Is there a dollar minimum before I have to file a suspicious transaction report?

No. STR obligations are triggered by reasonable grounds to suspect, not by a dollar amount: a $500 transaction can require a report just as much as a $500,000 one if the surrounding facts are suspicious. This is the most commonly misunderstood reporting rule.

What if I file a suspicious transaction report on a client: do I have to tell them?

No, and FINTRAC's guidance is explicit that you should not tip off your client that you are filing one. Disclosing that an STR has been or will be made, with the intent to prejudice a criminal investigation, is an offence. Practically: file with FINTRAC directly and confidentially, and don't change how you interact with the client in ways that would signal your suspicion.

Does the $10,000 large cash threshold apply to a single payment or can it be split across several?

It covers a single transaction of $10,000 or more in cash, and also 24-hour rules aggregating multiple cash transactions by or on behalf of the same person that together reach the threshold within that window. Structuring payments to stay just under $10,000 is itself a red flag that can trigger a suspicious transaction report.

Do e-transfers or financing payments count as 'cash' for this rule?

No. The large cash transaction report requirement is specifically about physical currency. Electronic transfers, financed payments, cheques and card payments are not 'cash' for this purpose, though they carry their own record-keeping requirements.

STR and large cash reporting obligations for dealerships & leasing companies

Beyond client identification, reporting entities must file specific reports with FINTRAC: suspicious transaction reports with no dollar threshold, and large cash transaction reports at $10,000. Here's what triggers each and what the report has to contain.

Client identification and a compliance program are the foundation, but FINTRAC's regime also requires specific reports to be filed when certain things happen. For a dealership or leasing company, the two that matter most are the suspicious transaction report and the large cash transaction report.

Suspicious transaction reports (STRs): no dollar threshold

An STR must be filed whenever you have reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing, regardless of the dollar amount, and whether or not the transaction was completed. This surprises a lot of new reporting entities: a small deal can still require a report if something about it doesn't add up.

Red flags relevant to financing and leasing transactions include:

A client who seems indifferent to financing terms or overpays to pay off a loan almost immediately.
Payment sources that don't match the client's apparent financial profile.
Reluctance to provide identification or beneficial ownership information.
Structuring payments to stay just under reporting thresholds.
Deals routed through unrelated third parties for no clear business reason.

An STR must be filed as soon as practicable once suspicion is formed, not held pending internal debate, and never disclosed to the client (see the FAQ on tipping off).

Large cash transaction reports (LCTRs): the $10,000 threshold

A large cash transaction report is required when you receive $10,000 or more in cash in a single transaction, or in cash transactions that together reach that threshold within a 24-hour period from or on behalf of the same person. This applies specifically to physical currency, not financed payments, e-transfers, or cheques.

The report must be submitted within 15 calendar days of the transaction and needs details on the transaction, the individual conducting it, and, where applicable, the individual or entity on whose behalf it's conducted. Deliberately splitting a cash payment to duck the threshold doesn't avoid the report: it's a pattern that itself points toward filing an STR instead.

Record keeping ties it together

Every reportable transaction, and the identification and records behind it, needs to be retained, generally for at least five years. This is the same retention duty that applies to the client identification records discussed in our KYC guide, and it's tested the same way at examination: can you produce the file, with the right details, for a transaction an examiner selects?

Practical takeaways for financing & leasing

Train staff to recognize suspicious patterns, not just to collect ID: STRs depend on judgment calls at the point of sale.
Never rely on a dollar threshold as your only trigger for reviewing a transaction: the $10,000 LCTR rule is separate from the no-threshold STR obligation.
Document the "why" behind any STR filing, and keep that documentation as confidential as the report itself.
Build reporting into your process, not into memory: the businesses that miss these obligations usually aren't ignoring the rule, they simply have no system prompting the question at the right moment.

Provasure flags red-flag patterns and reporting triggers as part of the deal workflow, so the question gets asked at the point of sale instead of after the fact. Or start with the free 12-item readiness checklist to see where your reporting process stands today.

Sources: FINTRAC's suspicious transaction reporting and large cash transaction reporting requirements are set out in its official guidance at fintrac-canafe.canada.ca. Reporting obligations are fact-specific. Verify against current guidance or counsel before relying on this summary.

This article is general regulatory information, not legal advice. Requirements depend on your business: verify against FINTRAC's official guidance or counsel.