Anti-money-laundering policy

1. Our commitment

Finexia Finance Inc. is committed to preventing its services being used to launder the proceeds of crime, to finance terrorism or proliferation, or to evade sanctions. Our programme is designed to meet the requirements of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations, which apply to money services businesses in Canada.

We are registered with FINTRAC as a money services business under registration number N300001034.

2. Compliance officer

We appoint a compliance officer with the authority and independence to run the programme, report to the directors and file reports with FINTRAC. The officer can be reached at compliance@finexiaca.com.

3. Client identification (KYC)

We verify the identity of every client, for every order, regardless of amount. Before an order is executed we collect and verify:

• Full legal name, date of birth and residential address.
• A valid government-issued photo identification document, checked for authenticity.
• A liveness or selfie check confirming the document belongs to you.
• For companies: incorporation details, ownership structure and the identity of beneficial owners holding 25% or more.

We do not accept anonymous accounts, accounts in fictitious names, or clients who will not complete verification.

4. Screening

Every client is screened at onboarding and on an ongoing basis against sanctions lists applicable in Canada, politically exposed person (PEP) data and adverse media. A match triggers enhanced due diligence, senior sign-off and, where required, refusal of the relationship.

5. Risk-based approach

Each client and each transaction is risk-rated. Factors include the client’s country of residence, occupation and source of funds, the size and pattern of orders, the payment method, and the risk profile of the destination wallet address. Higher-risk relationships attract enhanced due diligence and more frequent review.

6. Transaction monitoring

We monitor activity for indicators including structuring below reporting thresholds, rapid movement of funds inconsistent with a client’s stated profile, third-party funding, and destination addresses associated with mixers, darknet markets, ransomware or sanctioned entities. Alerts are reviewed by the compliance team and documented.

7. Reporting

We file the reports required of us, including:

• Suspicious transaction reports, whether or not the transaction completed.
• Large virtual currency transaction reports at or above CAD 10,000.
• Large cash transaction reports where applicable.
• Terrorist property reports.

Canadian law prohibits us from telling a client that a suspicious transaction report has been made. If we cannot explain why an order was declined or delayed, this is often why.

8. Record keeping

Client identification records, transaction records, risk assessments and the reasoning behind reports are retained for at least five years as required by the PCMLTFA, and are made available to FINTRAC and law enforcement on lawful request.

9. Training and review

All staff receive anti-money-laundering training on joining and at least annually thereafter. The effectiveness of the programme is reviewed independently at least every two years, and findings are reported to the directors with a remediation plan.

10. Restricted clients and jurisdictions

We do not onboard clients who appear on applicable sanctions lists, who are resident in comprehensively sanctioned jurisdictions, or who refuse to explain their source of funds. We do not market or offer services to residents of the United Kingdom or the European Union.

11. Contact

Compliance enquiries, including requests from law enforcement, should be addressed to compliance@finexiaca.com.