When looking at recent penalties issued in this sector, Dealers in Precious Metals and Stones (DPMS) more than ever need to be aware that minor AML compliance hiccups can have impactful consequences. And especially compared to the penalties of the past given FINTRAC’s new administrative monetary penalty (AMP) framework that took effect on March 26, 2026 promising a 40x increase.
Here is the breakdown of the new financial reality when it comes to AMPs:
🔷 Minor Violations: Max penalty jumped from $1,000 to $40,000.
🔷 Serious Violations: Max penalty jumped from $100,000 to $4,000,000.
🔷 Very Serious Violations: Max penalty jumped from $500,000 to $20,000,000 (or cumulatively up to 3% of your gross global revenue) - as you can imagine, for large scale dealers at a global level, the financial consequences can be major.
When FINTRAC determines a penalty amount, they legally must evaluate your compliance history. Compliance history has always factored into FINTRAC’s penalty decisions, but now with penalties being 40x higher, an unaddressed issue from the past holds more weight than it used to.
So if you think that you have any dark spots on your past record, you will want to be extra vigilant of your go forward compliance as past issues can be reflected in new penalties.
With the enactment of Bill C-12, reporting entities, including the DPMS sector, must also have a proven reasonably designed, risk based and effective compliance program. A written policy alone won’t satisfy the requirement - your program must be proven effective in practice.
And on top of all of this, FINTRAC will now be requiring entities to enter into Mandatory Compliance Agreements (MCAs) for any final prescribed violations, and MCA breaches can result in additional penalties on top of your original AMP.
Let us audit your DPMS business framework and get you up to speed for the new 40x penalty and Mandatory Compliance Agreement era. Learn more or contact us via the button below.