FINTRAC imposes an administrative monetary penalty on 9197-9195 Québec Inc.

2020-11-13 ]

9197-9195 Québec Inc., also operating as Apadana Forex, Bureau de change Apadana, Conseil investissement Apadana, and Consulting Investment Apadana, a money services business in Montréal, Quebec, was imposed an administrative monetary penalty of $206,250 on July 2, 2020 for committing three violations. The violations were found during the course of a compliance examination in 2018. The case is closed.

Nature of Violation

Violation #1 – 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 – PCMLTF Regulations 71(1)(b)

9197-9195 Québec Inc.’s compliance policies and procedures did not cover the requirements for reporting suspicious transactions and terrorist property, conducting ongoing monitoring of business relationships, determining third parties, and conducting due diligence with respect to politically exposed domestic persons, heads of international organizations, their family members and close associates.

Violation #2 – Failure to assess and document the risk of a money laundering or terrorist financing offence, taking into consideration prescribed factors – PCMLTF Regulations 71(1)(c)

9197-9195 Québec Inc. did not assess and document the money laundering or terrorist activity financing risks for the business’ geographic locations, products and delivery channels, and clients and business relationships.

Violation #3 – Failure to report suspicious transactions – PCMLTFA 7

9197-9195 Québec Inc. failed to submit a suspicious transaction report where there were reasonable grounds to suspect that transactions were related to a money laundering offence.

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