The LinkedIn post below by Michael Cosgrove is a good reminder that Canada has stepped
up its penalty regime under the Proceeds of Crime Money Laundering and Terrorist
Financing Act (PCMLTFA). As of March 26, 2026, the maximum fine has gone from
$500,000 to $20 million. This is still well below what the US Department of Justice levied in
2024 against TD Bank for its long running disregard for failing to monitor millions of
transactions in a number of its US branches. The fine was close to $2 billion.
This new level of penalty applies to all financial institutions including credit unions, which
Mr. Cosgrove highlights here. He even references the Credit Union AML Training Gap SelfAssessment that his financial crime compliance training company has put together to help credit unions close the gaps on any deficiencies which remain based on how they are
conducting their AML /fraud prevention employee training.
Certified Crypto Compliance Specialist | Building Culture Around Compliance | Equipping Your Team to Flag Financial Crime | Protecting Your Company’s Reputation
The maximum penalty for an AML violation in Canada just went from $500,000 to $20 million.
On March 26, 2026, the new administrative monetary penalty framework under the PCMLTFA came into force. Prescribed violations now carry up to $20M for entities. Violations of a compliance order can reach the greater of $30M or 3% of gross revenue. And credit unions are not watching this from the sidelines.
In September 2025, FINTRAC imposed a $214,500 penalty on a Canadian credit union. The violations: failing to report suspicious transactions, failing to assess and document ML/TF risk, failing to apply special measures where risk was high, and failing to keep written compliance policies current.
Read that list again.
Every one of those failures runs through a person. The member services rep who didn’t recognize the indicator. The analyst who saw it and didn’t escalate. The manager who approved a file nobody had documented.
That is a training outcome, not a policy outcome.
Your training program is one of the pillars of your compliance program — and your two-year effectiveness review has to test whether it actually works, not just whether people clicked through it.
So: when did you last test whether your AML training changed behaviour?
If you’re not certain, we built a free 15-question self-assessment for credit unions. Five minutes. Scored against what FINTRAC examiners actually look for. You get your gaps, named, with where to start.
Take it here: https://lnkd.in/gG499DxG
What’s the weakest link in your training program right now — content, frequency, or proof it worked?
#AML #FINTRAC #CreditUnions #PCMLTFA #Compliance
