The document has not been made available to the public, but according to sources with access, the fine was imposed for these defects:
(1) Failure to report an attempted or actual suspicious transaction.
(2) Failure to report receipt of CAD$10,000, in cash, or more, in a single transaction.
(3) Failure to report an electronic funds transfer of CAD$10,000, or more, to a destination outside Canada.
(4) Failure to report receipt, from outside Canada, of an electronic funds transfer of CAD$10,000 or more.
(5) Failure to apply written compliance policies and procedures, which must be kept up to date and approved by a senior bank officer
The exact amount of the fine was CAD$ 1,154,670 . To say that I am disappointed that FINTRAC has failed to disclose the name of the offending bank is an understatement. Many Canadian banks have US subsidiaries, branches, or agencies, as well as affiliates in the Caribbean, and both American & Caribbean bankers deserve to know that a bank they regularly deal with is not following banking best practices with regard to anti-money laundering policies and procedures.
If this is a genuine effort to avoid reputation damage by the offending bank, I am not impressed, for the protection of the banking public certainly comes before the reputation of a guilty bank, and before the pockets of its shareholders. Someone needs to convey that message to the leadership of FINTRAC.