Compliance statement

01Registration

CCYFX PAY INC (“CCYFX”) is a corporation incorporated in British Columbia, Canada (company no. BC1564200), with its head office in Vancouver. CCYFX is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business for the following activities:

• Foreign exchange dealing
• Remitting or transmitting funds
• Dealing in virtual currency
• Payment services

You can confirm our registration on the FINTRAC MSB Registry. Registration with FINTRAC is not an endorsement by FINTRAC or the Government of Canada.

02Compliance programme

We maintain a written compliance programme under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations. The programme includes:

• A designated Compliance Officer with the authority and resources to administer the programme
• Written policies and procedures, approved by senior management and kept up to date
• A documented assessment of money laundering and terrorist financing risk across our clients, sectors, products, delivery channels and geographies
• Ongoing compliance training for everyone who acts on our behalf
• A review of the effectiveness of the programme at least every two years

03Risk appetite

We serve clients in sectors and structures that many financial institutions consider higher risk, including licensed gaming, regulated brokerage, adult entertainment, defence and international holding structures. We do so deliberately, and we manage the associated risk through enhanced due diligence, senior management approval and closer monitoring, rather than by declining entire sectors.

We assess each relationship individually. We may decline any application, or end any relationship, that falls outside our risk appetite.

04Client identification

We identify every client before we carry out a transaction or open a relationship. For entities, this includes:

• Confirming the existence of the entity from its registry records or constitutional documents
• Identifying its directors, trustees or other persons who control it
• Identifying every individual who directly or indirectly owns or controls 25% or more of the entity, and taking reasonable measures to confirm that information
• For trusts, identifying the settlor, the trustees, known beneficiaries and any protector
• Understanding the intended purpose and nature of the relationship

We also determine whether a client or any of its beneficial owners is a politically exposed person, the head of an international organization, or a family member or close associate of such a person.

05Enhanced due diligence

We apply enhanced due diligence wherever our risk assessment requires it. This may include verified evidence of source of wealth and source of funds, additional documents confirming ownership through each layer of a structure, senior management approval before the relationship begins, and more frequent reviews and closer transaction monitoring.

Where a fiduciary or introducer refers a client, we carry out our own due diligence on the client and its owners.

06Higher-risk sectors

For clients in regulated or sensitive sectors, we also require evidence of the controls that the sector demands. For example:

• Gaming: a valid licence for every market served, and player protection and anti-money laundering policies
• Brokerage: regulatory authorisation and confirmation that client money is segregated
• Adult entertainment: verified age, identity and consent for everyone depicted, with moderation and takedown processes
• Defence: export and brokering permits and end-user documentation

07Sanctions

We screen clients, their owners and controllers, and payment beneficiaries against Canadian sanctions, including measures under the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act and the Criminal Code, and against other major international sanctions lists. Screening takes place at onboarding, on every payment and whenever the lists change.

08Reporting

We file with FINTRAC the reports that Canadian law requires, including suspicious transaction reports, large cash transaction reports, large virtual currency transaction reports, electronic funds transfer reports and terrorist property reports. The law prohibits us from telling a client whether a suspicious transaction report has been filed.

09Record keeping

We keep client identification records, beneficial ownership information and transaction records for at least five years, in a form that we can provide to FINTRAC within 30 days of a request.

10Restricted clients

We do not open or maintain relationships with:

• Persons, entities or countries subject to Canadian sanctions
• Shell banks, or financial businesses operating without a required licence or registration
• Businesses in licensed sectors that do not hold the required licence for the markets they serve
• Anonymous accounts, or structures in which we cannot identify the beneficial owners
• Any activity that is illegal where it is carried out
• Clients who cannot explain third-party funding or the purpose of their payments

11Raising a concern

To raise a compliance concern, or to ask a question about this statement, please contact our Compliance Officer: