FINTRAC imposes an administrative monetary penalty on Taiwanese Canadian Toronto Credit Union Limited
Taiwanese Canadian Toronto Credit Union Limited, a credit union in Markham, Ontario, was imposed an administrative monetary penalty of $297,000 on November 1, 2021, for committing four violations. The violations were found during the course of a compliance examination in 2019. Taiwanese-Canadian Toronto Credit Union Limited has appealed the decision to the Federal Court.
Violation #1 – Failure to report suspicious transactions – PCMLTFA 7
Taiwanese Canadian Toronto Credit Union Limited failed to submit suspicious transaction reports where there were reasonable grounds to suspect that transactions were related to a money laundering or a terrorist financing offence.
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 – PCMLTF Regulations 71(1)(b)
Taiwanese Canadian Toronto Credit Union Limited’s compliance policies and procedures did not sufficiently cover the requirements related to client identification, beneficial ownership, domestic politically exposed persons and heads of international organizations, and ongoing monitoring of business relationships.
Violation #3 – Failure to assess and document the risk of a money laundering or terrorist financing offence, taking into consideration prescribed factors – PCMLTF Regulations 71(1)(c)
Taiwanese Canadian Toronto Credit Union Limited’s risk assessment did not fully consider the money laundering or terrorist activity financing risk of its products and delivery channels, as well as its clients and business relationships.
Violation #4 – Failure to institute and document the prescribed review – PCMLTF Regulations 71(1)(e)
Taiwanese Canadian Toronto Credit Union Limited’s prescribed review did not assess the completeness and effectiveness of its policies and procedures, and the effectiveness of its risk assessment.
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