Groupe Mackay Inc., a real estate broker in Lachine, Quebec, was imposed an administrative monetary penalty of $34,175 on January 14, 2016 for violating the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR).
Groupe Mackay Inc. was found to have the following deficiencies:
- Failure to develop and apply written compliance policies and procedures;
- Failure to assess and document the risks related to money laundering and terrorist financing;
- Inadequate written ongoing compliance training program; and
- Incomplete and inadequate record keeping of client information, including those related to ascertaining client identity.