FX Wallet Inc. ("FX Wallet") is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. As a registered Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), registration number C100000126, we are subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations.
This AML Policy outlines our commitment to preventing the use of our Services for money laundering, terrorist financing, sanctions evasion, or other financial crimes. All employees, officers, directors, and agents of FX Wallet are required to comply with this policy.
1. Compliance Framework
Our AML/CTF compliance program includes the following core elements:
- Designated Compliance Officer: A senior officer responsible for overseeing the implementation and effectiveness of the AML/CTF program.
- Written Policies and Procedures: Comprehensive internal policies governing customer due diligence, transaction monitoring, reporting, and record-keeping.
- Risk Assessment: Regular enterprise-wide risk assessments to identify, assess, and mitigate money laundering and terrorist financing risks.
- Employee Training: Ongoing AML/CTF training for all employees, with enhanced training for staff in compliance-sensitive roles.
- Independent Review: Biennial independent review of the compliance program's effectiveness by a qualified external party.
2. Customer Due Diligence (CDD)
2.1 Know Your Customer (KYC)
Before establishing a business relationship, we verify the identity of every customer through:
- Government-issued photo identification (passport, driver's licence, or provincial ID card).
- Proof of address (utility bill, bank statement, or government correspondence dated within 90 days).
- For business accounts: articles of incorporation, business registration, beneficial ownership declaration, and director/officer identification.
2.2 Enhanced Due Diligence (EDD)
We apply enhanced due diligence measures for higher-risk customers, including:
- Politically Exposed Persons (PEPs): Domestic and foreign PEPs, heads of international organizations, and their family members and close associates.
- High-Risk Jurisdictions: Customers located in or transacting with countries identified as high-risk by FATF, FINTRAC, or our internal risk assessment.
- High-Value Transactions: Transactions that exceed established thresholds or are inconsistent with the customer's profile.
- Complex Structures: Customers with complex corporate structures, nominee arrangements, or bearer shares.
EDD measures may include obtaining additional identification, verifying source of funds and source of wealth, conducting enhanced ongoing monitoring, and obtaining senior management approval for the business relationship.
2.3 Ongoing Monitoring
We continuously monitor customer accounts and transactions to detect:
- Unusual or suspicious transaction patterns.
- Transactions inconsistent with the customer's known profile, business, or source of funds.
- Structuring or splitting of transactions to avoid reporting thresholds.
- Rapid movement of funds through accounts with no apparent business purpose.
- Changes in customer risk profile or adverse media findings.
3. Sanctions Screening
We screen all customers, beneficial owners, and transaction counterparties against applicable sanctions lists, including:
- Canadian sanctions lists maintained by Global Affairs Canada under the Special Economic Measures Act (SEMA), Justice for Victims of Corrupt Foreign Officials Act (JVCFOA), and United Nations Act.
- FINTRAC's listed terrorist entities.
- U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list.
- European Union consolidated sanctions list.
- United Nations Security Council consolidated list.
Screening is performed at onboarding, at the time of each transaction, and on an ongoing basis as lists are updated. Any matches are escalated to the Compliance Officer for review and, if confirmed, result in immediate account freezing and regulatory reporting.
4. Transaction Monitoring and Reporting
We employ automated and manual transaction monitoring systems to identify and report:
4.1 Mandatory Reports to FINTRAC
- Suspicious Transaction Reports (STRs): Filed when there are reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing, regardless of the amount.
- Large Cash Transaction Reports (LCTRs): Filed for cash transactions of $10,000 CAD or more, or multiple cash transactions totalling $10,000 CAD or more within a 24-hour period.
- Electronic Funds Transfer Reports (EFTRs): Filed for international electronic funds transfers of $10,000 CAD or more.
- Terrorist Property Reports: Filed immediately upon discovering property owned or controlled by a listed terrorist entity.
4.2 Internal Escalation
Any employee who identifies potentially suspicious activity must immediately escalate the matter to the Compliance Officer. The Compliance Officer will assess the situation and determine whether a report to FINTRAC is warranted. Tipping off — informing a customer that a report has been or will be filed — is strictly prohibited and is a criminal offence under the PCMLTFA.
5. Record Keeping
In accordance with FINTRAC requirements, we maintain comprehensive records of:
- Customer identification and verification documents — retained for at least 5 years after the business relationship ends.
- Transaction records, including date, amount, currency, parties involved, and purpose — retained for at least 5 years from the date of the transaction.
- Copies of all reports filed with FINTRAC — retained for at least 5 years from the date of filing.
- Risk assessments, compliance reviews, and training records.
- All correspondence related to compliance inquiries, investigations, and regulatory examinations.
6. Employee Obligations
All FX Wallet employees are required to:
- Complete AML/CTF training upon hiring and at least annually thereafter.
- Report any suspicious activity to the Compliance Officer immediately.
- Not engage in tipping off or any action that could compromise an investigation.
- Cooperate fully with internal and external compliance reviews and audits.
- Maintain the confidentiality of all compliance-related information.
Failure to comply with this policy may result in disciplinary action, up to and including termination of employment, and may expose the individual to criminal liability under the PCMLTFA.
7. Risk-Based Approach
Our AML/CTF program is built on a risk-based approach, meaning we allocate compliance resources proportionate to the level of risk. We assess risk across four dimensions:
- Customer Risk: Based on customer type, occupation, PEP status, and source of funds.
- Geographic Risk: Based on the jurisdictions involved in the transaction or the customer's location.
- Product/Service Risk: Based on the type of service used and its susceptibility to misuse.
- Channel Risk: Based on how the customer interacts with us (online, in-person, through intermediaries).
8. Cooperation with Authorities
FX Wallet cooperates fully with FINTRAC, law enforcement agencies, and other regulatory authorities in the prevention and detection of financial crime. We respond promptly to lawful requests for information, production orders, and regulatory examinations.
We will not establish or maintain a business relationship where we are unable to apply adequate customer due diligence measures or where we have reasonable grounds to suspect the relationship involves financial crime.
9. Contact
For questions about this AML Policy or to report suspicious activity, please contact:
FX Wallet Inc. — Compliance Officer
2300 Yonge St, Suite 1600
Toronto, ON M4P 1E4, Canada
Email: [email protected]