Administrative monetary penalty on Caisse populaire Alliance limitée

[2026-09-24]

Caisse populaire Alliance limitée, also operating as Caisse Alliance, a provincial credit union headquartered in North Bay, Ontario, was imposed an administrative monetary penalty of $82,500 on June 5, 2026, for committing 4 violations. The violations were found during the course of a compliance examination. Caisse Alliance has paid the administrative monetary penalty in full and the case is closed.

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 – subsection 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 156(1)(b) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations

FINTRAC’s examination revealed that Caisse Alliance’s policies and procedures were incomplete, both in terms of documentation and implementation, in relation to various regulatory requirements.

More specifically:

• Caisse Alliance’s policies did not include measures addressing ministerial directives and operational restrictions related to Russia.
• Caisse Alliance’s policies did not address the obligation to report suspected sanctions evasion.
• FINTRAC identified gaps in client information, such as missing occupation details, and found that client information requirements were not consistently applied in accordance with its policies and procedures, affecting the ability to assess risks associated with clients.
• FINTRAC identified gaps in the analysis of unusual transaction alerts, including incomplete evaluations, limited adverse media research, and insufficient documentation, indicating that alert review requirements were not consistently applied in accordance with Caisse Alliance’s policies and procedures.
• FINTRAC’s examination found that ongoing monitoring practices did not consistently reflect the risks posed by clients.

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 take the prescribed special measure for high-risk activities – subsection 9.6(3) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 157 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations

FINTRAC’s examination revealed that Caisse Alliance did not conduct enhanced ongoing monitoring of high-risk clients in accordance with its own policies and procedures. While Caisse Alliance’s policy requires an annual review of high-risk clients, 46 of 118 high-risk client files had not been reviewed in over 12 months. Among these, 10 files had not been reviewed in more than 5 years, and 6 files had gaps exceeding 10 years between their two most recent reviews.

Although Caisse Alliance has established procedures for enhanced ongoing monitoring, including more frequent reviews for higher-risk clients, FINTRAC’s examination found that these procedures were not consistently applied in practice.

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 assess and document the risk of a money laundering or terrorist activity financing offence, taking into consideration prescribed factors – subsection 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 156(1)(c) and subsection 156(2) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations

FINTRAC’s examination revealed that Caisse Alliance’s risk-based assessment was incomplete, as it did not document an adequate assessment of the money laundering and terrorist activity financing risks associated with prescribed factors.

While the geographical locations of Caisse Alliance’s branches were assessed, FINTRAC identified a lack of analysis detailing how these geographical risks were evaluated. FINTRAC also found that Caisse Alliance had not assessed the money laundering and terrorist activity financing risks associated with the geographic locations where its clients reside.

Additionally, Caisse Alliance implemented new industry-specific operational and transaction-processing systems that support client onboarding, account management, payment processing, and lending activities, without assessing the associated money laundering and terrorist activity financing risks or establishing appropriate mitigation measures. Caisse Alliance’s use of a third-party provider to assign risk levels to clients was also found to be insufficient, as its predefined categories did not generate adequate transactional alerts for all transaction types and client profiles. This limitation contributed to missed red flags, including international electronic funds transfers to high-risk countries.

Lastly, Caisse Alliance’s evolving business model should have triggered a comprehensive update of its risk assessment to identify current risks, implement appropriate controls, and establish effective mitigation measures. However, this update was not conducted.

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 – subsection 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, and paragraph 156(1)(f) and subsection 156(3) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations

FINTRAC’s examination revealed that Caisse Alliance’s most recent two-year effectiveness review was incomplete and inadequate, as it did not fully assess the effectiveness of the compliance program, particularly regarding documentation and practical implementation. Although the review identified certain findings, it did not identify weaknesses subsequently identified by FINTRAC, including gaps in policies and procedures, the analysis of unusual transactions and the identification and reporting of suspicious transactions.

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 Caisse populaire Alliance limitée