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Administrative monetary penalty imposed on 857132 Ontario Limited

From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)

[2023-08-24]

857132 Ontario Limited, also operating as Diamonds For Less, a dealer in precious metals and precious stones in Toronto, Ontario was imposed an administrative monetary penalty of $99,314 on June 1, 2023, for committing 5 violations. The violations were found during the course of a compliance examination in 2021. The case is closed.

Nature of violation

Violation #1

Failure to submit a large cash transaction record in respect of every amount in cash of $10,000 or more that is received from a client in the course of a single transaction – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 39(2)

857132 Ontario Limited failed to submit a large cash transaction report for the receipt of $10,000 or more in cash.

Violation #2

Failure to appoint a person to be responsible for the implementation of a compliance program – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 71(1)(a)

857132 Ontario Limited did not ensure that the appointed person was responsible for implementing a compliance program.

Violation #3

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 71(1)(b)

857132 Ontario Limited failed to develop written compliance policies and procedures.

Violation #4

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 71(1)(c)

857132 Ontario Limited failed to assess and document the money laundering or terrorist activity financing risks.

Violation #5

Failure to develop and maintain a written ongoing compliance training program – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 71(1)(d)

857132 Ontario Limited failed to develop and maintain a written ongoing compliance training program.

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