Administrative monetary penalty on HRA Group Holdings
[2025-10-02]
HRA Group Holdings, also operating as HRA Group, a dealer in precious metals and stones headquartered in Vancouver, British Columbia, was imposed an administrative monetary penalty of $132,000 on June 2, 2025, for committing 4 violations. The violations were found during the course of a compliance examination. The administrative monetary penalty has been paid in full and the case is closed.
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 Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(b)
FINTRAC determined that HRA Group Holdings’ policies and procedures were inadequate, as most of the requirements were not developed or applied. The documentation HRA Group Holdings provided did not address or include all of the client identification, record keeping, or reporting requirements applicable to its business. Further, the documentation included no organizational anti-money laundering or anti-terrorist financing polices or procedures that were specific to HRA Group Holdings, or that could explain how HRA Group Holdings complied with the requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations.
Violation #1 is classified by the regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.
- Violation #2
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Failure to assess and document the risk referred to in subsection 9.6(2) of the Act, taking into consideration prescribed factors – 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)(c)
FINTRAC determined that HRA Group Holdings had not assessed or documented its money laundering or terrorist activity financing risks in the course of its activities, taking into consideration the prescribed factors: products, services and delivery channels; the geographic locations of its activities; clients and business relationships; and any other relevant factor. This finding was confirmed by HRA Group Holdings during the examination.
Violation #2 is classified by the regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.
- Violation #3
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Failure to develop and maintain a written, ongoing compliance training program – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraphs 156(1)(d) and paragraph 156(1)(e)
FINTRAC determined that HRA Group Holdings did not document and provide a formal compliance training program for its employees, nor did it document a plan for its ongoing compliance training program and its delivery. FINTRAC did not receive any training documentation from HRA Group Holdings during the examination.
Violation #3 is classified by the regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.
- Violation #4
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Failure 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)
FINTRAC determined that HRA Group Holdings had not conducted a review of its compliance program to assess the effectiveness of its policies and procedures, risk assessment, and training program. This finding was confirmed by HRA Group Holdings during the examination.
Violation #4 is classified by the regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.
Related link
- Date Modified: