Advance Payments Inc. is committed to the highest standards of Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance. We are dedicated to preventing our systems and services from being used for money laundering, terrorist financing, or other illegal activities.

1. Introduction

This policy outlines the procedures and controls we implement to detect, prevent, and report suspicious activities. As an entity pending registration as a Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), we adhere to the requirements of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

2. Customer Identification Program (CIP)

To comply with regulatory requirements, we implement a robust Customer Identification Program. This includes:

  • Verifying the identity of any person seeking to open an account or use our services.
  • Maintaining records of the information used to verify the person's identity.
  • Determining whether the person appears on any lists of known or suspected terrorists or terrorist organizations.

3. Know Your Customer (KYC) Procedures

We perform due diligence on all customers. This may involve collecting:

  • Government-issued photo identification (e.g., passport, driver's license).
  • Proof of address (e.g., utility bill, bank statement).
  • Information regarding the nature of the customer's business and source of funds.
  • Additional documentation for corporate entities, including beneficial ownership details.

4. Monitoring and Reporting

We continuously monitor transactions for suspicious activity. This includes:

  • Transactions that have no apparent business or lawful purpose.
  • Transactions that are inconsistent with a customer's known legitimate business or personal activities.
  • Unusual patterns of transactions.

We are required to report certain transactions to FINTRAC, including large cash transactions and suspicious transactions, in accordance with Canadian law.

5. Risk-Based Approach

We employ a risk-based approach to compliance, meaning that we allocate more resources and scrutiny to higher-risk customers and transactions. This allows us to effectively manage and mitigate money laundering and terrorist financing risks.

6. Compliance Officer

Advance Payments Inc. has designated a Compliance Officer responsible for overseeing the AML/KYC program, ensuring staff training, and maintaining compliance with all applicable laws and regulations.