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FINTRAC imposes an administrative monetary penalty on LaBoutique Realty Ltd.


LaBoutique Realty Ltd., also operating as LeHomes Realty First, a real estate brokerage in Vancouver, British Columbia was imposed an administrative monetary penalty of $275,385 on July 21, 2022 for committing seven violations. The violations were found during the course of a compliance examination in 2019. LaBoutique Realty Ltd. has appealed the decision to the Federal Court.

Nature of Violation

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

LaBoutique Realty Ltd. 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 to report the receipt from a client of an amount in cash of $10,000 or more in the course of single transaction – PCMLTF Regulations 38

LaBoutique Realty Ltd. failed to submit a large cash transaction report for the receipt of $10,000 or more in cash.

Violation #3 – 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)

LaBoutique Realty Ltd. did not ensure that the appointed person was responsible for implementing a compliance program.

Violation #4 – 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)

LaBoutique Realty Ltd. did not sufficiently develop and apply compliance policies and procedures for its regulatory obligations relating to record keeping, third party determination, business relationships and ongoing monitoring.

Violation #5 – 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)

LaBoutique Realty Ltd.’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 #6 – Failure to develop and maintain a written ongoing compliance training program – PCMLTF Regulations 71(1)(d)

LaBoutique Realty Ltd.’s written ongoing compliance training program was not fully documented or delivered to its staff.

Violation #7 – Failure to keep prescribed records – PCMLTF Regulations 39(1)(a) and 39(1)(b).

LaBoutique Realty Ltd. failed to record the type of funds received on a receipt of funds record and did not keep complete identification records.

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