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<\/figure>\n\n\n\nDetails of the Canada Bank Fined Case and FINTRAC\u2019s Findings<\/h2>\n\n\n\n
Under the regime, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)<\/a> acts as Canada’s primary AML law, under which FINTRAC exerts oversight. According to FINTRAC, FNBC violated five rules under the PCMLTFA, which resulted in enforcement action. Of these violations, one is classified as a “very serious” breach, three are “serious” failures, and the last is a “minor” weakness. <\/p>\n\n\n\n Canada’s AML\/ATF Regime operates on three interdependent pillars<\/a>: policy and coordination, prevention and detection, and, lastly, investigation, prosecution, and disruption.<\/p>\n<\/blockquote>\n\n\n\n The “very serious” breach involved FNBC’s inadequate identification and reporting of suspicious transactions. Among the files examined by FINTRAC, 31% involved transactions for which no suspicious transaction report was submitted despite reasonable grounds to suspect suspicious activity. This violation exposed critical gaps in FNBC’s AML<\/a> controls, potentially enabling suspicious transactions to be sent and received via their services. <\/p>\n\n\n\n Specifically, FNBC did not implement further investigations on scenarios where customer transactions were inconsistent with their financial status, where transactions were structured to avoid reporting threshold alerts, and where there was evidence of dishonesty from clients.<\/p>\n\n\n\n\n
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