Administrative monetary penalty on Northern Isga Foundation

[2026-03-26]

Northern Isga Foundation, a non-profit charitable organization authorized by the Alexis Nakota Sioux Nation Chief and Council to serve as the Nation’s Host First Nation charitable organization for the Eagle River Casino and Travel Plaza, a reporting entity in the casino sector, headquartered in Glenevis, Alberta, was imposed an administrative monetary penalty of $91,162.50 on March 2, 2026, for committing 4 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 Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(b)

FINTRAC’s examination revealed that Northern Isga Foundation failed 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. Specifically, Northern Isga Foundation’s policies and procedures were missing the following requirements, or the documentation and application of the requirements were incomplete:

• Verifying the identity of persons and entities: failed to document how patron identity is verified for large virtual currency transactions or for the receipt of funds of $3,000 or more.
• Ongoing monitoring: failed to outline how ongoing monitoring is conducted, how monitoring frequency is determined, or what enhanced measures apply to high‑risk patrons.
• Beneficial ownership: failed to document beneficial ownership requirements, including the definition, when information must be obtained, or what reasonable measures are used to confirm accuracy.
• Politically Exposed Persons (PEPs) and Heads of International Organizations (HIOs): failed to define the obligations related to determining whether a patron is a PEP or HIO. In addition, Northern Isga Foundation did not document the steps to take after identification of a PEP or HIO, including the associated record‑keeping requirements.
• Reporting requirements: failed to address reporting obligations for listed person or entity property reports, large virtual currency transaction reports, electronic funds transfer reports, or sanctions‑related reporting. Reporting timelines for required report types were also not documented.
• Record-keeping requirements: failed to outline record‑keeping requirements for large cash transactions, large virtual currency transactions, electronic funds transfers, receipt‑of‑funds records of $3,000 or more, or listed person or entity property reports.
• Ministerial directives: failed to document how ministerial directives are identified nor the steps it takes to ensure it meets the additional requirements as per each applicable directive.

Violation #1 is classified by the 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 Act, taking into consideration prescribed factors – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(c)

FINTRAC’s examination revealed that Northern Isga Foundation failed to assess and document the money laundering and terrorist financing risks related to certain prescribed factors. Specifically, Northern Isga Foundation failed to include “geography” and “other relevant factors” as prescribed risk factors in its risk assessment. Additionally, Northern Isga Foundation failed to document any additional controls, mitigation strategies, and enhanced or special measures for any identified high-risk patrons and business relationships.

Violation #2 is classified by the 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 Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraphs 156(1)(d) and paragraph 156(1)(e)

FINTRAC’s examination revealed that Northern Isga Foundation failed to develop an ongoing compliance training program. Northern Isga Foundation also failed to document a plan for its ongoing compliance training program and its delivery addressing the timing and frequency of training delivery, the recipients of the training, the training topics and material, and methods of delivery. In addition, Northern Isga Foundation failed to provide records of training delivered to its employees to demonstrate the delivery of any training.

Violation #3 is classified by the 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 Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(f)

FINTRAC’s examination revealed that Northern Isga Foundation failed to institute and document the prescribed review of its compliance program to assess the effectiveness of its policies and procedures, risk assessment, and training program. Specifically, Northern Isga Foundation’s policies and procedures indicated that it would conduct a documented review of its compliance program to test for effectiveness, but no documentation was provided to demonstrate that the prescribed review was conducted.

Violation #4 is classified by the 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 Northern Isga Foundation