Avoiding FINTRAC’s ‘hall of shame’
No one in the diamond industry wants to see its non-compliant behaviour sanctioned by an administrative penalty, referred to law enforcement agencies for potential prosecution, and/or posted to FINTRAC’s online ‘hall of shame,’ so to speak. The monetary hit of an administrative penalty is bad enough, and each of these administrative and penal sanctions come with legal fees, not to mention the blow to a business’s reputation.
Whether in the DPMS sector or sectors to which PCMLTFA and its regulations apply, good compliance is good business.
If your business has been examined, now is the time to act on any observations made by FINTRAC and correct noted deficiencies. Consult with compliance experts and consider moving toward compliance best practices. If your business has not yet been examined, consider conducting an independent audit of your compliance program and procedures. Be ready when FINTRAC comes knocking on your door.
Marc Lemieux is an experienced Quebec and Ontario lawyer specialized in banking, finance, and payment law. He acts for clients in court cases, commercial transactions, and compliance matters. Lemieux assists DPMSs in developing compliance regimes and advises on matters related to FINTRAC. He can be contacted via e-mail at marc@marclemieux.com.
