Administrative monetary penalty on 9321-0599 Québec Inc.
[2025-11-20]
9321-0599 Québec Inc., also operating as Les Immeubles Star / Star Realty, a real estate brokerage in Brossard, Québec, was imposed an administrative monetary penalty of $23,100 on July 2, 2025, for committing 2 violations. The violations were found during the course of a compliance examination. Les Immeubles Star / Star Realty has appealed the decision to the Federal Court.
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)
Les Immeubles Star / Star Realty’s policies and procedures were incomplete, as documentation for the following prescribed requirements was absent: beneficial ownership, ministerial directives and transactions restrictions, politically exposed persons and heads of international organizations, and terrorist property reports.
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 of a person or entity 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 Les Immeubles Star / Star Realty failed to adequately document the money laundering and terrorist financing risks for the following prescribed factors: clients and business relationships, products, services and delivery channels, the geographic location of its activities, and any other relevant factor. Les Immeubles Star / Star Realty’s risk assessment was a two-page document that listed questions for assessing the risks related to money laundering and terrorist financing for its business operations, but the document was undated, and all questions were left unanswered.
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.
Related link
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