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Credit Unions Facing Fines


In 2008 the Financial Transactions and Reports Analysis Center (FINTRAC) was given the authority to issue monetary fines against organizations and individuals who fail to implement adequate Anti Money Laundering (AML) controls. Since this time, FINTRAC has undertaken numerous audits of credit unions. This resulted in the first public fine issued against a credit union in Ontario for the sum of $37,090.

What does this mean for the credit union industry?

It means that credit unions are currently on FINTRAC’s radar. In the last year, numerous credit unions have undergone both onsite and desk audits. Virtually all were cited for a deficiency.

Could these deficiencies result in more fines being issued?

No one knows for sure. What we do know is that the process is slow and it can take over a year for a fine to be issued after the initial deficiency is noticed. This means we may begin to see numerous monetary fines being announced, as the notifications occur and appeal deadlines expire.

Protect your credit union’s reputation and bottom line.

If you have not completed an independent compliance review you are already in violation of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Your first independent review was supposed to be completed by June 2010. If you haven’t taken action yet, it is critical that you arrange for an independent compliance review immediately.

The review scope must ensure that the requirements of the Act are adequately addressed. The review must include a sampling and review of client records, transactions and regulatory reports. This sampling should be based on the results of the mandatory risk-based assessment of your products, members and your credit union.

For additional guidance on conducting a compliance review see Section 8 of Guideline 4: Implementation of a Compliance Regime available here.