Administrative monetary penalty on MSBG International Holdings Ltd.
From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
[2025-02-25]
MSBG International Holdings Ltd., also operating as MTT Centre, a money services business in Vancouver, British Columbia, was imposed an administrative monetary penalty of $24,750 on December 19, 2024, for committing 1 violation. The violation was found during the course of a compliance examination in 2023. The administrative monetary penalty has been paid in full by MSBG International Holdings Ltd. and proceedings have ended.
MSBG was previously subject to FINTRAC examinations to ensure compliance with requirements set out in Parts 1 and 1.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and associated Regulations. On June 15, 2023, FINTRAC conducted its third compliance examination of MSBG, which uncovered non-compliance with their policies and procedures.
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 – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 71(1)(b)
FINTRAC determined that MSBG International Holdings Ltd.’s compliance policies and procedures do not comply with the requirements of paragraph 71(1)(b) of the Regulations. Overall, MSBG International Holdings Ltd. had incomplete policies and procedures.
Notably, FINTRAC confirmed that MSBG International Holdings Ltd. policies and procedures were incomplete, as they did not outline the process or steps involved in submitting financial transactions to FINTRAC. This gap was found for all financial transactions applicable to this entity, specifically:
- suspicious transactions reports
- large cash transaction reports
- electronic funds transfers
- terrorist property reports
Policies and procedures are critical in a compliance program as they set out and communicate important principles and standards that employees and delegated persons with compliance responsibilities must meet in a consistent manner. Documented policies and procedures also serve to ensure clarity and consistency in business operations. Failing to develop, apply, and keep written compliance policies and procedures up to date can result in not meeting other requirements set out in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) and associated Regulations, and undervalues sound business practices designed to minimize a business’ exposure to money laundering and terrorist activity financing. Partially documented policies and procedures potentially leave employees, or those acting on behalf of the business, unaware of the exact actions to take or appropriate decisions to make, in order to comply, when specific situations arise in practice.
In this case, violation #1 is classified by regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.
Related link
- Date Modified: