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FINTRAC imposes an administrative monetary penalty on Montecristo Jewellers Inc.


Montecristo Jewellers Inc., a dealer precious metals and precious stones in Vancouver, British Columbia, was imposed an administrative monetary penalty of $222,750 on February 17, 2022, for committing four violations. The violations were found during the course of a compliance examination in 2019. Montecristo Jewellers Inc. has appealed the decision to the Federal Court.

Nature of Violation

Violation #1 – Failure to report suspicious transactions – PCMLTFA 7

Montecristo Jewellers Inc. failed to submit a suspicious transaction report where there was reasonable grounds to suspect that transactions were related to a money laundering offence.

Violation #2 – 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)

Montecristo Jewellers Inc.'s compliance policies and procedures did not sufficiently cover the requirements related to business relationships and the ongoing monitoring of business relationships.

Violation #3 – 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)

Montecristo Jewellers Inc.'s risk assessment did not fully consider the money laundering or terrorist activity financing risk of its geographic locations and its clients and business relationships.

Violation #4 – Failure to develop and maintain a written ongoing compliance training program – PCMLTF Regulations 71(1)(d)

Montecristo Jewellers Inc.'s written ongoing compliance training program did not ensure employees had an adequate understanding of requirements for suspicious transaction reports.

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