Large Virtual Currency Transaction Report Casino Rules: The CAD 10,000 Threshold
For a casino, a large virtual currency transaction report is triggered when the casino receives virtual currency worth CAD 10,000 or more in a single transaction. The filing is a threshold report. It does not depend on whether the player looks suspicious.
This guide covers the amount, the aggregation rule, the filing clock and the records to keep. It is general information, not legal advice. Check your own obligations against the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, its regulations and current FINTRAC guidance.
What triggers the report at a casino
The trigger is receipt. When a casino takes in virtual currency from a player and the amount is CAD 10,000 or more, the event is reportable. FINTRAC states the amount in Canadian dollars, so any crypto deposit has to be converted. The Bank of Canada does not publish virtual currency rates, so the casino sets its own exchange-rate method under its FINTRAC LVCTR guidance, documents it and applies it the same way each time.
Not every token is in scope. FINTRAC defines virtual currency as a digital representation of value, or the private key that gives access to one, that can be used for payment or investment and is readily exchangeable for funds or for another exchangeable currency. Currencies that work only inside a closed environment, or that can be redeemed only for goods, services or loyalty rewards, fall outside that definition. A casino should test each asset it accepts against the definition and record the result for each asset, rather than assume that all crypto is covered.
The 24-hour rule catches split deposits
A single transaction is not the only trigger. Two or more receipts that add up to CAD 10,000 or more within a consecutive 24-hour window must also be reported when the casino knows they are conducted by the same person or entity, on behalf of the same third party, or for the same beneficiary. A player who makes several smaller wallet deposits in one day is the typical case. Teams that build only single-transaction checks tend to miss it.
Filing deadline and record keeping
The report is due within 5 working days after the day the casino receives the amount. A working day is Monday to Friday, excluding public holidays. Keep a copy of each report for at least 5 years from the date it was created.
- Record the receipt date in one system of record, so the 5-working-day clock can be shown.
- Store the exchange rate used, the method behind it and the date it was applied.
- Keep a log of each filing, including who submitted it and when.
- Retain every filed copy for at least 5 years.
How LVCTRs differ from STRs and large cash reports
An LVCTR is filed because of the amount. A suspicious transaction report works differently. It is triggered by suspicion rather than by an amount, and it is due as soon as practicable after the casino completes the measures that support its reasonable grounds to suspect money laundering or terrorist financing. A large cash receipt is reported on a separate large cash transaction report instead, so the same player can generate different filings depending on the asset used. Our suspicious transaction report guide covers the suspicion test and the narrative in detail.
Three gaps to check first
Three gaps are worth checking first in any casino LVCTR program. The first is conversion: the exchange rate is chosen after the fact to fit the number, or it is never written down. The second is scope: in-platform tokens are assumed to be virtual currency, or real crypto is assumed to be out of scope, without a test against the definition. The third is aggregation: single-transaction logic is built and the 24-hour window is never added. Each gap can be closed with a short written procedure and a test file of sample transactions that someone signs off each quarter.
For the wider obligations on crypto-accepting casinos, including the travel rule that applies to electronic funds and virtual currency transfers, read our crypto travel rule guide.
The rules above reflect the FINTRAC casino and LVCTR pages reviewed for this article. FINTRAC updates its guidance, so confirm the threshold, deadline and definition against the current source before you rely on them.