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FINTRAC imposes an administrative monetary penalty on Magasin Château D'Ivoire Inc.

2021-05-19 ]

Magasin Château D'Ivoire Inc., also operating as Château D'Ivoire, a dealer in precious metals and stones in Montréal, Quebec, was imposed an administrative monetary penalty of $206,910 on March 1, 2021, for committing five violations. The violations were found during the course of a compliance examination in 2019. Magasin Château D'Ivoire Inc. has appealed the decision to the Federal Court.

Nature of violation

Violation #1 – 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 – PCMLTF Regulations 71(1)(b)

Magasin Château D'Ivoire Inc.'s policies and procedures did not cover the requirements relating to record-keeping and ongoing monitoring of business relationships, as well as procedures relating to the reporting of terrorist property.

Violation #2 – Failure to assess and document the risk of a money laundering or terrorist financing offence, taking into consideration prescribed factors – PCMLTF Regulations 71(1)(c)

Magasin Château D'Ivoire Inc. failed to assess and document the money laundering or terrorist activity financing (ML/TF) risk of its geographic locations, products and delivery channels, and clients and business relationships.

Violation #3 – Failure of a person or entity that has employees, agents or mandataries or other persons authorized to act on their behalf to develop and maintain a written ongoing compliance training program for those employees, agents or mandataries or persons – PCMLTF Regulations 71(1)(d)

Magasin Château D'Ivoire Inc.'s written compliance training program did not cover training on its policies and procedures, the frequency and timing of the training, and how it would be maintained on an ongoing basis.

Violation #4 – Failure to report the receipt from a client of an amount of $10,000 or more in the course of a single transaction – PCMLTF Regulations 39.2

Magasin Château D'Ivoire Inc. failed to submit large cash transaction reports for the receipt of $10,000 or more in cash.

Violation #5 – Failure to report suspicious transactions – PCMLTFA 7

Magasin Château D'Ivoire Inc. failed to submit a suspicious transaction report where there were reasonable grounds to suspect that transactions were related to a money laundering offence.

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