Administrative monetary penalty on Caisse populaire acadienne ltée

[2026-09-24]

Caisse populaire acadienne ltée, also operating as UNI Financial Cooperation, a federally regulated credit union headquartered in Caraquet, New Brunswick, was imposed an administrative monetary penalty of $676,500 on July 23, 2026, for committing 3 violations. The violations were found during the course of a compliance examination. Caisse populaire acadienne ltée has paid the administrative monetary penalty in full and the case is closed.

Nature of violation

Violation #1

Failure of a person or entity to report financial transactions that occurred in the course of its activities and in respect of which there are reasonable grounds to suspect that the transactions are related to the commission or the attempted commission of a money laundering or a terrorist activity financing offence – section 7 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act

FINTRAC’s examination determined that in 4 instances, Caisse populaire acadienne ltée failed to report multiple financial transactions that exhibited money laundering or terrorist activity financing indicators and met the reasonable grounds to suspect threshold. Caisse populaire acadienne ltée failed to report these financial transactions in suspicious transaction reports to FINTRAC.

The 4 unreported suspicious transaction reports contained some of the following indicators:

• Size or type of transactions atypical of what is expected from the client.
• Funds transferred in and out of an account on the same day or within a relatively short period of time.
• Frequent transfers between different financial institutions.
• Transaction involving an unusual or unjustified amount.
• Transactions involving individuals or entities identified by the media, law enforcement, and/or intelligence agencies as being linked to criminal activities.

Violation #1 is classified by regulations as a Very 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 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 populaire acadienne ltée’s documented policies and procedures were incomplete, due to gaps in both documentation and application, related to various regulatory requirements.

More specifically:

• The policies failed to document procedures for handling production orders related to money laundering and terrorist financing indicators. As a result, 4 suspicious transaction reports were not submitted.
• FINTRAC identified weaknesses in the analysis of unusual transactions alerts as they were missing complete transaction assessments, linkages of account searches, and documented conclusions.
• FINTRAC found that ongoing monitoring was performed inconsistently, as some clients had outdated identification information, and documented policies and procedures related to ongoing monitoring were not consistently followed.
• FINTRAC found that Caisse populaire acadienne ltée failed to address transactional alerts backlog posing risks to accurate client risk ratings, enhanced measures, and suspicious transaction reporting.

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 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 populaire acadienne ltée’s risk-based assessment was incomplete, as it did not document a complete assessment of the money laundering and terrorist activity financing risks associated with prescribed factors.

Caisse populaire acadienne ltée’s risk assessment did not include sufficient analysis of its client base, including a breakdown of clients across different risk categories. This lack of information prevented Caisse populaire acadienne ltée from understanding its overall risk profile and adjusting its ongoing monitoring measures accordingly, limiting its ability to identify inherent vulnerabilities and align controls with actual risks.

In addition, FINTRAC found that Caisse populaire acadienne ltée’s risk assessment was not applied in practice, not adequately identifying high‑risk activities that could have resulted in an increase in client risk scoring or suspicious transaction reporting.

FINTRAC noted that Caisse populaire acadienne ltée did not conduct the required risk assessment of its transaction monitoring system, an essential step for identifying system vulnerabilities and documenting mitigation measures. This limited Caisse populaire acadienne ltée’s ability to understand and address weaknesses in its transaction monitoring framework.

Finally, FINTRAC found that Caisse populaire acadienne ltée did not include manual processes to adjust the risk rating for scenarios not automatically captured by its transaction monitoring system, such as production orders or adverse media. This affected Caisse populaire acadienne ltée’s ability to accurately risk rate its clients and possible suspicious transaction reporting to FINTRAC.

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.

Related link

• News release: FINTRAC imposes an administrative monetary penalty on Caisse populaire acadienne ltée