Administrative monetary penalty on DMCL Chartered Professional Accountants
[2025-10-09]
DMCL Chartered Professional Accountants, also operating as DMCL, an accounting firm with locations in Vancouver, Surrey, Port Coquitlam and Victoria, British Columbia, was imposed an administrative monetary penalty of $72,750 on July 25, 2025, for committing 3 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 DMCL did not adequately develop and apply written compliance policies and procedures that are kept up to date and approved by a senior officer at the time of the examination. Specifically, the requirements relating to politically exposed persons and heads of international organizations determinations and ministerial directive requirements were absent from DMCL’s policies and procedures.
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 of a money laundering offence or a terrorist activity financing offence in the course of its activities, taking into consideration the prescribed factors – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9.6(2) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(c) and subsection 156(2).
FINTRAC determined that DMCL failed to assess and document the money laundering and terrorist financing risks related to products, services and delivery channels, geographic locations, clientele and business relationships, new developments and new technologies, and any other relevant factors. Specifically, the risk assessment documentation reviewed by FINTRAC during the examination did not contain DMCL’s money laundering or terrorist financing risks for these prescribed factors, as it only identified some of the risks associated with the products and services that DMCL offers to its clients.
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 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 determined that DMCL did not complete a documented review of its compliance program for the purpose of testing the effectiveness of its policies and procedures, risk assessment, and training program, within the prescribed two-year limit. During the examination, FINTRAC determined that four years had elapsed between DMCL’s review in 2019 and its 2023 review. Additionally, FINTRAC noted that DMCL’s 2023 review documentation lacked sufficient detail to explain how the entity conducts its review, how it tests the effectiveness of each component of its compliance program, how the results of its review are documented and if any deficiencies are found, how they are addressed.
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.
Related link
- Date Modified: