FINTRAC Fines DMCL Chartered Professional Accountants $72,750 for AML Compliance Failures
October 9, 2025 – Ottawa
FINTRAC has announced an administrative monetary penalty (AMP) of $72,750 against DMCL Chartered Professional Accountants, an accounting firm with offices in Vancouver, Surrey, Port Coquitlam, and Victoria, British Columbia.
The penalty was issued on July 25, 2025, following a compliance examination that identified multiple violations of Part 1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations.
The case has been settled in full and is now closed.
Source: FINTRAC Official News Release
Read the full FINTRAC news releaseWhat FINTRAC Found
DMCL was found to have committed three administrative violations, all related to the foundational elements of a compliance regime:
- Failure to develop and apply written compliance policies and procedures that were up to date and approved by a senior officer.
- Failure to assess and document the risk of money laundering and terrorist activity financing within the firm's operations, as required under subsection 9.6(2) of the PCMLTFA.
- Failure to conduct and document a prescribed effectiveness review of its compliance program at least once every two years, as required by regulation.
Each of these obligations is a core component of Canada's AML compliance framework—the absence of any one exposes a business to heightened regulatory scrutiny and operational risk.
Why This Matters for Accountants and Professional Firms
This penalty highlights that accounting firms are not exempt from Canada's AML/ATF regime. Under the PCMLTFA, accountants and accounting firms fall within FINTRAC's reporting sectors when they:
- Receive or pay funds on behalf of clients,
- Purchase or sell real estate, or
- Manage client money, securities, or assets.
Even firms that handle such transactions infrequently must still maintain an active compliance program—including written policies, risk assessments, staff training, and bi-annual effectiveness reviews.
For professional services firms, the risk is twofold:
- Regulatory penalties for failing to maintain a compliant AML program; and
- Reputational damage, especially for firms whose credibility relies on financial integrity and audit quality.
The Growing Enforcement Trend
FINTRAC has significantly increased its enforcement activity in recent years:
- 23 Notices of Violation were issued in 2024–25, the most in FINTRAC's history, totaling over $25 million in penalties.
- More than 150 penalties have now been imposed across nearly every reporting sector since 2008.
With Bill C-2 introducing harsher penalties and potential imprisonment for non-compliance, the message from regulators is unambiguous—every reporting entity must be audit-ready, documented, and demonstrably compliant.
Lessons for Compliance Teams
DMCL's case offers key takeaways for all firms subject to the PCMLTFA:
Current Policies
Your policies and procedures must be current, specific, and approved by senior management. Boilerplate templates or outdated manuals don't meet FINTRAC's standards.
Risk Assessment
You must conduct a formal risk assessment that identifies and documents money-laundering and terrorist-financing risks associated with your clients, services, geography, and delivery channels.
Effectiveness Review
A documented effectiveness review—at least every two years—is mandatory. This can be performed internally or by an external auditor, but it must test your program's real-world application.
Critical reminder: Without these elements in place, even well-intentioned firms can face penalties.
Protecting Your Firm with Automation and Oversight
For accountants, MSBs, and other reporting entities, accuracy and documentation are the difference between compliance and enforcement.
Modern compliance programs should include:
- Automated tracking of report deadlines,
- Risk-based onboarding checklists,
- Centralized policy management, and
- Documented training and review records.
How Comply+ Can Help
Comply+ automates FINTRAC reporting and provides tools that help organizations stay compliant with Canada's AML regime.
- Risk assessment templates tailored to your business sector
- Policy tracking and automated compliance reviews
- STR/LCTR/LVCTR submission automation through direct API integration
- Documented training and effectiveness review tools
- Centralized compliance documentation management
Comply+ ensures your reporting is complete, accurate, and on time—so you can focus on running your business, not fearing the next audit.
Final Thoughts
The $72,750 penalty against DMCL Chartered Professional Accountants demonstrates that FINTRAC's enforcement reach extends to all reporting entities, including professional services firms.
For accounting firms and other professionals subject to the PCMLTFA, the compliance requirements are clear: maintain current policies, conduct documented risk assessments, and perform regular effectiveness reviews.
With FINTRAC enforcement at record levels and Bill C-2 raising the stakes even higher, now is the time to ensure your compliance program is audit-ready and fully documented.
Stay Compliant and Audit-Ready with Comply+
Don't let compliance gaps put your firm at risk. Comply+ offers automated FINTRAC reporting, risk assessment tools, and compliance program management designed specifically for Canadian reporting entities.