Administrative Monetary Penalties

Public notice of administrative monetary penalties

2010-09-22 ]

Sutlej Foreign Exchange Inc., engaged in the business of a money services business in Mississauga, Ontario, was issued a penalty of $ 8,450 on July 26, 2010, for committing six violations.

Nature of Violation

Failure of a person or entity 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, which is contrary to subsection 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 71(1)(b) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of a person or entity to assess and document the risk referred to in subsection 9.6(2) of the Act, taking into consideration prescribed factors, which is contrary to subsection 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 71(1)(c) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of a person or entity that has employees, agents or other persons authorized to act on their behalf to develop and maintain a written ongoing compliance training program for those employees, agents or persons, which is contrary to subsection 9.6(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 71(1)(d) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of a money services business 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, which is contrary to subsection 9(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 28(1)(b) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of a money services business to report the receipt from outside Canada of an electronic funds transfer of $10,000 or more in the course of a single transaction, together with the prescribed information, which is contrary to subsection 9(1) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and paragraph 28(1)(c) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.

Failure of a money services business to keep prescribed records, in accordance with section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 30 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations.