Public notice of administrative monetary penalties

2015-11-18 ]

Services Financiers C.M. Inc., also operating as Services Financiers CM, a money services business in Montréal, Québec, was imposed an administrative monetary penalty of $17,535 on July 27, 2015, for committing five violations related to the following deficiencies:

  • Incomplete written compliance policies and procedures;
  • Failure to assess and document the risks related to money laundering and terrorist financing;
  • Inadequate written ongoing compliance training program;
  • Failure to institute and document the prescribed review; and
  • Incomplete record keeping in respect of foreign exchange transaction tickets.

Nature of Violation

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 paragraph 71(1)(d) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of a person or entity to institute and document the prescribed review, which is contrary to subsection 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 71(1)(e) 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 paragraph 30(f) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Date Modified: