Administrative monetary penalty on Manor Windsor Realty Ltd.
[2026-02-12]
Manor Windsor Realty Ltd., a real estate brokerage in Windsor, Ontario, was imposed an administrative monetary penalty of $107,250 on November 27, 2025, for committing 4 violations. The violations were found during the course of a compliance examination. Manor Windsor Realty Ltd. 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)
FINTRAC determined that Manor Windsor Realty Ltd.’s policies and procedures were not complete and adequate as regulatory requirements were not documented and/or applied in its operations. The documentation Manor Windsor Realty Ltd. 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 information regarding ministerial directives and failed to outline the brokerage-specific measures on how it will comply with the requirements.
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 Manor Windsor Realty Ltd.’s risk assessment was not complete as it did not adequately document its money laundering or terrorist activity financing risks in the course of its activities specific to its business. The risk assessment failed to take into consideration the following prescribed factors: products and delivery channels; the geographic locations of its activities; clients and business relationships; and any other relevant factor.
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 Manor Windsor Realty Ltd.’s training program was incomplete as the training material was missing key regulatory requirements. In addition, Manor Windsor Realty Ltd. failed to provide records of training delivered to its employees to demonstrate the delivery of any training. Manor Windsor Realty Ltd. also failed to document a plan for its ongoing compliance training program and its delivery addressing the timing and frequency of training delivery, the recipients of the training, the training topics and material, and methods of delivery.
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 Manor Windsor Realty Ltd. failed to institute and document the prescribed review of its compliance program to assess the effectiveness of its policies and procedures, risk assessment, and training program.
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
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