The Financial Transactions and Reports Analysis Centre of Canada, or FINTRAC, imposed an administrative monetary penalty of $67,150 on Juba Express Inc., a Toronto-based money services business. This penalty, levied on August 29, 2025, resulted from a compliance examination that uncovered multiple violations of Part 1 of the Proceeds of Crime, Money Laundering, and Terrorist Financing Act and its associated Regulations. The violations primarily involved fundamental failures in the entity’s anti-money laundering and counter-terrorist financing, or AML/CTF, compliance program, including critical shortcomings in risk assessment and transaction reporting duties. The enforcement action underscores the regulator’s commitment to ensuring that all reporting entities, particularly those in the high-risk money services sector, adhere strictly to the compliance regime designed to protect Canada’s economy from illicit financial activity. This case serves as a sharp reminder that compliance obligations are non-negotiable and that comprehensive, up-to-date AML controls are essential for businesses operating in the financial landscape.

Mandatory Compliance Program Elements and Penalties

The Proceeds of Crime, Money Laundering, and Terrorist Financing Act mandates that all reporting entities, including money services businesses like Juba Express Inc., establish and maintain a rigorous and effective anti-money laundering compliance program. This program must be comprehensive, documented, and regularly updated to reflect the business’s current operations and risks. A core element of this requirement is the development and application of written compliance policies and procedures approved by a senior officer, which was one of the areas where Juba Express Inc. was found deficient. Without well-defined policies, a business lacks the necessary framework to guide employees on record keeping, client identification, and mandatory reporting, leaving it vulnerable to exploitation by criminal elements seeking to launder illicit proceeds. The failure to have such foundational controls constitutes a serious violation, directly undermining the purpose of the Canadian AML/CTF regime.

Another critical pillar of the compliance program that was breached relates to risk assessment. The Act requires that reporting entities assess and document the risk of a money laundering or terrorist financing offence, considering prescribed factors specific to their activities, customers, products, and geographic locations. This assessment is the bedrock upon which the entire compliance program is built, determining the level of due diligence and monitoring required. FINTRAC determined that Juba Express Inc. failed to properly execute this foundational duty, indicating a significant blind spot regarding the potential money laundering and terrorist financing vulnerabilities inherent in its operations. A flawed or absent risk assessment prevents a money services business from tailoring its mitigation measures effectively, creating an environment where high-risk transactions may go undetected or inadequately scrutinized. These lapses in establishing a foundational and tailored risk-based approach represent a systemic failure in the first line of defense against financial crime.

The regulatory framework is designed to detect and deter the three primary stages of money laundering—placement, layering, and integration—by requiring reporting entities to maintain an audit trail and file reports on specific types of transactions. Placement involves introducing illegal funds into the financial system, often in large cash amounts. Layering is the process of obscuring the source of the money through complex transactions. Integration is the stage where the funds re-enter the legitimate economy. Money services businesses, especially those handling remittances and electronic funds transfers, are highly susceptible to being exploited during the placement and layering phases, making their reporting obligations exceptionally important.

The Failure of Mandatory Transaction Reporting

A substantial part of the compliance failure in the Juba Express Inc. case involved non-compliance with mandatory reporting requirements, which are instrumental for FINTRAC to generate and disseminate financial intelligence. Reporting entities must report certain high-value transactions to the financial intelligence unit in near real-time, providing law enforcement and national security agencies with the actionable intelligence needed for their investigations. The Toronto-based money services business was cited for failing to submit both Electronic Funds Transfer Reports, or EFTRs, and Large Cash Transaction Reports, or LCTRs, for transactions exceeding the $10,000 threshold. Electronic funds transfers, whether incoming or outgoing, that total $10,000 or more in the course of a single transaction must be reported, along with prescribed information, as they are a key channel for moving funds across borders in the layering stage of money laundering. Similarly, large cash transactions of $10,000 or more, essential for the placement stage, also require mandatory reporting.

The deliberate or negligent failure to submit these reports obstructs the flow of vital information to FINTRAC, severely limiting its ability to piece together patterns of suspicious activity that may indicate money laundering or terrorist financing schemes. When an entity consistently misses these reporting thresholds, it suggests a systemic breakdown in the firm’s day-to-day transaction monitoring and record-keeping systems. In the context of a money services business that facilitates the rapid and cross-border movement of funds, the lack of timely and accurate EFTRs and LCTRs can create significant gaps in the national financial intelligence picture. This non-compliance is not merely an administrative oversight; it is a critical vulnerability that can be directly leveraged by criminals to move proceeds of crime through the formal financial system undetected. The integrity of the entire Canadian AML/CTF framework hinges on the reliability and completeness of reporting from businesses like Juba Express Inc., making these violations particularly serious.

Beyond the reporting failures, the money services business also failed to submit a notification of change to its registration information with FINTRAC. All money services businesses are required to register with FINTRAC and ensure that their registration information is kept current. Changes to the business’s structure, services, or ownership must be promptly communicated to the regulator. This requirement exists to maintain transparency and ensure that FINTRAC can effectively supervise and communicate with the registered entity. Failing to update registration information creates an accountability gap, hindering the regulator’s oversight capabilities and preventing the regulator from accurately assessing who controls the business and what activities it undertakes. This seemingly administrative violation is tied to the broader issue of transparency and accountability within the regulated sector, which is fundamental to preventing money laundering.

Consequences of Compliance Failures for MSBs

The administrative monetary penalty levied on Juba Express Inc. is one of the tools FINTRAC uses to enforce compliance and encourage a change in non-compliant behaviour. The penalty amount of $67,150 is intended to be dissuasive and proportionate to the nature and scope of the violations, which in this case included multiple foundational failures in the anti-money laundering compliance regime. FINTRAC categorizes violations into different levels of seriousness, ranging from minor to very serious, with corresponding penalties. The violations found at Juba Express Inc., such as the lack of adequate compliance policies and the failure to assess risk, are typically classified as serious due to their potential to expose the financial system to significant money laundering risk.

For money services businesses, which inherently face a higher risk profile due to their services involving large volumes of cash or rapid international transfers, the regulatory expectation for robust AML controls is particularly high. The penalty sends a clear message to the sector that a passive or incomplete approach to compliance will incur tangible financial consequences. Beyond the immediate financial fine, non-compliance can lead to reputational damage, the imposition of compliance agreements, and in extreme cases, the revocation of registration, which would prevent the entity from legally operating. The regulatory focus is on ensuring that businesses do not simply have paper policies, but rather an operational and effective compliance program that is actively applied and monitored. The overall increase in the number and magnitude of penalties issued by FINTRAC in recent years, including the twenty-three Notices of Violation issued in 2024–25 for a total exceeding $25 million, highlights a national trend of intensified enforcement and a low tolerance for systemic compliance gaps across all regulated sectors.

Enhancing AML Defense and Future Outlook

The experience of Juba Express Inc. offers crucial lessons for all money services businesses regarding the minimum acceptable standards for their anti-money laundering defense. The violations illustrate that a failure in one area, such as a deficient risk assessment, often cascades into failures in other critical components, like transaction reporting and procedural documentation. To mitigate the risk of severe administrative monetary penalties, businesses must adopt a proactive and continuous compliance posture. This involves not only putting the required written policies in place but also rigorously training staff, implementing robust technological solutions for transaction monitoring and record keeping, and conducting regular internal and external audits to identify and fix compliance gaps.

Money services businesses must commit sufficient resources to ensure their compliance regimes are dynamic, adapting to evolving money laundering and terrorist financing typologies. This includes properly documenting all risk-based decisions, ensuring that electronic funds transfers and large cash transactions are accurately and timely reported, and maintaining a transparent and up-to-date registration status with the financial intelligence unit. FINTRAC’s consistent enforcement actions confirm that financial entities must view their AML obligations not as mere bureaucratic hurdles but as an essential defense mechanism for the integrity of the Canadian financial system and the security of its economy. The ongoing commitment to stringent enforcement by regulators aims to foster a culture of compliance where every entity understands its role in the collective fight against financial crime.

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Key Notes

• The administrative monetary penalty of $67,150 against Juba Express Inc. was imposed by FINTRAC for five separate violations of the Proceeds of Crime, Money Laundering, and Terrorist Financing Act.
• Key compliance failures included the failure to develop and apply updated written compliance policies and procedures and the failure to assess and document the risk of money laundering or terrorist financing effectively.
• The money services business failed to submit mandatory Electronic Funds Transfer Reports and Large Cash Transaction Reports for transactions exceeding the $10,000 threshold, hindering the creation of financial intelligence.
• Administrative penalties are a regulatory tool intended to enforce compliance and compel a change in non-compliant behavior within the financial services sector.
• This enforcement action against a money services business highlights the sector’s high vulnerability to being exploited for illicit financial activities, requiring robust and actively managed AML/CTF programs.

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Related Links

• The Proceeds of Crime, Money Laundering, and Terrorist Financing Act
• FINTRAC Guidance on Compliance Programs
• FINTRAC Guidance for Money Services Businesses
• FATF Recommendations on Money Laundering and Terrorist Financing
• FINTRAC Information on Administrative Monetary Penalties

Other FinCrime Central Articles About Crackdown on Money Business Services

• Canadian Crystal Currency Exchange Hit With FINTRAC Penalty
• FINTRAC Penalty Against MSBG International: A Warning for Money Services Businesses
• CBUAE Hits Exchange Houses with 4.1 Million Dirham Fines Over Money Laundering Failures

Source: FINTRAC

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