FINTRAC Fines Cambrian Credit Union $116,160 Over AML Compliance Lapses
| 2025-06-10
Cambrian Credit Union in Canada has been fined $116,160 by FINTRAC for failing to meet anti-money laundering obligations, including reporting and risk assessment.
Cambrian Credit Union in Canada has been fined $116,160 by FINTRAC for failing to meet anti-money laundering obligations, including reporting and risk assessment.
Canada’s Financial Transactions and Reports Analysis Centre (FINTRAC) imposed the penalty on 3 March 2025 following a compliance review conducted in 2023. The investigation revealed four violations of Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated regulations. The credit union, headquartered in Winnipeg, has paid the fine in full, and no further action is pending.
Failure to Report Suspicious Transactions
The most serious breach involved the failure to file a Suspicious Transaction Report, despite evidence suggesting potential links to money laundering or terrorist financing. According to FINTRAC, Cambrian Credit Union did not carry out enhanced due diligence on a high-risk client who had previously been reported. As a result, subsequent transactions by the same individual were neither investigated nor reported, despite meeting the threshold for suspicion.
This violation, which undermined the agency’s ability to detect financial crime, was classified as “very serious” under Canadian regulations.
Gaps in Electronic Funds Reporting
The second violation concerned the non-reporting of two incoming international electronic fund transfers, each valued at CAD 10,000 or more. These transactions, which met the threshold for mandatory disclosure, were not flagged due to what FINTRAC described as human error and inconsistencies in internal reporting procedures.
While considered a “minor” violation, the lapse indicated deficiencies in the institution’s ability to consistently implement its own policies.
Weak Internal Policies and Procedures
FINTRAC also cited Cambrian Credit Union for failing to maintain adequate written policies and procedures for compliance. The agency said the institution’s documentation lacked sufficient guidance on transaction monitoring, suspicious activity reporting, and handling law enforcement requests.
The agency noted that an effective compliance programme is essential to protect Canada’s financial system. “When a reporting entity fails to conduct thorough ongoing monitoring of business relationships, it is unaware of changes to the client’s transactions, activities, and circumstances,” FINTRAC stated in its findings.
Incomplete Risk Assessment Framework
The fourth violation addressed the credit union’s incomplete risk-based assessment. FINTRAC found that Cambrian Credit Union did not fully evaluate the risks associated with client behaviour, geographic exposure, or the use of new technologies.
In particular, the institution failed to explain the rationale behind its risk classifications or demonstrate that it had implemented adequate mitigation measures. The lack of detailed analysis could result in an inability to identify or address high-risk activities, thereby increasing exposure to financial crime.
Context
Under Canadian law, financial institutions are required to identify, assess, and mitigate risks related to money laundering and terrorist financing. These obligations include reporting suspicious transactions, maintaining detailed compliance programmes, and monitoring client relationships on an ongoing basis.
FINTRAC is responsible for ensuring that regulated entities, such as credit unions and banks, comply with these requirements. Administrative monetary penalties are among the enforcement tools it uses to promote accountability and strengthen Canada’s anti-money laundering framework.
The penalty against Cambrian Credit Union follows a number of similar actions taken in recent years against financial institutions that fail to meet compliance standards. These measures are designed to enhance transparency and reduce the risk of criminal abuse of Canada’s financial system.
Failure to Report Suspicious Transactions
The most serious breach involved the failure to file a Suspicious Transaction Report, despite evidence suggesting potential links to money laundering or terrorist financing. According to FINTRAC, Cambrian Credit Union did not carry out enhanced due diligence on a high-risk client who had previously been reported. As a result, subsequent transactions by the same individual were neither investigated nor reported, despite meeting the threshold for suspicion.
This violation, which undermined the agency’s ability to detect financial crime, was classified as “very serious” under Canadian regulations.
Gaps in Electronic Funds Reporting
The second violation concerned the non-reporting of two incoming international electronic fund transfers, each valued at CAD 10,000 or more. These transactions, which met the threshold for mandatory disclosure, were not flagged due to what FINTRAC described as human error and inconsistencies in internal reporting procedures.
While considered a “minor” violation, the lapse indicated deficiencies in the institution’s ability to consistently implement its own policies.
Weak Internal Policies and Procedures
FINTRAC also cited Cambrian Credit Union for failing to maintain adequate written policies and procedures for compliance. The agency said the institution’s documentation lacked sufficient guidance on transaction monitoring, suspicious activity reporting, and handling law enforcement requests.
The agency noted that an effective compliance programme is essential to protect Canada’s financial system. “When a reporting entity fails to conduct thorough ongoing monitoring of business relationships, it is unaware of changes to the client’s transactions, activities, and circumstances,” FINTRAC stated in its findings.
Incomplete Risk Assessment Framework
The fourth violation addressed the credit union’s incomplete risk-based assessment. FINTRAC found that Cambrian Credit Union did not fully evaluate the risks associated with client behaviour, geographic exposure, or the use of new technologies.
In particular, the institution failed to explain the rationale behind its risk classifications or demonstrate that it had implemented adequate mitigation measures. The lack of detailed analysis could result in an inability to identify or address high-risk activities, thereby increasing exposure to financial crime.
Context
Under Canadian law, financial institutions are required to identify, assess, and mitigate risks related to money laundering and terrorist financing. These obligations include reporting suspicious transactions, maintaining detailed compliance programmes, and monitoring client relationships on an ongoing basis.
FINTRAC is responsible for ensuring that regulated entities, such as credit unions and banks, comply with these requirements. Administrative monetary penalties are among the enforcement tools it uses to promote accountability and strengthen Canada’s anti-money laundering framework.
The penalty against Cambrian Credit Union follows a number of similar actions taken in recent years against financial institutions that fail to meet compliance standards. These measures are designed to enhance transparency and reduce the risk of criminal abuse of Canada’s financial system.
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