BC accounting firm DMCL fined for AML/ATF non-compliance by FINTRAC

OTTAWA, October 19, 2025 — News that an accounting firm in British Columbia was fined for non-compliance by the federal financial intelligence unit has highlighted evolving and costly risks for Canadian accountants. The Financial Transactions and Reports Analysis Centre recently announced that Dale Matheson Carr Hilton LaBonte LLP had paid more than $72,000 for failing to "assess and document" money laundering and terrorist financing risks. 

Following a compliance examination, the federal agency imposed an administrative monetary penalty of $72,750 on July 25, 2025, for non-compliance with Part 1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations. DMCL Chartered Professional Accountants was found to have committed the following administrative violations:

• Failure to develop and apply written compliance policies and procedures that are kept up to date and are approved by a senior officer.
• Failure to assess and document the risk of a money laundering offence or a terrorist activity financing offence in the course of its activities, taking into consideration the prescribed factors.
• Failure to institute and document the prescribed review of its compliance program for the purpose of testing its effectiveness, to be carried out and the results documented every two years by an internal or external auditor of the person or entity. 

According to the Canadian Press, Matthew Gosden of DMCL said in a statement that the firm took "immediate action" to fix its policies and procedures when FINTRAC informed the firm about the violations earlier this year. FINTRAC says the administrative monetary penalty has been paid in full and the case is closed. 

Evolving AML/ATL regulatory risks for accountants

FINTRAC has a webpage specifically for accountants that explain its record-keeping requirements to comply with anti-money laundering/anti-terrorist financing legislation. The guidance outlines certain record keeping requirements for accountants and accounting firms, as well as links to additional record keeping requirements. 

As Hugh Neilson, a well-known tax consultant, pointed out on LinkedIn: “The issues identified don't suggest any money-laundering activity was detected, only that the firm lacked the required processes to assess the risks of money-laundering activity.” As another LinkedIn member posted: “This shows how costly small compliance gaps can become. A written policy on paper means nothing if it’s not updated and tested regularly.” 

According to FINTRAC’s penalty against DMCL sends a clear warning to Canada’s non-financial sectors, the penalty “confirms a paradigm shift: compliance failure itself constitutes risk.” For accounting firms, which “often sit at the intersection of legitimate and high-risk financial activity … these violations might appear administrative, [but] they reveal deeper structural weaknesses that leave professional service networks open to abuse by illicit actors. 

“When compliance controls are deficient, such intermediaries can inadvertently become conduits for layering transactions or disguising beneficial ownership.” 

DMCL the subject of other regulatory action

DMCL has more than 300 team members spread across its offices Vancouver, Surrey, Tri-Cities (Port Coquitlam), and Victoria, British Columbia. It traces its history to 1984, when Robert (Bob) J. Matheson began business as a sole practitioner in Vancouver. The firm grew through mergers and a 2004 commitment to continue audit work following the the implementation of Sarbanes-Oxley in the United States. 

In 2021, the US Public Company Accounting Oversight Board censured DMCL and fined the firm US$50,000 for violating PCAOB rules and standards in connection with two issuer audits. In 2023, the Canadian Public Accountability Board also sanctioned the firm and barred it from accepting “new elevated and high-risk reporting issuers.” 

As reported by Canadian Accountant, the sanctions against DMCL were part of a wave of sanctions against auditors in British Columbia by regulators on both sides of the border, which garnered the attention of business journalists in BC, who were critical of accounting regulation in the province. 

In a statement, Sarah Paquet, director and CEO of FINTRAC, stated: “Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime is in place to protect the safety of Canadians and the security of Canada’s economy. FINTRAC works with businesses to help them understand and comply with their obligations under the Act. We are also firm in ensuring that businesses continue to do their part and we will take appropriate actions when they are needed.” 

Colin Ellis is a contributing editor to Canadian Accountant.