Administrative monetary penalty on Juba Express Inc.

[2025-12-11]

Juba Express Inc., a money services business in Toronto, Ontario, was imposed an administrative monetary penalty of $67,150 on August 29, 2025, for committing 5 violations. The violations were found during the course of a compliance examination. Juba Express Inc. has appealed the decision to the Federal Court.

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 determined that Juba Express Inc. did not develop and apply its compliance policies and procedures aligned with its obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations. This was determined based on a review of the documentation provided, interviews, and the testing of transaction records.

FINTRAC's review of Juba Express Inc.’s compliance policies and procedures found Juba Express Inc. did not conduct periodic ongoing monitoring of business relationships for the purposes of detecting suspicious transactions, keeping client information up to date, reassessing the level of risk associated with the client, and determining whether transactions were consistent with client information. Additionally, Juba Express Inc.’s policies and procedures indicated suspicious transaction reports would be filed within 30 days after reaching the reasonable grounds to suspect threshold for reporting, instead of filing suspicious transaction reports as soon as practicable. Furthermore, Juba Express Inc.’s policies and procedures did not include how terrorist property reports would be filed to FINTRAC and other mandatory disclosure recipients. Finally, Juba Express Inc.’s policies and procedures did not outline full requirements related to politically exposed persons and heads of international organizations.

Policies and procedures are critical in a compliance program as they 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 potentially leave employees, or those acting on behalf of the business, unaware of the exact actions to take or appropriate decisions to make, in order to comply, when specific situations arise in practice.

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 to assess and document the risk referred to in subsection 9.6(2) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, taking into consideration the prescribed factors – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(c) and subsection 156(2).

FINTRAC determined that Juba Express Inc. failed to assess and document the money laundering and terrorist financing risks related to its products and delivery channels, geographic risks, clients and business relationships, and new developments and technology. While Juba Express Inc. had documented a risk assessment, it was not tailored to reflect Juba Express Inc.’s operations or updated over time. The risk assessment also failed to mitigate factors identified as being high risk using appropriate enhanced risk mitigating measures.

Assessing and documenting money laundering and terrorist 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 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.

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 of a money services business to report the initiation, at the request of a person or entity, of an international electronic funds transfer of $10,000 or more in a single transaction, together with the prescribed information – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 30(1)(b).

FINTRAC examined Juba Express Inc.’s electronic funds transfer reports. Of the reports reviewed, FINTRAC identified 9 instances where the report included incomplete transaction information, initiator information, and/or beneficiary information. Inadequate data included inaccurate addresses, inadequate occupations, missing date of birth, and/or missing transaction time.

Failure to submit a prescribed report such as an electronic funds transfer report along with prescribed information results in a loss of intelligence for FINTRAC which may prevent it from using that information to carry out its mandate per paragraphs 40 (b) and 40 (d) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

Violation #3 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.

Violation #4

Failure of a money services business to report the receipt from a person or entity of an amount of $10,000 or more in cash in a single transaction, together with the prescribed information – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 30(1)(a).

FINTRAC examined Juba Express Inc.’s large cash transactions reports. Of the reports reviewed, FINTRAC identified 3 reports which included inadequate client occupations and/or addresses.

Failure to submit a report such as a large cash transaction report with prescribed information results in a loss of intelligence for FINTRAC which may prevent it from using that information to carry out its mandate per paragraphs 40 (b) and 40 (d) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

Violation #4 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.

Violation #5

Failure of an applicant or a registered person or entity to submit a notification of a change to the information provided in a prescribed application in the prescribed manner and with the prescribed information – Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations, paragraph 4(b) and section 5.

Juba Express Inc. confirmed having two branch locations in addition to their primary location; however, one of the branches was not disclosed on Juba Express Inc.’s money services business registration as required. Additionally, FINTRAC found three discrepancies in the agent information provided on Juba Express Inc.’s registration (two instances where inactive agents had not been removed and one instance where an active agent was not disclosed). Finally, Juba Express Inc.’s money services business registration indicated offering payment service providing activity; however, FINTRAC found that the money services business did not offer payment service providing services in practice.

Registration information lets FINTRAC know of the types of activities, products and services provided by money services businesses that could be used for money laundering and terrorist financing, such as cash transactions and transferable monetary instruments, international electronic funds transfers, informal remittance systems and foreign currency exchanges. Money services business registration information also includes details on a business’ model and size. This information allows FINTRAC to understand the complexity of the business’ operations and helps to assess the risks and consequences of non-compliance. Registration information that is not submitted in the prescribed manner or that is incomplete, outdated, or unclear diminishes the effectiveness of FINTRAC's compliance activities and its ability to ensure compliance in the money services business sector.

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.

Related link

• News release: FINTRAC imposes an administrative monetary penalty on Juba Express Inc.