Administrative monetary penalty on Pathwise Credit Union
[2026-09-24]
Pathwise Credit Union, a provincial credit union headquartered in Oshawa, Ontario, was imposed an administrative monetary penalty of $41,250 on June 4, 2026, for committing 2 violations. The violations were found during the course of a compliance examination. Pathwise Credit Union has paid the administrative monetary penalty in full and the case is closed.
Nature of violation
- Violation #1
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Failure of a person or entity 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 determined that Pathwise Credit Union’s compliance policies and procedures were incomplete, as they did not document and apply the necessary measures to meet all of the entity’s obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations. The policies and procedures identified as incomplete were as follows:
- The frequency of ongoing monitoring of business relationships was not commensurate with a risk‑based approach, and the documented ongoing monitoring frequency was not applied in practice. A review of ongoing monitoring records revealed a backlog of medium‑risk account reviews, as well as low‑risk accounts that were monitored only on a trigger basis rather than at the frequency established in the policies and procedures.
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
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Failure of a person or entity 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) and subsection (2)
FINTRAC’s examination found that Pathwise Credit Union did not adequately assess or document the money laundering and terrorist financing risks associated with certain prescribed factors. The credit union’s risk assessment was incomplete, as it did not fully evaluate risks related to its clients and business relationships.
Furthermore, FINTRAC’s examination found that Pathwise Credit Union did not adhere to its own risk assessment, which includes a specific timeframe for which members must be classified as high risk after being subject to a suspicious transaction report.
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.
Related link
- Date Modified: