FINTRAC imposes an administrative monetary penalty on Cathay Pacific Realty Ltd.

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

Cathay Pacific Realty Ltd. failed to submit a suspicious transaction report where there were reasonable grounds to suspect that transactions were related to a money laundering offence.

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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)

Cathay Pacific Realty Ltd.’s policies and procedures did not sufficiently cover the requirements related to ongoing monitoring of business relationships and ministerial directives, or were not applied in practice for third party determination.

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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)

Cathay Pacific Realty Ltd. failed to assess and document the money laundering or terrorist activity financing risks of its geographic locations, products and delivery channels, and clients and business relationships.

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

Cathay Pacific Realty Ltd. failed to develop and maintain a written ongoing compliance training program.

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Violation #5 – Failure to institute and document the prescribed review – PCMLTF Regulations 71(1)(e)

Cathay Pacific Realty Ltd. failed to institute and document the prescribed review of its policies and procedures, risk assessment and training program.