Casino Disbursement Report: FINTRAC Rules for Casinos

A casino disbursement report (CDR) is the report a Canadian casino sends to FINTRAC when it pays a client $10,000 or more in a single disbursement, or in two or more disbursements totalling $10,000 or more within a consecutive 24-hour period for the same person or entity. It is due within 15 calendar days.

This guide turns FINTRAC casino disbursement guidance into a working checklist for compliance teams at land-based casinos, lottery corporations and the vendors that build their cashier systems. Every rule below is taken from FINTRAC's published guidance as accessed on 9 November 2026. It is an explainer, not legal advice: confirm your own obligations with FINTRAC guidance and counsel.

Casino disbursement report: the short answer

Casino disbursement reporting requirements come from the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. In practice, compliance staff need five facts:

• Threshold: a single disbursement of $10,000 or more is reportable.
• Aggregation: under the 24-hour rule, smaller disbursements are combined when together they reach $10,000 within 24 consecutive hours and you know they were requested or received by, or on behalf of, the same person or entity.
• Deadline: 15 calendar days after the day of the disbursement.
• Channel: electronically through the FINTRAC Web Reporting System (FWR) or the FINTRAC API; paper only if you lack the technical capability.
• Retention: keep a copy of each report for at least five years.

A CDR covers money going out of the casino. Cash coming in is a different report, and suspicion is a third obligation that has no threshold at all. Those links are covered further down.

Who has to file: what FINTRAC treats as a casino

Land-based casinos, slot halls and Internet lottery schemes

FINTRAC states that all casinos must comply with casino disbursement reporting. Its definition of a casino reaches beyond the traditional table-game floor: it includes organisations that conduct and manage a lottery scheme involving slot machines or other electronic gaming devices where more than 50 such machines are at a fixed place, and those that conduct and manage an Internet lottery scheme.

That second limb matters for iGaming. Whether a particular online operator files CDRs itself depends on whether it is a reporting entity under the PCMLTFA, which turns on how the scheme is conducted and managed in that province. FINTRAC's guidance is the place to confirm that status; do not assume it from a licence or a white-label agreement.

The short-term charity exemption

A registered charity that operates in a casino for two consecutive days or less, under the supervision of the casino, is not itself a casino for these purposes. The supervising casino's own obligations are unaffected.

Service providers can file, but responsibility stays with you

A casino may use a service provider to submit reports on its behalf. FINTRAC is explicit that the legal responsibility for reporting cannot be delegated. If your cashier platform vendor, payment processor or outsourced compliance team prepares the file, your organisation still owns its accuracy and its timing. The same applies to the identity data behind each report: the payee name, address, identification and occupation fields usually come from your onboarding stack, so it is worth reviewing how your current vendors capture them when choosing KYC providers for iGaming operators.

What counts as a reportable disbursement

FINTRAC lists exactly eight types of reportable casino disbursement and eight items that are not reportable. The table reproduces both lists without additions.

Slot jackpots, front money and comps

Two questions come up often. A slot jackpot paid out in funds is a "payment on a bet" and is reportable once it meets the threshold on its own or through aggregation. Comps and player-point redemptions are not reportable, however valuable they are. Front money works in both directions: depositing into the front money account is excluded, while a front cash withdrawal is reportable.

Mixed payouts: report only the reportable portion

Where one payout mixes reportable and non-reportable elements, FINTRAC says to report only the reportable portion. As an illustration, if a large win is settled partly in chips and partly by cheque, the chip portion is excluded and only the cheque amount counts toward the $10,000 threshold. Cage and cashier systems should record each component separately so the reportable amount can be calculated without manual reconstruction.

The casino disbursement 24-hour rule

Same requester or receiver: what you must know

The 24-hour rule applies when two or more disbursements total $10,000 or more within a consecutive 24-hour period and you know they were requested or received by, or on behalf of, the same person or entity. Some secondary summaries describe this as payouts to "certain" clients; FINTRAC's wording is about knowledge that the requester, the receiver or the on-behalf-of party is the same. That makes your data model the real control. If the cage, the online cashier and the cheque desk each hold their own customer records, you may not "know" what your systems could have told you.

FINTRAC's guidance refers to "your" 24-hour period, so define how your casino measures the window and apply that method consistently.

Wait until the window closes

For aggregated disbursements, FINTRAC tells reporting entities to wait until the end of the 24-hour period before submitting, and to include every disbursement in the group in the same report. Filing after the first payout and again after the second produces two incomplete reports instead of one correct one.

Worked example: a front-money withdrawal plus an online cash-out

The following example is based on FINTRAC's own scenario B.3 in its CDR guidance. A client withdraws $20,000 from a front money account late one evening. Less than 24 hours later, the same client transfers $4,000 from an online casino account to a bank account.

The $4,000 transfer would not be reportable on its own. It joins the report because the casino knows the same person requested both disbursements inside one 24-hour window. For operators running both a casino floor and an online channel, the 24-hour log has to see both.

Payouts on behalf of someone else

FINTRAC's scenario B.2 covers a third-party case: one person redeems $25,000 in chips on behalf of another person, and the casino issues a cheque payable to that person. That is a single above-threshold disbursement, reported with the on-behalf-of fields completed. This is where third-party determination comes in: staff need to ask, and record, who the money is really for.

Filing the report: deadline, channel and fields

15 calendar days

The casino disbursement report FINTRAC receives must arrive within 15 calendar days after the day of the disbursement. Calendar days include weekends and holidays.

FWR, API or paper

Reports are filed electronically through the FINTRAC Web Reporting System or the FINTRAC API. Paper is permitted only when you do not have the technical capability to report electronically.

Mandatory vs reasonable-measures fields

The form has four sections: general information, disbursement information, starting action and completing action. Each field falls into one of four categories:

• Mandatory (*): must always be completed.
• Mandatory for processing: the report cannot be accepted without it.
• Mandatory if applicable: required whenever the information applies to the disbursement.
• Reasonable measures: you must take reasonable measures to obtain the information, such as asking the client, and complete the field if you obtain it.

FINTRAC warns that failing to provide applicable information may lead to criminal or administrative penalties. When a reasonable-measures field is blank, your records should show that you asked.

Foreign currency conversion

If a disbursement is made in a foreign currency, convert it to Canadian dollars at the Bank of Canada exchange rate in effect at the time of the disbursement. If the Bank of Canada has not published a rate for that currency, use the rate your casino actually used and document it. The conversion decides whether the threshold is met, so the rate source belongs in the record.

How a CDR fits with STRs, EFT reports and threshold reports

A CDR is one of several FINTRAC reports a casino may owe for the same client. The comparison below shows the trigger, threshold and deadline for each, based on FINTRAC guidance.

When you file a CDR and an STR together

FINTRAC confirms that the same disbursement can require both a CDR and an STR. The CDR is mechanical: it is triggered by amount and timing. The STR is judgement-based and has no monetary threshold, so a $4,000 cash-out can require an STR even when no CDR is due. Our guide to suspicious transaction reports in casinos covers indicators and timing. If a disbursement is sent as a reportable electronic funds transfer, an EFT report is needed in addition to the CDR. Virtual currency received by the casino falls under separate rules, explained in our page on large virtual currency transaction reports.

Listed persons: stop the payout

If the funds are property of a listed person or entity, the rule changes completely. FINTRAC's instruction is not to complete the disbursement and to file a Listed Person or Entity Property Report immediately. Screening against the relevant lists therefore has to happen before the cheque is cut or the transfer is released, not afterwards during the CDR batch.

Record keeping and controls that make CDRs defensible

Five-year retention and the 30-day production rule

FINTRAC's casino record-keeping guidance requires a copy of each CDR to be kept for at least five years from the date it was created. All required records must be capable of being produced to FINTRAC within 30 days of a request. A report that was filed on time but cannot be retrieved later is still a compliance gap.

Capturing payee and on-behalf-of data at the cage and online cashier

Many CDR problems are easier to prevent at the point of payout than to fix at the filing stage. A practical control set:

• Make the disbursement type a required field at the cage and in the online cashier, using FINTRAC's eight reportable types plus an "excluded" option.
• Record mixed payouts as separate components so the reportable portion is calculated automatically.
• Link land-based and online customer records to one client identifier so the 24-hour rule sees every channel.
• Prompt staff to ask whether the client is acting for someone else, and store the answer even when it is "no".
• Store the exchange rate source for every foreign-currency payout.
• Run listed-person screening before release of funds, with a hard stop.
• Reconcile the 24-hour log against filed reports weekly, so missed aggregations are found well inside the 15-day window.

Monitoring tools can surface patterns that point to money laundering, such as repeated payouts just under $10,000, but no tool removes the casino's own reporting responsibility. Our overview of AML compliance software for iGaming explains what these systems do and where human review is still needed.

For the full text, including the field-by-field instructions in Annex A, read FINTRAC's casino disbursement guidance.

Responsible gambling note

This article is a B2B compliance explainer for casino and iGaming operators. It does not promote gambling or suggest that any game or strategy produces winnings. The legal gambling age in Canada is 18 or 19 depending on the province. If gambling is causing problems for you or someone you know, contact your provincial responsible-gambling service; in Ontario, ConnexOntario offers free, confidential support. Nothing here is legal advice: confirm your obligations with FINTRAC guidance and qualified counsel.

18+ only. Gambling can be addictive — please play responsibly and only bet what you can afford to lose. If gambling is affecting you or someone you know, contact a local support service. This content is informational and never a guarantee of winnings.

Written and reviewed by the iGaming Expert Hub editorial team. Facts checked against primary sources; see the reference above.

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