The Investigation Committee determined that DMCL LLP (the “Firm”) contravened the following Rules of the CPABC Code of Professional Conduct:
201.1 - Maintenance of the good reputation of the profession
501 - Policies and procedures for compliance with professional standards
502 - Policies and procedures for the conduct of a practice
The Financial Transactions and Reports Analysis Centre of Canada (”FINTRAC”) conducted an inspection of the Firm in 2025 to ensure compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“PCMLTFA”). The Firm self-reported to CPABC that FINTRAC had identified deficiencies in the Firm’s compliance program and that FINTRAC determined there were three violations of the PCMLTFA. The Firm was required to remediate the identified deficiencies, fined $72,750 and a public notice of the violations and penalties was published on the FINTRAC website.
The Committee took into consideration the penalties that were imposed by FINTRAC in reaching its recommendations.
The Committee recommended that the Firm:
- accept a reprimand;
- pay expenses of $3,184; and
- accept the publication of a notice of this Determination and Recommendation which identifies the Firm.