Key takeaways
- Banks must identify clients, monitor accounts and report some transactions to FINTRAC under the PCMLTFA
- Reported automatically: international transfers of CAD 10,000 or more (within 5 business days) and cash deposits of CAD 10,000 or more (within 15 calendar days), including smaller amounts that add up within 24 hours
- Suspicious transaction reports have no minimum amount
- Neither FINTRAC nor banks publish a full list of what triggers a review; it depends on what the bank knows about you
- Papers that usually help: statements, pay slips, sale deeds, gift letters, inheritance papers
Which law makes banks ask?
The main law is the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. It applies to banks, credit unions, trust and loan companies, money services businesses and others. FINTRAC is the federal agency that receives their reports.
Under the Act and FINTRAC guidance, a bank must:
- Verify your identity. FINTRAC says the business "is required by law to ask you for ID."
- Ask about third parties. You may be asked if you act for someone else.
- Run a compliance program that assesses the risk of money laundering. When the bank sees a high risk, the Act requires special measures.
- Monitor accounts over time. FINTRAC says monitoring checks whether transactions are consistent with what the bank knows about the client.
- Report certain transactions to FINTRAC (next section).
So a question about your money is the bank doing its legal job. It is not an accusation.
What does a bank report to FINTRAC?
| Report | When it is made | Deadline for the bank |
|---|---|---|
| Electronic funds transfer report | An international transfer of CAD 10,000 or more, sent or received | Within 5 business days |
| Large cash transaction report | Cash (Canadian or foreign bills and coins) of CAD 10,000 or more received | Within 15 calendar days |
| Large virtual currency transaction report | Virtual currency worth CAD 10,000 or more | See FINTRAC guidance |
| Suspicious transaction report | Reasonable grounds to suspect money laundering, terrorist financing or sanctions evasion | As soon as practicable |
The first three thresholds also apply to two or more smaller amounts within 24 hours that add up to CAD 10,000 or more. Since January 2015, banks also send reports of international transfers of CAD 10,000 or more to the CRA.
A suspicious transaction report has no minimum amount. It also covers attempted transactions. FINTRAC says the test is "a step above simple suspicion."
Money you carry across the border is a separate rule. You report CAD 10,000 or more to the Canada Border Services Agency (CBSA). See declaring money at the border.
What triggers a review of a large deposit?
There is no public list. FINTRAC publishes indicators to help businesses spot suspicious activity. But it says a transaction "may not appear suspicious in and of itself." The decision comes from a "holistic assessment of facts, context" and indicators. Each bank also sets its own internal rules and does not publish them.
In general terms, a review is more likely when a deposit does not fit what the bank knows. For a newcomer, the bank often knows little at first. That is why early deposits get more questions. Situations that commonly lead to questions include:
- a large transfer soon after you open the account;
- money sent by a person who is not you, with no explanation;
- large cash deposits;
- money moving in and out quickly;
- information that does not match, such as a different name on the sending account.
These are examples, not a rule. Many people with all of the above are never asked anything, and others are asked about smaller amounts.
A note on splitting. Do not break a deposit or transfer into smaller pieces to stay below CAD 10,000. The 24-hour rule exists for exactly this. Deliberately splitting amounts is a known warning sign and can lead to a suspicious transaction report.
What documents do banks usually ask for?
The bank wants to understand how you got the money. FINTRAC defines source of funds as "how the funds were acquired, not where the funds may have been transferred from." Typical requests include:
| Your money came from | Papers banks commonly ask for |
|---|---|
| Work savings | Pay slips, employment letter, tax returns, statements showing savings building up |
| Selling property | Sale deed or agreement, statement showing the money arriving |
| A gift | Signed gift letter, giver's statement, proof of relationship |
| An inheritance | Will, probate or succession certificate, estate statement |
| Investments or a business | Broker or business statements, tax returns |
This list is typical, not set by law. Your bank may ask for something else. Provide translations if papers are not in English or French. For a gift, use a clear letter: see gift letters from family abroad.
Can the bank hold my money?
Yes, in some cases. A bank can hold funds while it completes its review. There is no public rule on how long that review takes. Answer fast and completely, and ask the bank exactly what is missing.
Separate rules limit holds on cheques. The Financial Consumer Agency of Canada (FCAC) says the first CAD 100 of a cheque deposit must be available right away if you deposit with a teller, or on the next business day if you deposit another way. For a Canadian-dollar cheque from a Canadian institution over CAD 1,500, the maximum hold is 7 business days in person or 8 business days by ATM or other methods. FCAC says banks "often hold foreign cheques for 30 days."
If you disagree with how your bank handled your account, you can complain to the bank. FCAC says banks must give a written final response within 56 days. After that, you can go to the Ombudsman for Banking Services and Investments (OBSI).
Will the bank tell me if it reports me?
For routine reports, such as a transfer of CAD 10,000 or more, FINTRAC's pages do not say you will be told. You do not need to do anything.
For suspicious transaction reports, section 8 of the Act says no one may disclose that a report was made, or its contents, "with the intent to prejudice a criminal investigation." FINTRAC guidance also tells staff not to ask questions they would not normally ask if that could tip off the client. So a bank may not explain why it is asking.
How can I prepare before a large transfer?
- Tell the bank first. Ask what papers it wants for an incoming transfer of your size. Some banks will note it on your file.
- Send from an account in your own name when you can. Money from another person needs a letter.
- Keep the chain clear. Show the money from its origin (salary, sale, gift) to the account it leaves from.
- Write the purpose on the transfer, for example "personal savings, relocation to Canada."
- Keep copies of every transfer receipt and reference number.
For the full move, see how to bring money to Canada and source of funds vs proof of funds.
Common questions
Is it illegal to deposit more than CAD 10,000?
How long does a bank have to report my transfer?
Is there a list of amounts or actions that trigger a review?
Does the CRA see my transfer?
Can I complain if my bank holds my money?
Sources
- FINTRAC: Financial transactions reported to FINTRAC
- FINTRAC: The PCMLTFA and client identity verification
- FINTRAC: Reporting suspicious transactions
- FINTRAC: Reporting large cash transactions
- FINTRAC: Ongoing monitoring requirements
- FINTRAC: Politically exposed persons and heads of international organizations (definitions of source of funds and source of wealth)
- Justice Laws: Proceeds of Crime (Money Laundering) and Terrorist Financing Act
- Justice Laws: Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184)
- CRA: Electronic funds transfer reporting
- FCAC: Cashing a cheque (hold periods)
- FCAC: Filing a complaint with a bank, your rights
- CBSA: Crossing the border with CAN$10,000 or more