Administrative monetary penalty imposed on The Centre Pacific Project Marketing Corp.
From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
[2023-08-10]
The Centre Pacific Project Marketing Corp., a real estate broker in Vancouver, British Columbia, was imposed an administrative monetary penalty of $57,915 on May 23, 2023, for committing 6 violations. The violations were found during the course of a compliance examination in 2019. The case is closed.
Nature of violation
- Violation #1
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Failure of a person or entity to appoint a person to be responsible for the implementation of a compliance program – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 71(1)(a)
The Centre Pacific Project Marketing Corp. failed to ensure that an appointed person was responsible for implementing a compliance program. - Violation #2
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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 – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 71(1)(b)
The Centre Pacific Project Marketing Corp. did not sufficiently develop and apply compliance policies and procedures for its regulatory obligations relating to suspicious transaction reporting (STR), terrorist property reporting (TPR), record keeping, verifying client identity, third party determination, as well as ongoing monitoring of all business relationships. - Violation #3
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Failure to assess and document the risk of a money laundering or terrorist financing offence, taking into consideration prescribed factors – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 71(1)(c)
The Centre Pacific Project Marketing Corp. failed to assess and document the money laundering or terrorist activity financing (ML/TF) risks of its geographic locations, its new technologies, products and delivery channels, and clients and business relationships. - Violation #4
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Failure of a person or entity that has employees, agents or mandataries or other persons authorized to act on their behalf to develop and maintain a written ongoing compliance training program for those employees, agents or mandataries or persons – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 71(1)(d)
The Centre Pacific Project Marketing Corp. failed to develop and maintain a written ongoing compliance training program. - Violation #5
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Failure to institute and document the prescribed review – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 71(1)(e)
The Centre Pacific Project Marketing Corp. failed to institute and document the prescribed review of its policies and procedures, risk assessment and training program. - Violation #6
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Failure to keep prescribed records – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 39(1)(b)
The Centre Pacific Project Marketing Corp. failed to keep prescribed records in respect of client information records.
Related link
- Date Modified: