Public notice of administrative monetary penalties

2015-05-13 ]

9245-9205 Québec Inc., also operating as Bijouterie My Tan, a money services business in Montréal, Quebec, was imposed an administrative monetary penalty of $20,780 on May 7, 2015, for committing seven violations related to the following deficiencies:

  • Failure to report a large cash transaction;
  • Failure to develop and apply written compliance policies and procedures;
  • Failure to assess and document the risks related to money laundering and terrorist financing;
  • Failure to develop and maintain a written, ongoing compliance training program;
  • Incomplete and inadequate record keeping, including those related to ascertaining client identity; and
  • Failure to submit a notification of change to its money services business registration.

Nature of Violation

Failure of a money services business to report the receipt from a client of an amount in cash of $10,000 or more in the course of a single transaction, together with the prescribed information, which is contrary to subsection 9(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 28(1)(a) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of a person or entity 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 which is contrary to subsection 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 71(1)(b) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of a person or entity to assess and document the risk referred to in subsection 9.6(2) of the Act, taking into consideration prescribed factors, which is contrary to subsection 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 71(1)(c) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of a person or entity that has employees, agents or other persons authorized to act on their behalf to develop and maintain a written ongoing compliance training program for those employees, agents or persons which is contrary to subsection 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 71(1)(d) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of a money services business to keep prescribed records which is contrary to section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and subsection 30(f) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of a person or entity that is required to ascertain the identity of a person to set out prescribed information on the appropriate records in respect of the person which is contrary to section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 67 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of an applicant or a registered person or entity to submit a notification of a change to the information provided in a prescribed application in the prescribed manner and with the prescribed information which is contrary to section 11.13 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and subsection 4(b) and subsection 5 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Date Modified: