Money Laundering Detection Regimes Credit Unions in Canada
Author: Christ Randle, CAMS-Audit
In order to assess the state of the current money laundering detection regimes at credit unions, surveys were sent to managers responsible for the execution of these regimes at several credit unions across Canada. Through the survey responses received, this paper has documented that the credit union industry as a whole is facing a high risk of noncompliance against their obligations to detect and therefore report suspicious transactions. The response, being the provision of guidance relative to the development, execution and maintenance of an effective money laundering detection regime, will mitigate this risk and strengthen the overall AML regime in Canada.
The obligations of credit unions to detect suspicious transactions are several and challenging; the penalties for failure are severe to catastrophic. This proposed detection regime implies significant changes to the nature and level of the human and technological resources required to develop, execute and maintain such a regime. Only by being prepared to respond to each and all of these potential challenges, can those responsible for the credit union’s AML operations offer reasonable assurance to the credit union, its board of directors, employees, members and communities that their regulatory obligations are met and their social contract upheld.