FINTRAC imposes an administrative monetary penalty on Pan Pacific Platinum Real Estate Services Inc.
[2022-10-06]
Pan Pacific Platinum Real Estate Services Inc., also operating as LeHomes Realty, a real estate brokerage in Vancouver, British Columbia was imposed an administrative monetary penalty of $282,397.50 on March 28, 2022 for committing seven violations. The violations were found during the course of a compliance examination in 2019. Pan Pacific Platinum Real Estate Services Inc. has appealed the decision to the Federal Court.
Nature of Violation
Violation #1 – Failure to report suspicious transactions – PCMLTFA 7
Pan Pacific Platinum Real Estate Services Inc. failed to submit a suspicious transaction report when there were reasonable grounds to suspect that transactions were related to a money laundering offence.
Violation #2 – Failure of a person or entity to appoint a person to be responsible for the implementation of a compliance program – PCMLTF Regulations 71(1)(a)
Pan Pacific Platinum Real Estate Services Inc. 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 – PCMLTF Regulations 71(1)(b)
Pan Pacific Platinum Real Estate Services Inc. did not sufficiently develop and apply compliance policies and procedures for its regulatory obligations relating to third party determination, receipt of funds records and business relationships and ongoing monitoring.
Violation #4 – 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)
Pan Pacific Platinum Real Estate Services Inc.’s risk assessment did not take into consideration the money laundering or terrorist activity financing risk of its products and delivery channels, its geographic location or its clients and business relationships.
Violation #5 – Failure to develop and maintain a written ongoing compliance training program – PCMLTF Regulations 71(1)(d)
Pan Pacific Platinum Real Estate Services Inc.’s written ongoing compliance training program was not fully documented or delivered to its staff.
Violation #6 – Failure to institute and document the prescribed review – PCMLTF Regulations 71(1)(e)
Pan Pacific Platinum Real Estate Services Inc.’s failed to institute and document a review of its policies and procedures, its risk assessment and its training program for the purpose of testing their effectiveness.
Violation #7 – Failure to keep prescribed records – PCMLTF Regulations 39(1)(b)
Pan Pacific Platinum Real Estate Services Inc. did not keep complete client identification records.
- Date Modified: