Administrative monetary penalty on Immeubles Jack Sera, Inc.
From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
[2025-05-01]
Immeubles Jack Sera, Inc., a real estate broker in Laval, Quebec, was imposed an administrative monetary penalty of $107,250 on November 20, 2024, for committing 4 violations. The violations were found during the course of a compliance examination in July 2022. Immeubles Jack Sera Inc. has appealed the decision to the Federal Court.
Nature of violation
- Violation #1
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Failure of a person or entity 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 Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(b)
Immeubles Jack Sera's written policies and procedures were inadequate, resulting in 5 procedural gaps related to the following requirements:
- beneficial ownership
- third party determination
- politically exposed persons and heads of international organizations
- business relationships and ongoing monitoring
- ministerial directives and transaction restrictions
- Violation #2
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Failure of a person or entity to assess and document the risk referred to in subsection 9.6(2) of the Act, taking into consideration the prescribed factors – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(c) and subsection 156(2)
During the examination, FINTRAC determined that while Immeubles Jack Sera Inc. completed a generic risk assessment form, this documentation was inadequate as it did not take into consideration the prescribed factors, omitted to assign risk levels, and failed to define mitigation measures to reduce high-risk factors.
- Violation #3
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Failure of a person or entity to institute and document a plan for the ongoing compliance training program and deliver the training – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(e)
FINTRAC’s examination determined that Immeubles Jack Sera failed to institute and document a plan for an ongoing training program and its delivery.
- Violation #4
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Failure of a person or entity to institute and document the prescribed review – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(f) and subsection 156(3)
FINTRAC’s examination determined that Immeubles Jack Sera Inc. had not conducted a prescribed review every two years of its compliance program to assess the effectiveness of its policies, procedures, risk assessment and training program.
Related link
- Date Modified: