual) as the conductor

If Golden Bank has instead a business practice (which is explained in its policies and procedures) to treat a person (individual) as the conductor, regardless of the person’s role, then the bank would notice that transactions 01, 02 and 03 were all conducted by Yara and total $19,000. The Bank would also notice that transactions 01 and 03 were conducted by Yara on behalf of The Rosie Kitchen Supply Company and total $13,000.

Summary table of scenario: Receipt of cash – 24‑hour rule – Aggregation on conductor – Person
24‑hour window Transaction reference number Time of transaction Disposition type Amount ($) Conductor Beneficiary Third party Aggregation type
12 am to 11:59 pm 01 1:30 pm Exchange to fiat currency 5,000 Yara The Rosie Kitchen Supply Company The Rosie Kitchen Supply Company Conductor
02 1:40 pm Exchange to fiat currency 6,000 Yara Yara None Conductor
03 3:05 pm Outgoing domestic funds transfer 8,000 Yara The Blueberry Company The Rosie Kitchen Supply Company Conductor

Golden Bank submits 2 reports:

These 2 reports contain some transactions that are the same (transactions 01 and 03), but some that are different. The first report aggregated by conductor contains 1 additional transaction (transaction 02) that is not in the second report aggregated by third party.

Infographics summarizing example B.6

Infographic summarizing the scenario and report requirement for example B.6: Receipt of cash – 24 hour rule – Aggregation on conductor – EntityInfographic summarizing the scenario and report requirement for example B.6: Receipt of cash – 24 hour rule – Aggregation on conductor – Entity
Infographic summarizing the scenario and report requirement for example B.6: Receipt of cash – 24‑hour rule – Aggregation on conductor – Entity
Infographic summarizing the scenario and report requirement for example B.6: Receipt of cash – 24-hour rule – Aggregation on conductor – PersonInfographic summarizing the scenario and report requirement for exampleB.6: Receipt of cash – 24-hour rule – Aggregation on conductor – Person
Infographic summarizing the scenario and report requirement for example B.6: Receipt of cash – 24‑hour rule – Aggregation on conductor – Person

Annex C – Examples of the 24‑hour rule applied to large virtual currency transactions

Note: The examples used in this guidance are meant to help explain your reporting requirements. All details described in these examples such as names of persons, names of entities, addresses, phone numbers and email addresses are fictitious.

In this annex

Assumptions for the 3 examples

Example C.1: Receipt of virtual currency – 24‑hour rule – Aggregation on the conductor

Scenario

Summary table of scenario: Receipt of virtual currency – 24‑hour rule – Aggregation on the conductor
24‑hour window Transaction reference number Time of transaction Disposition type Amount (virtual currency) Amount ($) Conductor Beneficiary Third party Aggregation type
12 am to 11:59 pm 01 2:20 am Added to virtual currency wallet 2 2,000 Eve James None Conductor
02 11:08 am Added to virtual currency wallet 4 4,000 Eve Sam None Conductor
03 3:39 pm Added to virtual currency wallet 12 12,000 Eve Celine None Conductor

Large Virtual Currency Transaction Report requirement

In this scenario, General Coin Company would review all transactions that fall within the 24‑hour window to check if multiple transactions occurred for the same aggregation type that together total $10,000 or more. The money services business would notice:

General Coin Company submits 1 report:

Transaction 03 (in the amount of $12,000) is over $10,000 but does not need to be reported in its own report, as this transaction has been included in report 1 that is aggregated by conductor.

A transaction in the amount of $10,000 or more must be reported in its own report if the transaction has not been aggregated with any other transaction(s) in a 24‑hour window.

For more information, refer to:

Infographic summarizing example C.1

Infographic summarizing the scenario and report requirement for example C.1: Receipt of virtual currency – 24-hour rule – Aggregation on the conductorInfographic summarizing the scenario and report requirement for example C.1: Receipt of virtual currency – 24-hour rule – Aggregation on the conductor
Infographic summarizing the scenario and report requirement for example C.1: Receipt of virtual currency – 24‑hour rule – Aggregation on the conductor

Example C.2: Receipt of virtual currency – 24‑hour rule – Aggregation on the beneficiary

Scenario

Summary table of scenario: Receipt of virtual currency – 24‑hour rule – Aggregation on the beneficiary
24‑hour window Transaction reference number Time of transaction Disposition type Amount (virtual currency) Amount ($) Conductor Beneficiary Third party Aggregation type
12 am to 11:59 pm 01 7:39 am Added to virtual currency wallet 4 4,000 Eve James None Beneficiary
02 1:15 pm Added to virtual currency wallet 6 6,000 Celine James None Beneficiary
03 5:08 pm Added to virtual currency wallet 3 3,000 Sam James None Beneficiary
04 5:11 pm Added to virtual currency wallet 2 2,000 Sam Celine None Not applicable
05 6:37 pm Added to virtual currency wallet 11 11,000 Irene James None Beneficiary

Large Virtual Currency Transaction Report requirement

In this scenario, General Coin Company would review all transactions that fall within the 24‑hour window to check if multiple transactions occurred for the same aggregation type that together total $10,000 or more. The money services business would notice:

General Coin Company submits 1 report:

Transaction 05 (in the amount of $11,000) is over $10,000 but does not need to be reported in its own report, as this transaction has been included in report 1 that is aggregated by beneficiary.

A transaction in the amount of $10,000 or more must be reported in its own report if the transaction has not been aggregated with other transactions in a 24‑hour window.

For more information, refer to:

Infographic summarizing example C.2

Infographic summarizing the scenario and report requirement for example C.2: Receipt of virtual currency – 24-hour rule – Aggregation on the beneficiaryInfographic summarizing the scenario and report requirement for example C.2: Receipt of virtual currency – 24-hour rule – Aggregation on the beneficiary
Infographic summarizing the scenario and report requirement for example C.2: Receipt of virtual currency – 24‑hour rule – Aggregation on the beneficiary

Example C.3: Receipt of virtual currency – 24‑hour rule – Aggregation on the third party

Scenario

Summary table of scenario: Receipt of virtual currency – 24‑hour rule – Aggregation on the third party
24‑hour window Transaction reference number Time of transaction Disposition type Amount (virtual currency) Amount ($) Conductor Beneficiary Third party Aggregation type
12 am to 11:59 pm (Friday) 01 12:12 am Added to virtual currency wallet 8 8,000 Eve James Celine Third party
02 11:32 pm Added to virtual currency wallet 4 4,000 James Eve Celine Third party
12 am to 11:59 pm (Saturday) 03 12:39 am Added to virtual currency wallet 2 2,000 Eve James Celine Not applicable

Large Virtual Currency Transaction Report requirement

In this scenario, General Coin Company would review all transactions that fall within the 24‑hour window to check if multiple transactions occurred for the same aggregation type that together total $10,000 or more. The money services business would notice:

General Coin Company submits 1 report:

Infographic summarizing example C.3

Infographic summarizing the scenario and report requirement for example C.3: Receipt of virtual currency – 24-hour rule – Aggregation on the third partyInfographic summarizing the scenario and report requirement for example C.3: Receipt of virtual currency – 24-hour rule – Aggregation on the third party
Infographic summarizing the scenario and report requirement for example C.3: Receipt of virtual currency – 24‑hour rule – Aggregation on the third party

Annex D – Examples of the 24‑hour rule applied to casino disbursements

Note: Examples for Annex D will be provided closer to the implementation of the new reporting form for casino disbursements.

Details and history

Published: June 2021

List of changes and updates
Date
[YYYY-MM-DD]
Summary of changes
2023-10-23
  • New title (used to be "Transaction reporting guidance: the 24‑hour rule")
  • Reorganization and reformatting of already existing sections so that relevant information may be located more quickly
  • Adding new sections explaining common exceptions and intricacies of the 24‑hour rule such as:
    • identical and overlapping report types
    • single transactions of $10 000 or more
    • situations where one must not aggregate
  • Expanding the annexes with 9 new Large Cash Transaction Report scenarios and Large Virtual Currency Transaction Report scenarios (with corresponding infographics)
  • Using plain language, where possible, in order to enhance readability
  • Minor adjustments to comply with Canada.ca Content Style Guide

For assistance

If you have questions about this guidance, please contact FINTRAC by email at guidelines-lignesdirectrices@fintrac-canafe.gc.ca.

Date Modified: