Administrative monetary penalty imposed on Global West Realty Limited
From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
[2024-01-17]
Global West Realty Limited, also operating as Global West Realty Limited Brokerage, a real estate broker in Mississauga, Ontario was imposed an administrative monetary penalty of $132,000 on August 18, 2023. The violations were found during the course of a compliance examination in 2021. Global West Realty Limited has appealed the decision to the Federal Court.
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 – paragraph 71(1)(a) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations
Global West Realty Limited did appoint an individual as its compliance officer; however, the individual did not take any steps to implement a compliance program. For example, Global West Realty Limited did not have any documentation of its policies and procedures, risk assessment, written training program, or review of its 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 – paragraph 71(1)(b) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations
Global West Realty Limited had not developed and applied written compliance policies and procedures. - Violation #3
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Failure to assess and document the risk of a money laundering or terrorist activity financing (ML/TF) offence, taking into consideration prescribed factors – paragraph 71(1)(c) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations
Global West Realty Limited failed to assess and document money laundering or terrorist activity financing risks. - Violation #4
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Failure to develop and maintain a written ongoing compliance training program – paragraph 71(1)(d) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations
Global West Realty Limited 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 – paragraph 71(1)(e) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations
Global West Realty Limited failed to institute and document the prescribed review of its policies and procedures, risk assessment and training program.
Related link
- Date Modified: