Administrative monetary penalty on Jones Lang Lasalle Real Estate Services, Inc.
From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
[2024-10-29]
Jones Lang Lasalle Real Estate Services, Inc., also operating as JLL, a real estate broker in Toronto, Ontario, was imposed an administrative monetary penalty of $107,827.50 on March 13, 2024, for committing 6 violations. The violations were found during the course of a compliance examination in 2022. The administrative monetary penalty has been paid in full and proceedings have ended.
Nature of violation
- Violation #1
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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
Jones Lang Lasalle Real Estate Services, Inc. did not document and implement certain procedures related to its obligations, such as client identification, third party determination, ongoing monitoring of business relationships and ministerial directive requirements. - Violation #2
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Failure to assess and document the risk of a money laundering or terrorist financing offence, taking into consideration prescribed factors – paragraph 71(1)(c) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations
Jones Lang Lasalle Real Estate Services, Inc.’s money laundering and terrorist financing risk assessment was incomplete, as it did not sufficiently consider prescribed risk factors such as products and delivery channels, geographic location, its clients and business relationships, and new technologies. The assessment utilized a generic checklist and categorized the overall risk level as “low” without providing sufficient rationale for the determination. - Violation #3
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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 – paragraph 71(1)(d) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations
Jones Lang Lasalle Real Estate Services, Inc.’s training program documentation was incomplete because it did not address certain requirements, such as business relationships and ongoing monitoring, and reporting obligations connected to terrorist property and suspicious transactions. Furthermore, the training program did not include a detailed plan for the delivery of the training to agents and employees. Finally, the training program was not up to date, having not received necessary revisions for several years. - Violation #4
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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
Jones Lang Lasalle Real Estate Services, Inc. did not conduct the prescribed two-year review to test the effectiveness of its policies and procedures, risk assessment, and training program. - Violation #5
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Failure to keep prescribed records – subsection 39(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations
In 40 instances, Jones Lang Lasalle Real Estate Services, Inc. failed to keep adequate records related to clients and receipts of funds by either omitting to keep the record entirely or omitting to include in those records required information such as the number of the account affected by the transaction, the account type, the date of birth and the nature of the principal business or occupation of the client. - Violation #6
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Failure to keep prescribed information when required to verify a person’s identity – section 64.2 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations
In 14 instances, Jones Lang Lasalle Real Estate Services, Inc. did not keep adequate records when required to verify the identity of a person who provided funds for a real estate transaction, omitting information such as the type of document used to identify the person, document number, the province or state, country or jurisdiction that issued the document, and the expiry date.
Related link
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