The FINTRAC 24-Hour Rule: Static Windows vs. Running Clocks

Few FINTRAC rules look simpler than the 24-hour rule. If a client brings in $6,000 cash in the morning and $5,000 in the afternoon, you treat it as one $11,000 transaction and file a Large Cash Transaction Report (LCTR). Most teams know that much.

The hard part is deciding where the 24 hours start and stop. FINTRAC's guidance describes a static window, such as midnight to midnight. Some compliance teams and examiners read the regulation as a running clock that starts with the first transaction. Both approaches can be defended, but they give different answers in exactly the cases that matter most: transactions spread out to avoid the threshold.

This post covers what the law says, what FINTRAC's guidance adds, where the two interpretations split, and how to pick a method an examiner will accept.

The 24-hour rule is set out in the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), sections 126 to 130. Section 126 covers cash:

The remaining sections apply the same logic to other report types:

Three details in the wording matter:

1. "24 consecutive hours." The regulation does not say "calendar day" or "business day," and it does not say when the 24 hours begin.
2. "Knows." Aggregation applies when you, an employee or a senior officer knows the transactions share a conductor, a third party or a beneficiary. If your records and systems can link them, an examiner will expect you to know.
3. Three aggregation types. Same conductor, same third party (on whose behalf) and same beneficiary are assessed separately. One set of transactions can aggregate one way and not another.

FINTRAC's guidance, Reporting transactions to FINTRAC: The 24-hour rule, describes a static 24-hour window: a fixed period such as 9:00 am Monday to 8:59 am Tuesday. The main points:

• The 24 hours must be consecutive, and a window cannot be longer than 24 hours. A Friday-to-Monday weekend is not one window.
• You can use different static windows for different business lines or transaction types, for example midnight to midnight for wires and 8:00 pm to 7:59 pm for cash.
• A single transaction cannot fall into more than one window.
• Your compliance policies and procedures should state when each window starts and ends, and the start and end times go into the report itself.

Static windows are popular because they are easy to run. A nightly batch job groups the day's transactions, totals them per client and flags anything at $10,000 or more.

The regulation's text supports a second reading. Under a running clock, also called a rolling window, the 24 hours start at the first transaction. Every new transaction then opens a window that looks back (or forward) 24 hours.

FINTRAC's own worked example shows the difference. A client makes three $5,500 cash deposits:

Deposits 2 and 3 are 18 hours apart and total $11,000. A static window never reports that pair. A running clock does.

The gap gets starker at the boundary. Take a business on a midnight-to-midnight window. A client deposits $5,000 at 11:59 pm Monday and $5,500 at 12:01 am Tuesday.

Under the static window, each deposit sits alone in its own day and neither day reaches $10,000, so no report is filed. Under a running clock, $10,500 arrived within 24 consecutive hours, and that is a single reportable transaction under s.126.

This is not hypothetical. Examiners regularly find transactions just inside 24 hours of each other that were never aggregated because they straddled a window boundary. Once a client or an employee learns where the cut-off falls, the boundary becomes a structuring tool.

The key point is that FINTRAC guidance is guidance, not law. The static window examples explain one way to comply. They do not change what the regulation says, and the regulation says "24 consecutive hours."

From that perspective, the regulation doesn't really require you to specify a 24-hour window at all. What it requires is a method that actually captures transactions made within 24 consecutive hours, and that clients or staff can't manipulate. This is also why many practitioners would like FINTRAC to add a running clock example to its guidance alongside the static ones: a 24-hour clock that starts at the first transaction.

Interpretations vary between examiners and over time, and this is not legal advice. The practical takeaway still holds: a static window you can defend on paper can still leave a gap an examiner will find in your data.

Pick the method that best captures the 24-hour period for your business, and be ready to explain why. A few options, from least to most protective:

Whichever you choose, document it:

• Write down the window for each business line and transaction type in your compliance policies and procedures, including start and end times and the time zone you report in.
• Explain why it fits your business: hours of operation, channels and transaction volumes.
• Aggregate each type separately: conductor, third party and beneficiary can each have their own window.
• Store full timestamps for every transaction, not just the date. You can't run a rolling look-back, or prove to an examiner that you didn't need one, without them.
• Test it. In your two-year effectiveness review, sample client activity near your window boundaries and confirm nothing reportable slipped through.

The 24-hour rule exists to stop people from splitting transactions to avoid reporting. A static window follows FINTRAC's examples, but it creates a fixed boundary that can be gamed. A running clock follows the regulation's wording more closely and leaves no boundary to game. Whichever you choose, the test an examiner applies is whether your method actually caught the transactions made within 24 consecutive hours.