Effective Date: 01.03.2025

Registration Number (FINTRAC): C100000462

1. Purpose

This policy sets out URIGHTCOMPANY FINANCE LIMITED’s approach to the prevention of money laundering, terrorist financing, and other illicit financial activities in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC requirements.

2. Scope

This policy applies to:
– All employees, agents, and partners of the Company;
– All business clients using URIGHTCOMPANY’s payment services;
– All jurisdictions in which we operate.

3. Compliance Officer

A dedicated AML Compliance Officer (CO) is appointed and is responsible for:
– Oversight of the AML/CTF program;
– STR (Suspicious Transaction Reports) and LCTR reporting to FINTR-AC;
– Staff training and audit;
– Ongoing monitoring of compliance obligations.

4. Risk-Based Approach

We apply a risk-based approach (RBA) to assess and mitigate ML/TF risks:
– Enhanced due diligence (EDD) for high-risk clients (e.g., PEPs, high-risk jurisdictions);
– Ongoing monitoring of transactions for unusual behavior;
– Client risk scoring based on business activity, geography, and transaction volume.

5. Customer Due Diligence (CDD) & Know Your Customer (KYC)

Prior to providing services, we must:
– Identify and verify the identity of each client;
– Collect business registration documents and beneficial ownership;
– Verify authorized representatives;
– Screen all parties against global sanctions lists.

See KYC Policy for detailed requirements.

6. Ongoing Monitoring

Transaction monitoring rules are defined to detect suspicious patterns;
All activity is reviewed based on risk profile;
Red flags include: layering, unusual crypto conversions, rapid fund movements, etc.

7. Record Keeping

We retain the following for a minimum of 5 years:
– Identification documents
– Transaction records
– Communication logs
– STRs and compliance logs

Records are securely stored and accessible only to authorized personnel.

8. Reporting Obligations

We report the following to FINTRAC:
– Suspicious Transaction Reports (STRs)
– Large Cash Transaction Reports (LCTRs) (if applicable)
– Large Virtual Currency Transactions (LVCTRs)
– Terrorist Property Reports

Reports must be submitted without delay after detection.

9. Training

All employees undergo AML/CTF training:
– At onboarding;
– Annually thereafter;
– Additional training when legislation or company procedures change.

10. Independent Review

Our AML/CTF program is reviewed every 2 years by an independent third party to ensure compliance with Canadian regulations.

11. Sanctions Compliance

We screen all clients and transactions against:
– UN Sanctions List
– OFAC SDN List
– EU Sanctions
– Canadian Sanctions List

Sanctioned parties are denied access and reported as necessary.

12. Internal Controls

Dual control mechanisms on high-value transactions;
Access restrictions on client data;
2FA for internal systems;
Regular audits by compliance personnel.

13. Policy Review

This AML/CTF policy is reviewed at least annually or following major regulatory changes.

Contact AML Compliance Officer: [email protected]