Comply+ FINTRAC Reporting

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) has imposed a $601,139.80 administrative monetary penalty (AMP) on First Nations Bank of Canada (FNBC) for multiple violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations.

The penalty follows a compliance examination that revealed significant gaps in the bank's anti-money laundering and anti-terrorist financing (AML/ATF) controls. The case was finalized on September 22, 2025, and the administrative monetary penalty has been paid in full.

Key Details

Penalty Amount: $601,139.80
Date Finalized: September 22, 2025
Bank: First Nations Bank of Canada (FNBC)
Headquarters: Saskatoon, Saskatchewan
Status: Penalty paid in full

What FINTRAC Found

According to FINTRAC, FNBC was found to have committed five key violations under the PCMLTFA:

Failure to submit Suspicious Transaction Reports (STRs) where reasonable grounds existed to suspect that transactions were related to money laundering or terrorist financing.
Failure to develop and apply written compliance policies and procedures that were current and approved by a senior officer.
Failure to assess and document AML/ATF risks associated with its operations.
Failure to take prescribed special measures as required under the Regulations.
Failure to conduct ongoing monitoring of business relationships to detect suspicious patterns or unusual activities.

These failures strike at the heart of Canada's AML/ATF framework, as they directly impact FINTRAC's ability to generate financial intelligence used by law enforcement and national security agencies.

Critical Impact: When a financial entity fails to file STRs, FINTRAC loses visibility into potentially criminal financial activity—which, in turn, undermines Canada's broader efforts to combat money laundering and terrorist financing.

Why This Penalty Matters

At over $600,000, this is one of the largest penalties issued by FINTRAC in 2025—underscoring that even federally regulated financial institutions are not immune from enforcement action.

The violations point to systemic breakdowns in both transaction monitoring and program governance, including the absence of effective internal oversight. This case reinforces that:

Policy Implementation

Policies must be more than written documents—they need to be applied, enforced, and updated as risks evolve.

Ongoing Monitoring

Ongoing monitoring is not optional. Even smaller or regionally focused banks must have automated or systematic methods to detect unusual transactions.

Senior Management Oversight

Senior management approval and oversight are mandatory—FINTRAC expects accountability at the leadership level.

The Broader Enforcement Context

FINTRAC has intensified enforcement actions over the past two years:

23 Notices of Violation were issued in 2024–25—the highest in its history—totaling more than $25 million in penalties.
Over 150 penalties have been imposed across all sectors since 2008.
The trend is clear: FINTRAC expects full compliance across all reporting entities—from major banks and credit unions to accountants, MSBs, and real estate firms.

Lessons for Financial Institutions

This case highlights the need for financial entities to review and reinforce their AML programs immediately. Key action points include:

1. Re-evaluate STR Procedures

Ensure all front-line staff and compliance officers clearly understand what constitutes "reasonable grounds to suspect." Train for judgment calls, not just thresholds.

2. Review Written Policies and Risk Assessments

Documentation must match real operational risk. FINTRAC will not accept outdated or boilerplate compliance manuals.

3. Audit Ongoing Monitoring Processes

Whether manual or automated, monitoring systems must flag unusual activity patterns. FINTRAC expects clear escalation pathways and documented reviews.

4. Verify Senior Officer Approval

Policy and procedural changes must be reviewed and formally approved at the senior management level, ensuring accountability and governance integrity.

A Reminder: Non-Compliance Is No Longer Just Financial

Under Bill C-2, amendments to the PCMLTFA introduce even harsher penalties—including potential imprisonment for certain non-compliance offences and sharply increased monetary fines. This means that organizations can no longer treat reporting obligations as an administrative nuisance—they are now a legal and criminal exposure point.

Critical Warning

Accuracy and timeliness in FINTRAC reporting have never been more critical. Even a well-intentioned firm can be penalized if reports are missing, incomplete, or incorrectly filed—especially since FINTRAC's FWR (web reporting) tool does not automatically validate some report types like LVCTRs.

How Comply+ Can Help

Staying compliant under this expanding regulatory environment requires more than policy binders—it demands automation, audit-ready documentation, and intelligent reporting.

Comply+ helps organizations:

Automate LCTR, LVCTR, EFTR, and STR submissions directly through the FINTRAC API
Maintain up-to-date compliance documentation and audit trails
Receive proactive alerts when reporting thresholds or timelines are approaching
Implement systematic ongoing monitoring with automated suspicious activity detection
Ensure senior officer approval workflows for all compliance policies and procedures
Generate comprehensive risk assessments with documented mitigation strategies

With Comply+, your reporting is accurate, verifiable, and always on time—ensuring your institution stays ahead of regulatory risk and avoids costly enforcement actions like the one faced by First Nations Bank of Canada.

The Bottom Line

The $601,139.80 penalty against First Nations Bank of Canada serves as a stark reminder that no financial institution is too small or too specialized to escape FINTRAC's scrutiny. The violations found in this case—particularly the failure to submit STRs and maintain adequate ongoing monitoring—represent fundamental breakdowns in AML controls that put both the institution and Canada's financial system at risk.

As enforcement actions continue to increase in frequency and severity, financial institutions must prioritize comprehensive AML program implementation, regular compliance testing, and investment in technology solutions that can automate and validate reporting processes.

Take Action Now: Don't wait for a compliance examination to discover gaps in your AML program. Review your policies, test your procedures, and ensure your technology infrastructure can support accurate and timely FINTRAC reporting.

FINTRAC Fines First Nations Bank of Canada $601,139.80 for AML Compliance Failures