Administrative monetary penalty on Griffin Jewellery Designs Inc.
[2025-12-04]
Griffin Jewellery Designs Inc., a full-service jewellery retailer with 21 locations across Ontario, Nova Scotia and New Brunswick, was imposed an administrative monetary penalty of $77,137.50 on October 17, 2025, for committing 3 violations. The violations were found during the course of a compliance examination. Griffin Jewellery Designs Inc. is paying the administrative monetary penalty 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 Griffin Jewellery Designs Inc.’s policies and procedures were incomplete, as most of the key regulatory requirements were not documented or applied in practice. The documentation Griffin Jewellery Designs Inc. provided did not address or include all the client identification, record keeping, or reporting requirements applicable to its business. Further, the documentation did not include any information regarding ministerial directives and how Griffin Jewellery Designs Inc. complies with the requirement.
Violation #1 is classified by the regulations as a Serious violation. The imposed penalty considers 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, taking into consideration 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)
FINTRAC determined that Griffin Jewellery Designs Inc.’s risk assessment was incomplete. Griffin Jewellery Designs Inc. failed to fully assess its money laundering or terrorist activity financing risks in the course of its activities specific to its business, taking into consideration the prescribed factors: products, services and delivery channels; the geographic locations of its activities; and clients and business relationships.
Violation #2 is classified by the regulations as a Serious violation. The imposed penalty considers 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)
FINTRAC determined that Griffin Jewellery Designs Inc. had not conducted a review of its compliance program to assess the effectiveness of its policies and procedures, risk assessment, and training program. This was confirmed by Griffin Jewellery Designs Inc. during the examination.
Violation #3 is classified by the regulations as a Serious violation. The imposed penalty considers 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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