Casino Record Keeping Requirements: FINTRAC Guide

Under the casino record keeping requirements FINTRAC sets, a casino keeps a copy of every report it files, large cash and large virtual currency records ($10,000 or more), EFT records ($1,000 or more), receipt of funds and extension of credit records ($3,000 or more), a ticket for every currency exchange, and account records, generally for at least five years.

This guide brings those rules together for compliance officers. It ties each record to its section of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR, SOR/2002-184), made under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), and explains when each five-year clock starts. Sources: FINTRAC's casino record keeping guidance (effective 1 June 2021, date modified 2022-04-27) and the PCMLTFR text on the Justice Laws website (current to 19 October 2026, last amended 26 March 2026), both opened on 14 November 2026. It is a general explainer, not legal advice. Whether a particular operator, including an online one, is a casino reporting entity under the PCMLTFA is a question to settle with FINTRAC guidance and counsel. Gambling is for adults only (18+ or 19+ depending on province); if play stops being fun, contact your provincial responsible gambling service.

Casino record keeping under FINTRAC: the short version

FINTRAC's casino page sorts what you must keep into eight groups: copies of the reports you submit, large cash transaction records, large virtual currency transaction records, electronic funds transfer records, receipt of funds records, foreign currency exchange transaction tickets, extension of credit records and account records. Three rules sit over all of them:

• Retention: keep each record for at least five years. A provincial regulator or your own policy can require longer, never shorter.
• Production: you must be able to give FINTRAC any record within 30 days of a request.
• Format: electronic records are acceptable as long as you can produce a paper copy.

Our page on large cash transaction reports at casinos carries a one-table summary of these records next to the LCTR filing rules. This page goes deeper: section numbers, what each record must contain, which clock applies, how the 24-hour rule affects records, and how to design retention into your systems.

The full record matrix: thresholds, sections and retention

The matrix below is the core of FINTRAC record keeping for casinos. Thresholds are in Canadian dollars. The retention column applies PCMLTFR s.148(1), explained in the next section.

Transaction records

Section 72 is the broadest casino rule and worth reading in full. A large cash transaction record is required for a single cash amount of $10,000 or more received in any of the ways a casino usually takes cash: the sale of chips, tokens or plaques, a front cash deposit, a safekeeping deposit, the repayment of credit (including a marker or counter cheque), a fiat bet, or the sale of casino cheques. There is an exception when the cash comes from a financial entity or a public body. Section 73 applies the same logic to virtual currency worth $10,000 or more. Section 74(2) adds three more record types: extension of credit at $3,000 or more, a foreign currency exchange ticket for every exchange, and records for electronic funds transfers of $1,000 or more.

Account records

Section 74(1) lists what a casino keeps when it opens an account: signature cards, information on each account holder and each person authorised to give instructions, records confirming the binding power of a corporation or other entity, the intended use of the account, account applications, account operating agreements, deposit slips, and debit and credit memos. Together these records tie a funded account to the people who own and control it. Our guide to client identity verification under FINTRAC covers the ID-method records that sit alongside these. If a vendor stores that evidence for you, its retention terms become part of your compliance, so check them when you compare KYC and AML providers for casino operators.

Copies of reports

Every report filed with FINTRAC creates its own record: the copy. That rule is covered in its own section below, because the report names have changed.

How long to keep records: the three five-year clocks

"Five years" is only half the answer; the other half is five years from when. This is where casino records retention in Canada trips teams up. PCMLTFR s.148(1) sets three starting points:

• s.148(1)(a), from the day the account is closed: signature cards, account operating agreements, account applications and records of the intended use of the account.
• s.148(1)(b), from the day of the last business transaction: records of client information and records confirming the existence of an entity.
• s.148(1)(c), from the day the record was created: every other record, including large cash and virtual currency records, EFT records, foreign exchange tickets and credit records.

So the honest answer to "how long must casinos keep records under FINTRAC" is this: at least five years, but the start date depends on the record. A player who opens an account in 2027 and plays until 2035 keeps their account application on file until at least 2040. A large cash record from their first visit can go after five years from the day it was made, unless your own policy or a provincial rule asks for longer. A retention system that applies one flat "delete after five years from creation" rule to everything will destroy account records too early.

The 24-hour rule and record keeping

PCMLTFR s.126 says that when a casino receives two or more cash amounts totalling $10,000 or more within 24 consecutive hours, they are treated as a single transaction if the casino knows they were made by or on behalf of the same person or entity, or for the same beneficiary. The rule applies to the record as well as the report. Three $4,000 cash buy-ins by the same player inside 24 hours create a large cash transaction record and the matching report, even though no single buy-in crosses the threshold.

In practice this means your cage, table and online cashier systems must link transactions to a single person across shifts and channels. Aggregation logic that only runs at the report stage, after the fact, tends to miss the record-keeping step. For the disbursement side of the same rule, see our guide to casino disbursement reports, which applies the 24-hour logic to payouts under PCMLTFR s.71.

Producing records: 30 days, formats and former staff

Under PCMLTFR s.149, records must be provided to FINTRAC within 30 days after a request made under s.62 of the Act. FINTRAC's casino guidance adds the practical conditions:

• Electronic records are acceptable if you can produce a paper copy of them.
• If an employee or contractor who kept records for you leaves, you must obtain those records before they go.
• Retention can be longer than five years if another rule or your policy requires it, but never shorter.

Thirty days is tight when a request covers several years of records across a legacy cage system, an online platform and an outsourced KYC vendor. Test retrieval before an examiner does.

Exceptions that remove duplication

The rules are designed so you do not record the same thing twice. The main exception sits in s.72 itself: cash received from a financial entity or a public body does not need a large cash transaction record. FINTRAC's guidance also lists exceptions where the information you would record is already held in another record you keep. Treat exceptions narrowly and write down which one you are relying on, because an examiner will ask why a record is missing.

Copies of reports: STR, LCTR, LVCTR, CDR, EFTR and the LPEPR

Every report submitted to FINTRAC must be kept as a copy for at least five years. One naming trap: FINTRAC's casino record keeping page (modified 2022-04-27) lists the new report name but still uses the old abbreviation "TPR" in its retention line, a leftover from the Terrorist Property Report. That report has been replaced by the Listed Person or Entity Property Report, and FINTRAC's current guidance for it (modified 1 October 2025) says to keep a copy for at least five years from the day it is sent.

One more related record: under PCMLTFR s.120.2, casinos take reasonable measures to determine whether a person is a politically exposed person or head of an international organization when an account is opened, periodically afterwards, and for international EFTs or cash or virtual currency receipts of $100,000 or more. Keep the record of that determination with the client file.

Building retention into your casino platform

The PCMLTFR casino records above usually live in four or five systems: the cage or cashier, the player account platform, the KYC and screening vendor, the case management tool and email. The checklist below is process guidance, not a legal requirement list. Use it to test whether each record can be found and exported in time.

When you shortlist KYC and AML providers, ask each one how long it keeps verification evidence, whether it applies your retention triggers or its own, and how quickly it can export a full client file. No vendor makes you compliant on its own; the obligation stays with the reporting entity.

Two more checks. Provincial gaming regulators such as Alberta Gaming, Liquor and Cannabis (AGLC) set their own casino AML policies, so read them alongside the federal rules; a provincial rule can lengthen retention but cannot shorten the federal minimum. And FINTRAC publishes a guide on harm done assessment for record keeping violations (date modified 2019-08-26), which explains how it assesses the harm of a record keeping failure and how that feeds the base penalty calculation under its administrative monetary penalties (AMP) framework. Missing or late records are treated as a compliance failure in their own right, not a paperwork detail.

For the full official wording, read FINTRAC record keeping requirements for casinos together with PCMLTFR ss.72-74, 126, 148 and 149. Then check that your KYC and AML stack keeps each record on the right clock and can export it within 30 days.

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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