Administrative monetary penalty on 2294235 Ontario Inc.

[2025-12-02]

2294235 Ontario Inc., also operating as Global Currency Exchange, a money services business in Niagara Falls, Ontario, was imposed an administrative monetary penalty of $70,537.50 on July 28, 2025, for committing 6 violations. The violations were found during the course of a compliance examination.

Nature of violation

Violation #1

Failure to develop and apply written compliance policies and procedures that are kept up to date and, in the case of an entity, are approved by a senior officer – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(b)

FINTRAC’s examination determined that 2294235 Ontario Inc. had incomplete and inadequate policies and procedures that did not address the majority of the requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations. Specifically, 2294235 Ontario Inc.’s policies and procedures did not adequately document requirements related to filing reports to FINTRAC, know your client obligations, ministerial directives, and keeping prescribed records.

Policies and procedures are critical in a compliance program to set out and communicate important principles and standards that employees and delegated persons with compliance responsibilities must meet in a consistent manner. Documented policies and procedures also serve to ensure clarity and consistency in business operations. Failing to develop, apply, and keep written compliance policies and procedures up to date can result in not meeting other requirements set out in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations, and undervalues sound business practices designed to minimize a business’ exposure to money laundering and terrorist activity financing. Partially documented policies and procedures can leave employees, or those acting on behalf of the business, unaware of the exact actions to take or appropriate decisions to make, when specific situations arise in practice.

In this case, violation #1 is classified by regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Violation #2

Failure of a person or entity to assess and document the risk, taking into consideration prescribed factors – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9.6(2) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(c) and subsection 156(2)

FINTRAC’s examination determined that 2294235 Ontario Inc. did not assess and document risks related to money laundering and terrorist activity financing. 2294235 Ontario Inc. failed to consider the risks of their products, services, and delivery channels, geography, risks related to new developments and technologies, or other relevant factors. Additionally, 2294235 Ontario Inc. did not establish risk assessment processes for clients and business relationships.

Assessing and documenting money laundering and terrorist activity financing risks ensures that reporting entities are aware of their potential exposure and vulnerability. Failing to assess and document the risks of money laundering and terrorist activity financing prevents reporting entities from identifying areas of its operations that are vulnerable to being exploited for these purposes and prevents appropriate mitigation measures from being put in place. This can also lead to failing to identify high-risk clients and business relationships for which enhanced risk mitigation measures must be applied. This can further result in the failure to detect and report suspicious transactions to FINTRAC.

In this case, violation #2 is classified by regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Violation #3

Failure to develop and maintain a written, ongoing compliance training program – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraphs 156(1)(d) and (e)

FINTRAC’s examination determined that 2294235 Ontario Inc. failed to develop and maintain a written, ongoing compliance training program. 2294235 Ontario Inc. confirmed that verbal training was provided to staff informally, but there was no documented training program or plan.

The purpose of a written, ongoing compliance training program is to ensure that all employees, agents, mandataries and/or other persons authorized to act on the reporting entity’s behalf understand the requirements of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations and follow the policies and procedures that have been established for compliance. It also ensures that employees, agents, mandataries and other persons authorized to act on a reporting entity's behalf understand money laundering and terrorist activity financing matters enough to be able to identify facts that may indicate financial transactions or activities related to these offences. Failing to develop and maintain a written, ongoing compliance training program may result in the above listed purposes not being met over time, and consequently, failing to comply with the requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations.

In this case, violation #3 is classified by regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Violation #4

Failure to institute and document the prescribed review – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(f) and subsection 156(3)

FINTRAC’s examination determined that 2294235 Ontario Inc. failed to institute and document the prescribed review of its policies and procedures, risk assessment, and training program. Specifically, 2294235 Ontario Inc. confirmed having never conducted a prescribed review of its compliance program.

Failing to conduct the prescribed review signals that the reporting entity may not be fulfilling one or more of its other requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Actand associated Regulations, by not having kept up to date with changes in the organization or external changes, such as new technologies in the financial sector and regulatory updates. Additionally, any gaps or ineffective processes in the existing compliance program may go undetected, leading to uncorrected non-compliance.

In this case, violation #4 is classified by regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Violation #5

Failure to provide, in accordance with a notice, documents or other information reasonably required by an authorized person – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 63.1(2)

2294235 Ontario Inc. failed to provide, in accordance with a notice, the requested foreign exchange transaction information for purposes of a compliance examination. On multiple occasions during the examination, FINTRAC requested all foreign exchange transaction ticket records for the examination period. 2294235 Ontario Inc. failed to provide foreign exchange transaction records for transactions valued under $3,000 CAD.

Failing to provide an authorized person reasonable assistance and any information with respect to the administration of Part 1 and 1.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations, or in accordance with a served notice, interferes with FINTRAC's compliance activities and its mandate under subsection 40(e) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. If FINTRAC is unable to ensure compliance, the regime's ability to detect, prevent and deter money laundering and the financing of terrorist activities is affected.

In this case, violation #5 is classified by regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Violation #6

Failure to keep prescribed records – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 36(i)

FINTRAC examined 5 foreign exchange transaction tickets valued at or above $3,000 CAD during the examination period. 2294235 Ontario Inc. failed to record the client’s occupation and the source of the exchange rate for all 5 foreign exchange transaction tickets.

FINTRAC was unable to assess foreign exchange transaction records for transactions under $3,000 CAD as they were not provided (see violation #5).

Record keeping requirements are important to Canada's anti-money laundering and anti-terrorist activity financing regime because they compel the preservation of the information needed to achieve the objectives of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations, as well as FINTRAC's mandate. Records that businesses are required to keep serve many purposes for the reporting entity, law enforcement and FINTRAC. Records with missing, incomplete, incorrect or inadequate information may affect the reporting entity’s ability to submit high quality and timely transaction reports to FINTRAC and to conduct effective risk assessments. They may also interfere with law enforcement investigations, and with FINTRAC's ability to ensure compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations

In this case, violation #6 is classified by regulations as a Minor violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Related link

• News Release: FINTRAC imposes an administrative monetary penalty on 2294235 Ontario Inc.