FINTRAC imposes an administrative monetary penalty on C&Z Holdings Ltd.

2021-03-04 ]

C&Z Holdings Ltd., also operating as Golden Apple, a money services business in Vancouver, British Columbia, was imposed an administrative monetary penalty of $101,969 on December 29, 2020 for committing nine 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 report the receipt from a client of an amount in cash of $10,000 or more in the course of a single transaction – PCMLTF Regulations 28(1)(a)

C&Z Holdings Ltd. failed to submit Large Cash Transaction Reports for the receipt of $10,000 or more in cash.

Violation #2 – Failure to report the sending out of Canada of an electronic funds transfer of $10,000 or more in the course of a single transaction, together with the prescribed information– PCMLTF Regulations 28(1)(b)

C&Z Holdings Ltd. failed to include in outgoing Electronic Funds Transfer Reports, information in the prescribed form and manner.

Violation #3 – 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)

C&Z Holdings Ltd. failed to develop and apply compliance policies and procedures related to reporting financial transactions, ongoing monitoring of business relationships, and politically exposed persons and heads of an international organization (HIO).

Violation #4 – 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)

C&Z Holdings Ltd. failed to assess and document the money laundering or terrorist activity financing (ML/TF) risks of its geographic locations, products and delivery channels, and clients and business relationships.

Violation #5 – Failure of a person or entity that has employees, agents or mandataries or other persons authorized to act on their behalf to develop and maintain a written ongoing compliance training program for those employees, agents or mandataries or persons – PCMLTF Regulations 71(1)(d)

C&Z Holdings Ltd. failed to maintain an ongoing training program.

Violation #6 – Failure to institute and document the prescribed review – PCMLTF Regulations 71(1)(e)

C&Z Holdings Ltd. failed to institute and document the prescribed review of its compliance policies and procedures, risk assessment and training program.

Violation #7 – Failure to keep prescribed records – PCMLTF Regulations 30(e)

C&Z Holdings Ltd. failed to keep prescribed information where an amount of $1,000 or more is remitted or transmitted.

Violation #8 – Failure to keep a record of the purpose and intended nature of a business relationship – PCMLTF Regulations 52.1

C&Z Holdings Ltd. failed to keep a record of the purpose and intended nature of business relationships.

Violation #9 – Failure to submit notification of change to MSB registration – PCMLTF Registration Regulations 4(b) and 5

C&Z Holdings Ltd. failed to notify FINTRAC of a change to MSB registration information.

Date Modified: