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Anti-Money Laundering and Anti-Terrorist Financing Policy

Last Updated: January 2025

1. Policy Statement

FIN TWIN Technologies Inc., operating as FINTWIN PAY, is committed to the highest standards of Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) compliance. As a registered Money Services Business (MSB) in Canada, we maintain comprehensive policies, procedures, and controls designed to detect and prevent the use of our services for money laundering, terrorist financing, or other financial crimes.

This policy applies to all employees, officers, directors, and agents of the Company, as well as all customers and business relationships.

2. Regulatory Framework

Our AML/ATF program is designed to comply with:

  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR)
  • FINTRAC Guidelines and Guidance
  • Criminal Code of Canada
  • United Nations Act and Regulations
  • Special Economic Measures Act (SEMA)
  • Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law)

3. MSB Registration

FIN TWIN Technologies Inc. is registered with FINTRAC as a Money Services Business:

  • MSB Registration Number: C10001675
  • Registered Activities: Foreign Exchange, Money Transfers, Issuing/Redeeming Money Orders, Virtual Currency Services, Payment Service Provider

4. Compliance Officer

We have appointed a Chief Compliance Officer responsible for:

  • Overseeing the implementation and effectiveness of the AML/ATF program
  • Reporting to senior management on compliance matters
  • Ensuring timely submission of reports to FINTRAC
  • Coordinating with law enforcement and regulatory authorities
  • Managing the compliance training program
  • Conducting periodic reviews and updates of policies and procedures

5. Know Your Customer (KYC) Program

5.1 Customer Identification

Before establishing a business relationship or conducting transactions, we verify the identity of all customers using reliable, independent source documents:

  • Government-issued photo identification (passport, driver's license, provincial ID)
  • Proof of address (utility bill, bank statement, government correspondence)
  • For businesses: corporate registration documents, beneficial ownership information

5.2 Customer Due Diligence (CDD)

We conduct risk-based customer due diligence including:

  • Verification of customer identity
  • Understanding the nature and purpose of the business relationship
  • Identification of beneficial owners (for corporate clients)
  • Assessment of customer risk profile
  • Screening against sanctions and PEP lists

5.3 Enhanced Due Diligence (EDD)

Enhanced due diligence measures are applied to higher-risk customers, including:

  • Politically Exposed Persons (PEPs) and their associates
  • Customers from high-risk jurisdictions
  • Complex or unusual transaction patterns
  • High-value transactions
  • Non-face-to-face business relationships

5.4 Ongoing Monitoring

We continuously monitor customer relationships and transactions to ensure they are consistent with our knowledge of the customer and their risk profile.

6. Transaction Monitoring

We maintain systems and procedures to monitor transactions for suspicious activity, including:

  • Automated transaction monitoring systems
  • Manual review of flagged transactions
  • Pattern analysis and anomaly detection
  • Threshold-based alerts
  • Periodic account reviews

7. Reporting Obligations

We comply with all reporting requirements under PCMLTFA, including:

7.1 Suspicious Transaction Reports (STRs)

We file STRs with FINTRAC when we have reasonable grounds to suspect that a transaction is related to money laundering, terrorist financing, or other criminal activity.

7.2 Large Cash Transaction Reports (LCTRs)

We report cash transactions of $10,000 CAD or more (or equivalent in foreign currency).

7.3 Electronic Funds Transfer Reports (EFTRs)

We report electronic funds transfers of $10,000 CAD or more sent or received internationally.

7.4 Virtual Currency Transaction Reports

We report virtual currency transactions of $10,000 CAD or more as required by regulation.

7.5 Terrorist Property Reports

We immediately report any property in our possession or control that we know is owned or controlled by a terrorist or terrorist group.

8. Sanctions Compliance

We maintain robust sanctions screening procedures:

  • Screening all customers against Canadian sanctions lists
  • Screening against international sanctions lists (UN, OFAC, EU)
  • Real-time transaction screening
  • Regular rescreening of existing customers
  • Immediate freezing and reporting of any matches

9. Record Keeping

We maintain comprehensive records as required by law:

  • Customer identification records
  • Transaction records
  • Compliance reports and documentation
  • Training records
  • All records retained for a minimum of five years

10. Employee Training

All employees receive AML/ATF training:

  • Initial training upon hiring
  • Annual refresher training
  • Updates on regulatory changes
  • Role-specific training as appropriate
  • Documentation of all training completed

11. Risk Assessment

We conduct regular risk assessments to identify, assess, and mitigate money laundering and terrorist financing risks, considering:

  • Customer risk factors
  • Product and service risk factors
  • Geographic risk factors
  • Delivery channel risk factors

12. Independent Review

Our AML/ATF program is subject to independent review every two years to assess its effectiveness and compliance with regulatory requirements.

13. Prohibited Activities

We do not knowingly:

  • Conduct business with shell banks
  • Process transactions for unlicensed MSBs
  • Facilitate transactions with sanctioned entities or jurisdictions
  • Assist customers in structuring transactions to avoid reporting thresholds
  • Provide services that may facilitate money laundering or terrorist financing

14. Cooperation with Authorities

We cooperate fully with FINTRAC, law enforcement, and other regulatory authorities in accordance with applicable laws. We respond promptly to information requests and production orders.

15. Updates to This Policy

This policy is reviewed and updated regularly to reflect changes in regulations, guidance, and best practices. Material updates will be communicated to all relevant parties.

16. Contact Information

For questions about our AML/ATF program, please contact:

Chief Compliance Officer
FIN TWIN Technologies Inc.
1025 King Street East, Unit 107-1587
Cambridge, Ontario, N3H 3P5, Canada
Email: compliance@fintwinpay.com