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FINTRAC - administrative monetary penalties imposed


March saw publication of the first 2023 administrative monetary penalties ($676,500) from FINTRAC.

Identified was:

  • Failure 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 – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(b)

  • Failure to assess and document the risk of a money laundering or terrorist financing offence, taking into consideration prescribed factors – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(c)

  • Failure to institute and document the prescribed review – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(f)

  • Failure to report suspicious transactions – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, section 7

With this reminder, are you confident your AML/ATF program will withstand scrutiny?

Please reach out if you want to discuss further.


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