AML Policy Statement

KYC/AML Policy Statement

  1. Introduction

This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy (the “Policy”) is implemented to comply with Canadian law, including but not limited to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, the Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations, the Freezing Assets of Corrupt Foreign Officials Act, the Assessment of Inherent Risks of Money Laundering and Terrorist Financing in Canada, and applicable guidance materials issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). This Policy also adheres to the requirements of Canadian sanctions legislation, including the United Nations Act, the Special Economic Measures Act, and the Justice for Victims of Corrupt Foreign Officials Act. Additionally, the Policy aligns with Electronic Funds Transfer (EFT) requirements under the Income Tax Act, the Excise Tax Act, and the Excise Act, 2001.

This Policy is designed to prevent money laundering, terrorist financing, fraud, and other financial crimes. By using our services, you agree to the terms outlined in this Policy.

  1. Identification and Verification

All clients must be fully identified before any business relationship is established. We do not allow any financial transactions outside of a formal business relationship.

For identification purposes, we may require you to provide the following information: full name, residential address, telephone number, email address, date of birth, government-issued identification number, and details regarding your bank account (e.g., bank name, account number, and any applicable EFT information).

We may also request the following documents for verification: a valid Canadian government-issued ID (such as a passport, driver’s license, or provincial ID card); a live selfie using direct video streaming technology; a bank statement or utility bill issued within the last three months; tax documents; or other relevant documents deemed necessary. Video identification may be required during the onboarding process or before certain transactions.

All clients will be identified before the establishment of any business relationship. No transactions or operations will be permitted outside of an established business relationship.

Our identification process includes:

  • You will be required to create an account, verify your email and phone number, and provide an appropriate identity document for verification. These steps must be completed before any business relationship is established.
  • You may be required to provide additional documentation, such as a utility bill, bank statement, or other proof of address, along with a selfie. You may also be required to undergo video identification. All these steps are prerequisites for establishing a business relationship and conducting transactions.

We may perform inquiries directly or through third parties to verify your identity or to protect against fraud or other financial crimes. By providing your personal information, you consent to its disclosure to credit reference, fraud prevention, and financial crime agencies, which may respond to our inquiries in full.

Clients are required to provide accurate and truthful information during the identification and verification process. Failure to comply with these requirements or providing false information may result in account suspension or termination. We reserve the right to refuse to enter into or maintain a business relationship with individuals or entities that do not meet our KYC/AML requirements.

We reserve the right to verify your identity on an ongoing basis, particularly if your identification information changes or your activities appear suspicious. We may request updated documents even if you have previously completed the identity verification process.

  1. No Random Operations

We do not permit any financial transactions or operations outside of an established business relationship. All transactions must occur within the framework of a pre-existing business relationship that has been fully verified according to this Policy.

4 . Prohibited countries and jurisdictions

Afghanistan

Belarus

Burundi

Central African Republic

Congo, the Democratic Republic

Eritrea

Gaza Strip

Guinea Bissau

Iran, Islamic Republic of

Iraq

Kosovo

Lebanon

Libya

Myanmar

North Korea

Panama

Russian Federation

Somalia

  1. Transaction Monitoring and Sanctions Compliance

We actively monitor and analyze your transactions. We may perform compliance-related tasks, including data capture, filtering, record-keeping, investigation management, and reporting. We may place you on watch and service denial lists, open cases for investigation where needed, send internal communications, and file statutory reports, if applicable.

We have the right to:

  • Report your transactions of a suspicious nature to the proper Canadian authorities, including FINTRAC, as required under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act;
  • Request that you provide any additional information and documents in case of suspicious transactions;
  • Suspend or terminate your account when we suspect you are engaged in illegal activity.

As part of our AML compliance program, we conduct sanctions screening in accordance with Canadian sanctions legislation, including the United Nations Act, the Special Economic Measures Act, and the Justice for Victims of Corrupt Foreign Officials Act. Clients and transactions may also be screened against sanctions imposed by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury, the European Union, and the United Nations. This screening ensures that no transactions or business relationships are maintained with individuals, entities, or countries subject to sanctions imposed by these bodies.

6. Data Protection

    Your personal data will be handled in accordance with Canadian data protection laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA). We are committed to ensuring the confidentiality and security of your information.

    7. Amendments to This Policy

      This Policy may be amended at any time without prior notice. Any changes will be effective immediately upon posting on our website. Your continued use of our services constitutes your acceptance of the revised Policy.

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