Anti-Money Laundering and Counter-Terrorist Financing Policy

  1. INTRODUCTION

This is the Anti-Money Laundering ("AML") and Counter-Terrorist Financing ("CTF") Policy of which is a Trading Name of

INFORMATION ABOUT US

is a Trading Name of as . is licenced by and registered with FINTRAC as a Money Service Business with FINTRAC license no. as required by the Canadian Federal Law combating money laundering and terrorism financing for businesses such as in the financial sector. Any concerns about the AML and CTF policies of and its services should be addressed to the Company.

As used in these AML and CTF policies, “” or “” or “” or “the Company” or “us” or “we” refers to the company , under the company number with its registered address at

Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm's knowledge or suspicions.

In response to the scale and effect of money laundering, Canada has passed legislation designed to prevent money laundering and to combat terrorism. This legislation, together with regulations, rules and industry guidance, forms the cornerstone of ‘s AML and CTF obligations for Canadian firms and outlines the offences and penalties for failing to comply.

is subject to provisions on Anti Money Laundering (AML) under the laws of Canada, which are in accordance with the FATF recommendations. Canada is a member country of the Financial Action Task Force (FATF). This means in particular that has to identify its customers and establish the beneficial owner's identity. The AML compliance policies approved by the Management Board include inter alia the processes for the identification of the customers and establishing the identity of the beneficial owner. The policies also cover the collection of information regarding the customers' business activities, relationships with Politically Exposed Persons and record retention procedures. Furthermore, regularly provides AML training to relevant employees and does not provide banking services to any bank that does not maintain a physical presence in any country and that is not a regulated affiliate. The anti-money laundering policies are applicable to head office and branches alike and are in accordance with the Wolfsberg anti-money laundering principles.

The AML Policy is designed to prevent money laundering by meeting the Canadian standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime.

This AML Policy sets out the minimum standards which must be complied with and includes:

The appointment of a Money Laundering Reporting Officer (MLRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;

Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;

Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);

Establishing and maintaining risk based systems and procedures to monitor on-going customer activity; Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

The maintenance of appropriate records for the minimum prescribed periods;

Training and awareness for all relevant employees

It is prohibited to provide any product or service or process any transaction for the benefit of individual or entity included in the international sanctions lists. As such, the adherence with applicable laws and regulations in relation to prevention of money laundering and terrorist financing, (hereinafter referred to as “AML”) is mandatory and fundamental to strategy and program.

has strict and transparent standards and continuously strengthens its processes so as to ensure compliance with applicable AML laws and regulations.

reserves the right to reject any customer, payment or business that is not consistent with the AML policy, irrespective of the requirements of the applicable AML laws and regulations.

  1. MAIN OBJECTIVES
  • Combating and preventing money laundering and terrorist financing and taking all the necessary preventive measures;
  • Preventing the misuse of the Company by anyone or anybody in illegitimate operations;
  • Appointing a Money Laundering Reporting Officer (MLRO) who has a sufficient level of seniority and independence, and who has responsibility for oversight of compliance with the relevant legislation, regulations, rules and industry guidance;
  • Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm;
  • Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);
  • Establishing and maintaining risk-based systems and procedures for the monitoring of on-going customer activity;
  • Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • Maintaining appropriate records for the minimum prescribed periods;
  • Training all employees on the rules and internal procedures which have to be observed, the risks that they and the Company face and how they can encounter the risks of money laundering and terrorist financing through their operations from their positions.
  1. COMPANY COMMITMENT

is committed to:

  • Accept only those Customers whose identity can be established and verified and whose source of funds can be reasonably established to be legitimate;
  • Not establish a business relationship, open accounts or maintain accounts for anonymous persons or those with fictitious names including anonymous accounts;
  • Make every possible effort to know the identity of the customer and the real beneficiary (Beneficiary Owner) of the account (i.e. the full name, the place and date of birth and verifying the identity by using valid, official and accredited documents “identification data” issued by the official bodies), in addition to the data and information available from trusted independent sources;
  • Apply a risk-based approach, and enhanced customer due diligence where required;
  • Monitor and identify suspicious transactions and activities and ensure that reportable ones get reported;
  • Provide regular and appropriate AML / CTF training and information to all employees to increase their awareness using various methods;
  • Maintain records, which are appropriate to the nature and complexity of the customer’s business.
  1. CUSTOMER DUE DILIGENCE

In terms of its obligations at law, is obliged to determine the applicant for business, the Customer or any beneficial owner, and to verify that such person is the person he purports to be, as well as to determine whether such person is acting on behalf of someone else, and to establish the purpose and intended nature of the business relationship and to monitor this relationship on an ongoing basis. In order to successfully adhere to its obligations, has developed Customer due diligence (“Due Diligence”) measures which must be implemented by and adhered to by its management and employees.

The Due Diligence measures assist in determining whether a particular Customer falls within their risk appetite, as well as helps the Company clearly understand the business activities of the Customer in such a way that any transactions which fall outside the business profile of the company may be investigated to determine whether any money laundering or funding of terrorism may be involved. This enables the Company to inform relevant authorities in a timely manner with adequate information on its Customer and their activities when such a request is made.

In summary, has adopted its Due Diligence policies in order to successfully carry out the following:

  • identification and verification of the applicant for business
  • identification and verification of the beneficial owner, where applicable
  • identification and verification when the applicant for business does not act as principal
  • obtaining information on the purpose and intended nature of the business relationship
  • conducting ongoing monitoring of the business relationship
  • establishing the source of wealth and source of funds
  • setting up of a Customer acceptance policy and ensuring that the applicant for business meets the requirements set out in such policy.
  • is strictly prohibited from keeping anonymous accounts or accounts in fictitious names.

4.1. Prohibitions

has no AML risk appetite for customers who engage in any of the following activities:

  • intentional or wilfully negligent breaches of law, regulation or policy applicable to money laundering and terrorist financing risk;
  • repeated unintentional or repeated accidental breaches of AML laws;
  • misusing the account for the purpose of money laundering or terrorism financing;
  • misusing the account for the purpose of other fraud;
  • facilitating business activities which could be construed as a tax offence;
  • refusing to provide sufficient information or documentation to demonstrate compliance with the standards outlined in AML policy.

The Company has no risk appetite for customers or transaction to or from jurisdictions which are identified as high-risk third countries on the lists of jurisdictions having serious deficiencies in their anti-money laundering regimes drawn up by the Canadian proceeds of crime (money laundering) and terrorist financing act and / or the FATF and / or any other relevant anti money laundering governing bodies of our AML KYC CTF partners from time to time, and/or the Company as amended from time to time. intends to conduct business only with reputable customers who use their own products, services, and related accounts for legitimate purposes, and whose identities can be determined and verified. In keeping with that principle, the Company will not knowingly conduct business with customers that seek to process payments through the Company involving:

  • Collecting donations as a charity or non-profit organization, NGO’s;
  • Dating (newly incorporated, not known);
  • Drug paraphernalia – product or accessory that is intended or modified for making, using, or concealing drugs, typically for recreational purposes;
  • Drugs / Illicit substances, steroids and certain controlled substances or other products that present a risk to consumer safety;
  • Extractive Industries (otherwise requires pre-approval);
  • Healthcare Discount Plans
  • High Risk File hosting / sharing and cyberlockers;
  • Unregulated pharmaceuticals, illegal drugs and or unlicensed drug related activity;
  • Infringe any duly registered copyrights/trademarks or other violation of intellectual property rights;
  • Involve offering or receiving payments for the purpose of bribery or corruption or any form of high yield financial investments (get rich quick schemes);
  • Items that encourage, promote, facilitate or instruct others to engage in illegal activity;
  • Lottery and gambling;
  • Membership Clubs;
  • Oil & Gas Industries (otherwise requires pre-approval);
  • Offshore banking operations;
  • PC Support sold via outbound telemarketing;
  • Phone Services;
  • Pyramid or Ponzi schemes;
  • Relate to the sale of dangerous or hazardous goods;
  • Replicas;
  • Sale of government ID’s or documents;
  • Scottish LP, LLP;
  • Services associated with prostitution, escort;
  • Stolen goods including digital and virtual goods (fictitious social media likes, spam emails);
  • Violate any law, statute, ordinance or regulation;
  • Weapons, firearms and ammunitions;

Please note that the company may suspend or terminate business relationship with the customer subject to the requirements of applicable AML laws and regulations.

4.2. Sanctions.

is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. will therefore screen against the relevant sanctions lists in the jurisdictions in which we operate.

has no AML Risk Appetite for establishing or maintaining a customer or a counterparty relationship with a natural person or legal entity designated on any of the below lists or where otherwise prohibited by applicable law or regulation:

  • sanction lists administered by the United States Office of Foreign Assets Control (OFAC),
  • the Canadian Government Sanctions List/s;
  • the United Nations Security Council Sanctions List (UN);
  • the Consolidated List of European Union Financial Sanctions (EU);
  • including the List of Specially Designated Nationals and Blocked Persons;
  • any other sanctions list.

In addition, pays particular attention to entities from countries which are on the list of noncooperative countries and territories drawn up by the Financial Action Task Force (FATF) and to monetary operations or transactions performed by or on behalf of them.

  1. MONITORING FOR SUSPICIOUS ACTIVITY

AML policy includes customer’s and beneficial owner’s due diligence and ongoing AML monitoring and AML reporting policies. At various points in time, may request information regarding the transactions carried out through the customer’s account opened at and the parties of the respective payment. If the customer may not respond sufficiently or within a timely manner, also reserves the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.

  1. EMPLOYEE’S OBLIGATIONS
  • The Company’s employees shall be personally liable for knowingly or deliberately failing to report known information or suspicion, regarding money laundering or terrorist financing.
  • The employees must cooperate and report, without delay, anything that comes to their attention in relation to transactions for which there is a slight suspicion that are related to money laundering or terrorist financing.
  • According to the Law, the Company’s employees shall fulfil their legal obligation to report their suspicions regarding Money Laundering and Terrorist Financing.

Version 12.09.22

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