AML
Under various federal and provincial regulations, the company has a duty to prevent criminals from legitimizing the proceeds of their criminal activities through the use of various techniques known as “money laundering.” PAYSAVO Canada Inc. (“PAYSAVO”) has developed strong internal Anti-Money Laundering and Anti-Terrorist Financing Policies and Procedures (“AML Policies”), in an effort to maintain due compliance with applicable laws and regulations relating to anti-money laundering and anti-terrorist financing in Canada, and with other such laws and regulations to which PAYSAVO operations are subject in other jurisdictions.
This PAYSAVO customer-facing policy outlines the internal approach taken by PAYSAVO to ensure compliance with international, federal, and provincial laws.
The Financial Transactions Reports Analysis Centre of Canada (“FINTRAC”) is Canada’s financial intelligence unit and AML and anti-terrorist financing supervisor responsible for monitoring compliance with the federal AML regime. In Canada, PAYSAVO is registered with FINTRAC and Revenu Québec as a Money Services Business (“MSB”) and has corresponding compliance obligations including, but not limited to the reporting, record keeping and know-your-client requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“PCMLTFA” or the “Act”), its associated regulations, and provincial laws in Quebec applicable to MSBs licensed in that province.
FINTRAC requires:
A Compliance Officer: or the appointment of a “responsible person”, typically the Chief Compliance Officer (“CCO”), who is charged with the implementation, oversight, and compliance of a MSB’s compliance program, which includes its internal AML Policies;
Compliance Policies and Procedures: the implementation of written compliance policies and procedures to mitigate compliance risk including records retention requirements and know-your-customer client identification, especially in the context of high-risk operations;
Ongoing Risk Assessment: conducting ongoing monitoring of all transactions for potentially suspicious, and attempted suspicious, activities and filing Suspicious Transaction Reports (“STR”), Terrorist Property Reports (“TPR”) and Large Virtual Currency Transaction Reports (“LVCTR”) when required;
Compliance Training: implementing a formal, ongoing, and documented compliance training program for all employees, agents, and others acting on behalf of PAYSAVO;
Effectiveness Review: instituting, maintaining, and documenting a review of the effectiveness of PAYSAVO’s internal AML policies and program no less than every two years.
Compliance Officer
PAYSAVO has designated its CCO as the “responsible person” for the implementation of its AML program. The CCO will conduct an annual review to test the effectiveness of the program. The CCO is also required to report any violations of the AML Policies directly to the CEO and the Board, and is responsible for recording and filing STRs, TPRs, LVCTRs and performing audits of PAYSAVO’s AML Policies and program at least annually.
Compliance Policies and Procedures
PAYSAVO has adopted a risk-based compliance regime approved by its board of directors (“The Board”). PAYSAVO personnel and the Board recognize the importance of implementing and maintaining a sound AML Policies that meets the requirements of all applicable laws and regulations, and as such, has implemented internal policies and procedures to achieve these requirements. The AML Policies are reviewed on a regular basis and, if necessary, revised in an effort to comply with regulatory changes.
Key points of the AML Policies include internal reporting and compliance requirements pertaining to:
Know Your Client (“KYC”) Identification Procedure
PAYSAVO maintains customer identity verification processes as required under legislation and according to industry best practices. PAYSAVO’s Customer Identity Program (“CIP”) is an important part of its AML Policies, which helps detect suspicious activity in a timely manner and prevent fraud.
To open an account and use PAYSAVO services, every client's identity must be verified, authenticated, and checked against various government watch lists. Only Canadian persons are able to open accounts with PAYSAVO. Failure to complete any of these steps will result in the inability to open an account and use the exchange platform on PAYSAVO.
Individual Account Opening
Prior to opening an account for an individual customer, PAYSAVO attempts to collect, verify, and authenticate the following information:
Individual Account Opening
Prior to opening an account for an individual customer, PAYSAVO attempts to collect, verify, and authenticate the following information:
- Full legal name;
- Date of birth;
- Contact information including email address and mobile phone number;
- Social insurance number or any comparable identification number issued by the government;
- Proof of identity (e.g., driver’s license, passport or any other government issued picture ID);
- Permanent home address (not a mailing address or P.O. Box); and
- Additional information or documentation that may be required at the discretion of the compliance team or in accordance with applicable laws.
Corporate Account Opening
Prior to opening an account for a corporation, PAYSAVO attempts to collect, verify, and authenticate the following information:
- The corporation’s legal name;
- Proof of legal existence (e.g., certificate of corporate status, a record that has to be filed annually under provincial securities legislation, any other record that confirms the corporation’s existence);
- Address (principal place of business and/or other physical location);
- Employer identification number or any comparable identification number issued by the government;
- Full legal name of all account signatories and beneficial owners;
- Contact information for all account signatories (email address and mobile phone number);
- Contact information of owners, principals, and executive management (as applicable);
- Proof of identity (e.g., driver’s license, passport or any other government issued picture ID) for each individual beneficial owner that owns 25% or more of the corporation, as well as all account signatories;
- Identifying information for each entity beneficial owner that owns 25% or more of the corporation (see individual customer information collected above for more details); and
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