FINTRAC imposes an administrative monetary penalty on HomeLife Glenayre Realty Chilliwack Ltd.

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)

HomeLife Glenayre Realty Chilliwack Ltd.’s policies and procedures did not sufficiently address the requirements for reporting suspicious transactions and terrorist property, as well as client identification and record keeping.

---

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)

HomeLife Glenayre Realty Chilliwack Ltd.’s risk assessment did not consider its geographic location, products and delivery channels, clients and business relationships, and new technologies.

---

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)

HomeLife Glenayre Realty Chilliwack Ltd.’s training program did not include the frequency, delivery methods and how training would be maintained on an ongoing basis.

---

Violation #4 – Failure to institute and document the prescribed review – PCMLTF Regulations 71(1)(e)

HomeLife Glenayre Realty Chilliwack Ltd. failed to institute and document a review, every two years, to assess the effectiveness of its policies and procedures, risk assessment and training program.

---

Violation #5 – Failure to keep prescribed records – PCMLTF Regulations 39(1)(b) and 39(1)(c)

HomeLife Glenayre Realty Chilliwack Ltd. failed to keep all the prescribed information in client information records.