FINTRAC for Banks, Credit Unions and Trust Companies
Six duties on every account, the penalty scale since 26 March 2026, and what FINTRAC cited in penalties on 13 banks and credit unions.
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If you take deposits in Canada, FINTRAC treats you as a financial entity
FINTRAC has published penalties on 13 banks and credit unions since January 2023, four of them on 24 September 2026. Nine had failed to report suspicious transactions. The penalty scale rose up to 40 times on 26 March 2026.
What you owe
Six duties run on every account, and the high-risk ones carry the most weight
Know every account holder before the account is used
Verify identity before the first transaction after the opening deposit. Confirm who owns a business client. Check for politically exposed persons at opening, periodically, and on international transfers of $100,000 or more.
Rate every client, then act on the high ones
Document each client's risk, monitor to match it, and apply enhanced measures to every high-risk client. Caisse Alliance, penalised in September 2026, is the latest cited for it.
Three reports, three clocks
A suspicious transaction report (STR) as soon as practicable, at any amount. A large cash report within 15 calendar days for $10,000 or more. An electronic funds transfer report within five business days for international transfers of $10,000 or more.
Sign off every correspondent bank
Before serving a foreign bank, confirm it is not a shell bank, get senior management approval and set out each side's obligations in writing.
Russia, Iran and North Korea: any amount
Every transaction from or to these countries is high risk, whatever the amount. Iran transactions are also reported to FINTRAC below the usual $10,000 thresholds.
Since 26 March 2026, the program has to work
The program must now be reasonably designed, risk-based and effective, and some program failures are now very serious violations.
What it costs
Nine of 13 penalised institutions missed a suspicious transaction report All four credit unions added on 24 September 2026 had out-of-date policies.
Maximum per violation under the AMP Regulations. Previous maximums from FINTRAC's penalty policy. An unreported suspicious transaction is a very serious violation.
Bank and credit union penalties
Also missed suspicious transaction reports: Synergy Credit Union, $214,500 (Nov 2025); First Nations Bank, $601,139.80 (Oct 2025); Cambrian Credit Union, $116,160 (Jun 2025); RBC, $7,475,000 and CIBC, $1,329,150 (Dec 2023); Wealth One Bank, $676,500 (Mar 2023). Policy gaps only: Pathwise Credit Union, $41,250, and Your Neighbourhood Credit Union, $16,500 (Sep 2026). Dates are FINTRAC publication dates.
How ComplyFactor helps
A second set of eyes on the files FINTRAC reads first We work alongside your compliance officer and leave the evidence an examiner asks for.
Suspicious transaction review
A second look at alerts closed without a report, and STR narratives that set out the grounds for suspicion.
High-risk client files
Risk ratings checked against the file, and enhanced measures and monitoring recorded for every client rated high.
Policies kept current
Matched to how your branches and digital channels run, kept current and approved by a senior officer.
Cash and transfer reporting
Large cash and international transfer reports, complete and on time, including incoming transfers and the 24-hour rule.
Onboarding and ownership reviews
Identity, beneficial ownership and politically exposed person files for personal and business accounts.
Two-year effectiveness review
An independent review against the effective standard in force since 26 March 2026.
Start with a suspicious transaction look-back
We sample alerts your team closed without a report and tell you how many should have been filed, before an examiner counts them for you.
contact@complyfactor.com · +1 807 806 0444
Sources: FINTRAC public notices of administrative monetary penalties, January 2023 to September 2026; PCMLTFA Administrative Monetary Penalties Regulations, s. 5; FINTRAC penalty policy; FINTRAC financial entity guidance, ministerial directives and changes page. ComplyFactor Banking and Financial Entities Leave-Behind, current to 24 September 2026.
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