Anonymised, illustrative composite. A buyer offered a deposit in two cash payments, each under the reporting threshold. The 24-hour aggregation rule treated them as one.
At a glance
A buyer purchasing a $340,000 condo needed to provide a $34,000 deposit (10%) and preferred to pay as much of it as possible in cash. To make the payment easier to handle, the buyer suggested splitting it: $9,600 in cash on the day the offer was accepted, another $9,600 in cash the following day, and the remaining $14,800 by bank draft once the funds cleared.
The buyer’s stated reason was ordinary enough — cash on hand from a family gathering, and a preference for not carrying the full amount at once. The agent had no reason to assume anything more than that, but the pattern itself was the thing that mattered, independent of the explanation offered for it.
FINTRAC’s Large Cash Transaction Report requirement applies to $10,000 or more in cash in a single transaction — and each of the two proposed payments, on its own, sat comfortably under that line. Taken separately, neither payment would trigger a report.
They cannot be taken separately. FINTRAC’s own 24-hour rule is explicit: a report is required when a reporting entity receives two or more cash amounts totalling $10,000 or more within a consecutive 24-hour window, from the same person, on behalf of the same person, or for the same beneficiary. $9,600 plus $9,600, a day apart, from the same buyer, is $19,200 — well over the threshold once aggregated.
Purchase price $340,000. Deposit $34,000 (10% of the price). Proposed structure: $9,600 cash on day one, $9,600 cash on day two, $14,800 by bank draft for the balance. The two cash payments total $19,200, against FINTRAC’s $10,000 threshold and its 24-hour aggregation window. The bank draft portion is not “cash” under FINTRAC’s narrow definition, which covers only bank notes and coins — it carries no LCTR obligation of its own.
Once a large cash transaction report is triggered, it must be filed within 15 calendar days of the day the cash was received, and the underlying record kept for at least five years from the day it was created.
The threshold test is not “was any single payment under $10,000” — it is whether two or more cash amounts, aggregated within a 24-hour window and known to be linked to the same person, together reach $10,000. FINTRAC’s own money-laundering indicator list for real estate names this exact pattern directly: “the party asks for the payment to be divided into smaller parts with a short interval between them” is listed as a red flag in its own right, independent of the reporting math.
The buyer’s proposed split, whatever the intent behind it, produced precisely the fact pattern the 24-hour rule and the red-flag indicator both exist to catch: two under-threshold amounts, a short interval apart, same source.
The agent recognized the structure before either payment was taken and flagged it to the brokerage’s compliance officer. Both cash payments were accepted, aggregated as a single $19,200 transaction under the 24-hour rule, and the Large Cash Transaction Report was filed within the 15-day deadline. The deal proceeded on that basis, with no suggestion the buyer had intended anything improper — the point of the rule is to catch the pattern regardless of intent, not to presume guilt from it.
For the underlying obligation, see the large cash transaction report glossary entry, and for the escalation path when a pattern looks deliberate rather than incidental, the suspicious transaction report glossary entry. For a related identification gap on a deposit, see a buyer who would not produce identification.
Treating each $9,600 payment as separately exempt, and never aggregating them, would have meant a large cash transaction report simply never got filed on a transaction that plainly required one — a reporting failure, not a paperwork delay, since the 15-day clock runs from the day the cash was received regardless of whether anyone noticed the pattern. Beyond the reporting gap itself, a structuring pattern that goes unrecognized and unexplained is also one of FINTRAC’s own suspicious-transaction indicators — a missed LCTR can, on the wrong facts, become a missed STR as well.
The tell is the arithmetic itself: a round cash figure sitting just under a known reporting line, offered in more than one instalment a short interval apart. FINTRAC draws its own red flag around exactly that shape. An agent who sees a proposed cash structure land suspiciously close to, but under, $10,000 — more than once, in quick succession — should treat the aggregation rule as the default assumption, not an edge case.
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