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FINTRAC imposes an administrative monetary penalty on Forest Hill Real Estate Inc.

[2022-03-22]

Forest Hill Real Estate Inc., a real estate broker in Toronto, Ontario, was imposed an administrative monetary penalty of $22,770 on October 28, 2021 for committing four violations. The violations were found during the course of a compliance examination in 2019. The case is closed.

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)

Forest Hill Real Estate Inc. failed to develop complete compliance policies and procedures related to the ongoing monitoring of business relationships.


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)

Forest Hill Real Estate Inc. failed to assess and document the money laundering or terrorist activity financing (ML/TF) risks of its geographic locations, products and delivery channels, and clients and business relationships.


Violation #3 – Failure to keep prescribed records – PCMLTF Regulations 39(1)(a), and 39(1)(c)

Forest Hill Real Estate Inc. failed to keep prescribed information in receipt of funds records, and failed to keep copies of corporate records.


Violation #4 – Failure to keep prescribed identification information – PCMLTF Regulations 64.2

Forest Hill Real Estate Inc. failed to keep identification information of individuals conducting a transaction on behalf an entity.

Date Modified: