FINTRAC Penalty on Global Currency Exchange: Compliance Failures and What MSBs Must Learn From This Case
On December 2, 2025, FINTRAC announced a new enforcement action—this time against 2294235 Ontario Inc., operating as Global Currency Exchange, a money services business (MSB) located in Niagara Falls, Ontario. Following a compliance examination, the MSB was ordered to pay an administrative monetary penalty (AMP) of $70,537.50 for multiple violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations.
While this is not one of FINTRAC's largest MSB penalties, it is one of the most instructive for small and mid-sized MSBs across Canada. The violations highlight several common—and preventable—compliance failures that continue to trigger enforcement actions nationwide.
Below, we break down the findings, explain why they matter, and outline what every MSB should be doing right now to avoid similar penalties.
Source: FINTRAC Official News Release
Read the full FINTRAC announcementWhat FINTRAC Found: A Breakdown of the Violations
According to FINTRAC, Global Currency Exchange committed six separate administrative violations:
1. Failure to Maintain Up-to-Date Compliance Policies and Procedures
FINTRAC determined the MSB's written policies were incomplete, outdated, or not reflective of actual business operations. This is one of the most common violations seen during examinations.
A compliant MSB must have written procedures which include, but are not limited to:
- KYC/identity verification
- Suspicious transaction reporting
- Large cash and EFT reporting
- Record-keeping
- Risk assessment and ongoing monitoring
- PEP/HIO determinations
- Training and review cycles
If any of these are missing—or not tailored to the business—FINTRAC treats it as a serious compliance weakness.
2. Failure to Conduct and Document a Risk Assessment
This continues to be one of the most frequent violations seen across the MSB sector. FINTRAC requires MSBs to assess the ML/TF risks associated with:
- Products and services
- Client types
- Delivery channels
- Geographic exposure
- Business model complexity
- Technology used
This risk assessment must be written, updated, and applied. Without it, the rest of the compliance program has no foundation.
3. Failure to Develop and Maintain a Compliance Training Program
Training failures are a leading cause of operational non-compliance.
FINTRAC requires MSBs to:
- Deliver AML training to all relevant employees
- Maintain training logs
- Have annual refresher modules
- Ensure staff understand red flags and escalation procedures
It seems that Global Currency Exchange could not demonstrate that such a program existed.
4. Failure to Conduct the Required Two-Year Effectiveness Review
Every two years, MSBs must conduct a documented review—internal or external—to test whether:
- Policies and procedures reflect current operations
- STRs, LCTRs, EFTRs, and LVCTRs are being filed correctly
- Risk assessment methodology is functioning
- Training is effective
- Records are being kept and retained properly
5. Failure to Provide Requested Documents or Information
During examinations, MSBs must provide documents, records, and information when requested by FINTRAC, in the manner and timeframe specified.
Failure to do so is a serious violation because it impedes FINTRAC's supervisory mandate.
6. Failure to Keep Prescribed Records
Record-keeping is the backbone of AML compliance, and FINTRAC penalizes MSBs that:
- Keep inconsistent records
- Fail to retain documents for the required 5-year period
- Do not maintain transaction logs
- Do not document client identification steps
- Lack audit-ready paper trails
This violation indicates gaps in operational discipline—not just paperwork oversight.
Why This Case Matters for MSBs Across Canada
This penalty reinforces a pattern we have seen throughout 2024 and 2025:
Most MSB enforcement actions are not triggered by complex AML failures— they're triggered by missing fundamentals.
Compliance programs often fail because:
- Documentation is outdated
- Staff aren't trained
- Risk assessments are generic templates
- No one performs the two-year review
- Reporting processes are manual and error-prone
- Operational AML tasks fall behind business growth
FINTRAC continues to be clear:
An MSB can be small, but its compliance program cannot be.
Even micro-MSBs (single-location currency exchanges, family-run businesses, small remittance companies) are held to the same PCMLTFA standards as national institutions.
Closing Thoughts
The $70,537.50 penalty against Global Currency Exchange is a reminder that FINTRAC is increasingly focused on foundational AML failures. These penalties are avoidable—if MSBs implement a structured, documented, well-maintained compliance program.
If your MSB needs help ensuring timely, accurate, audit-ready reporting, Comply+ offers automated FINTRAC reporting with AI-powered risk assessment tools designed specifically for MSBs and other PCMLTFA reporting entities.
Disclaimer:
This article is provided for general informational purposes only and reflects our interpretation and opinions based on publicly available information at the time of writing. It does not constitute legal advice, financial advice, regulatory guidance, or a substitute for professional counsel. Reporting entities and businesses subject to FINTRAC obligations should consult qualified legal and compliance advisors before making decisions relating to FINTRAC, AML obligations, or compliance requirements.
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