FINTRAC Large Virtual Currency Transaction Reporting Regime

A reportable large virtual currency transaction generally arises when a reporting entity receives virtual currency worth CAD 10,000 or more in a single transaction. The Regulations define virtual currency as a non-fiat digital representation of value usable for payment or investment and readily exchangeable for funds, or for another virtual currency readily exchangeable for funds. The definition also includes a private key that gives access to that value.

The 24-hour rule can combine multiple receipts. Two or more virtual currency transactions are treated as one CAD 10,000-or-more transaction when they fall within the reporting entity's static 24-hour window and the entity knows they were conducted by the same person or entity, conducted for the same third party, or received for the same beneficiary. Transactions of any size can enter the aggregation calculation.

FINTRAC states that receipt occurs when the transaction can no longer be reversed or cancelled. A Large Virtual Currency Transaction Report must then be sent within five working days after the day of receipt. Reports are submitted electronically through FINTRAC's web reporting system or application programming interface when the sender has the technical capability; paper reporting remains available where electronic submission is not technically possible.

The CAD threshold is determined using the Bank of Canada rate when one is published. Because the Bank of Canada does not publish virtual currency exchange rates, the Regulations direct reporting entities to use the rate they would apply in the ordinary course of business. FINTRAC says that the selected rate and source should be addressed in the entity's compliance policies and procedures.

Schedule 4 of the Regulations identifies the information associated with the report. It includes the virtual currency type and amount, exchange rate, transaction identifiers, sending and receiving addresses, account or reference information, transaction purpose where available, and information about persons or entities connected to the receipt and any remittance. FINTRAC's current reporting form organizes data into general, transaction, starting-action and completing-action sections.

The regime operates with related identity-verification and third-party determination requirements. A reporting entity must take reasonable measures to determine whether the person from whom virtual currency is received is acting for another person or entity and record prescribed third-party information when applicable. The Regulations also require a copy of every submitted report to be retained; FINTRAC states that the copy must be kept for at least five years from its creation.

A threshold report is distinct from a Suspicious Transaction Report. FINTRAC notes that both reports may be required for the same activity when the separate legal test for suspicious transaction reporting is met. The CAD 10,000 threshold therefore does not operate as a safe harbour or a finding that a transaction is suspicious.

Specified exceptions include virtual currency received as compensation for validating a transaction recorded on a distributed ledger and nominal amounts used solely to validate another transaction or transfer information. FINTRAC also identifies receipts for a reporting entity's own operational purposes as outside the Large Virtual Currency Transaction Report requirement. A narrower exception limits beneficiary-based 24-hour aggregation for public bodies, qualifying large publicly traded corporations or trusts, and regulated pension-fund administrators.

FINTRAC describes the requirements as applying to all reporting entities, while the Regulations implement reporting and recordkeeping through sector-specific provisions. The consolidated Regulations were current to May 26, 2026 and last amended on March 26, 2026 when this profile was reviewed. Later amendments have expanded parts of Canada's AML framework, but the core CAD 10,000 threshold, 24-hour aggregation rule and five-working-day deadline described here remained operative as of June 25, 2026.