Griffin Jewellery Designs Inc., a jewellery retailer operating 21 stores across Ontario, Nova Scotia and New Brunswick, has been issued a monetary penalty of $77,137.50 by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
The penalty followed a compliance examination that identified three violations of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.
The retailer has paid the penalty in full, and the case is now closed.
Summary of Violations
The first violation related to the failure to maintain up-to-date written compliance policies and procedures, approved by a senior officer. FINTRAC stated that Griffin’s documentation did not cover required elements such as client identification, record keeping and reporting obligations. It also lacked information on how the business complies with ministerial directives.
Secondly, Griffin Jewellery Designs did not fully assess and document risks associated with money laundering or terrorist financing. The company did not evaluate risks relating to its products, services, delivery channels, geographic locations or client relationships.
The third violation concerned the absence of a required review of the company’s compliance programme. FINTRAC confirmed that no formal review had been conducted to assess the effectiveness of Griffin’s policies, risk assessment or training activities.
All three violations were classified as serious under the Act and the related penalty regulations.
Regulatory Context
The Proceeds of Crime (Money Laundering) and Terrorist Financing Act sets out obligations for businesses in sectors vulnerable to financial crime, including jewellery, real estate, financial services and casinos. These include identifying clients, maintaining records, reporting certain transactions and conducting regular internal reviews.
FINTRAC states that administrative penalties are intended to encourage compliance rather than to penalise. The agency issued 23 notices of violation in 2024–25, totalling more than CA$25 million – the highest total in a single year. Since 2008, over 150 penalties have been issued across multiple sectors.
Implications for the Jewellery Sector
Jewellers in Canada are considered reporting entities under the Act and must have documented anti-money laundering (AML) and counter-terrorist financing (CTF) procedures in place. This includes a written compliance programme, documented risk assessments, employee training and a review at least once every two years.
The case reflects FINTRAC’s enforcement activity across designated non-financial businesses and professions (DNFBPs), which includes jewellery retailers.
In a statement, FINTRAC’s Director and CEO, Sarah Paquet, said:
“FINTRAC is committed to working with businesses to help them understand and comply with their obligations. However, we will take appropriate action when businesses are found to be non-compliant.”
Jewellers may wish to review their AML/CTF programmes to confirm they align with current regulatory expectations.
