Administrative monetary penalty on Immeubles Village Pointe-Claire Inc.
From: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
[2025-05-06]
Immeubles Village Pointe-Claire Inc., a real estate broker in Pointe-Claire, Quebec, also operating as Royal LePage Village Pointe-Claire and Royal LePage Village, was imposed an administrative monetary penalty of $36,360 on July 17, 2024, for committing 4 violations. The violations were found during the course of a compliance examination in March 2022. Immeubles Village Pointe-Claire Inc. will pay the administrative monetary penalty 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 – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 71(1)(b)
Immeubles Village Pointe-Claire Real Estate Inc. had not developed written policies and procedures with respect to applicable ministerial directives. Further, Immeubles Village Pointe-Claire Inc. had not applied written policies and procedures regarding requirements related to business relationships, the ongoing monitoring of these business relationships, and the determination of third parties. A review of customer files revealed shortcomings in the documentation of measures taken for, and the information obtained through, the ongoing monitoring of Immeubles Village Pointe-Claire Inc.’s business relationships.
- Violation #2
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Failure to develop and maintain a written ongoing compliance training program – Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 71(1)(d)
Immeubles Village Pointe-Claire Inc. had not developed or documented a training program.
- Violation #3
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Failure to keep records of information used to verify customer’s identity – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, section 6 and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, section 64.2
In 4 instances, Immeubles Village Pointe-Claire Inc. did not retain documents related to the identity of individuals conducting real estate transactions.
- Violation #4
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Failure to keep records of information used to verify customer’s identity – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, section 6 and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, subsection 65(4)
In 6 instances, Immeubles Village Pointe-Claire Inc. did not retain the paper copy of the document used to verify the existence of a corporate identity.
Related link
- Date Modified: