Anti-Money Laundering (AML) Policy & Sanctions Compliance Statement

Last updated: 2026

1. Policy Statement

FinNova Payments Ltd ("FinNova", "we", "our", or "us") is committed to maintaining the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. As a registered Money Services Business (MSB) with FINTRAC in Canada, we are subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations.

This policy outlines our commitment to preventing money laundering, terrorist financing, and other financial crimes through robust policies, procedures, and controls.

2. Regulatory Framework

Our AML/ATF program is designed to comply with applicable laws and regulations, including but not limited to:

  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
  • FINTRAC Guidelines for Money Services Businesses
  • Financial Action Task Force (FATF) Recommendations
  • Office of Foreign Assets Control (OFAC) Sanctions
  • United Nations Sanctions
  • European Union Sanctions Regulations

3. Customer Due Diligence (CDD)

We implement risk-based customer due diligence procedures, which include:

  • Identification Verification: Collecting and verifying customer identification documents
  • Beneficial Ownership: Identifying and verifying the identity of beneficial owners (25% or greater ownership)
  • Risk Assessment: Assessing the risk level of each customer based on factors such as business type, geographic location, and transaction patterns
  • Enhanced Due Diligence (EDD): Applying additional measures for high-risk customers
  • Ongoing Monitoring: Continuously monitoring customer transactions and updating customer information as necessary

4. Know Your Customer (KYC) Requirements

All customers must provide the following information before using our services:

  • Full legal name
  • Date of birth
  • Address (residential or business)
  • Government-issued identification document
  • For businesses: registration documents, articles of incorporation, and information about directors and beneficial owners

5. Transaction Monitoring

We employ automated transaction monitoring systems to detect and report suspicious activities. Our monitoring includes:

  • Real-time screening against sanction lists
  • Pattern analysis to identify unusual transaction behaviors
  • Threshold monitoring for large transactions
  • Geographic risk indicators
  • Peer group analysis

6. Sanctions Compliance

FinNova is committed to full compliance with economic sanctions imposed by:

  • Office of Foreign Assets Control (OFAC) - United States
  • Financial Sanctions Unit (FSU) - Canada
  • United Nations Security Council
  • European Union
  • Other applicable jurisdictions

We do not conduct business with individuals, entities, or countries listed on any sanctions list. All transactions are screened against comprehensive sanctions lists before processing.

7. Suspicious Activity Reporting

When we identify suspicious transactions or activities, we are required to report them to FINTRAC as a Suspicious Transaction Report (STR). We maintain strict confidentiality regarding such reports and do not disclose the filing of a report to the customer or any third party.

8. Record Keeping

We maintain comprehensive records of all customer identification, transaction data, and compliance documentation in accordance with regulatory requirements. Records are retained for a minimum of five years from the date of the last transaction or account closure.

9. Training and Awareness

All employees receive AML/ATF training upon joining the company and participate in ongoing refresher training. Training covers:

  • Recognition and reporting of suspicious activities
  • Customer due diligence procedures
  • Sanctions compliance requirements
  • Record keeping obligations

10. Compliance Officer

Our designated Compliance Officer is responsible for:

  • Overseeing the implementation and enforcement of AML/ATF policies
  • Ensuring adequate training programs are in place
  • Managing suspicious activity investigations
  • Liaising with regulatory authorities
  • Reporting to senior management and the board of directors

11. Third-Party Oversight

We conduct thorough due diligence on all third-party service providers and business partners to ensure they meet our AML/ATF standards. Regular reviews are conducted to assess ongoing compliance.

12. Policy Updates

This policy is reviewed annually or whenever significant regulatory changes occur. Updates are communicated to all relevant stakeholders and training programs are revised accordingly.

13. Contact

For questions or concerns regarding our AML/ATF and Sanctions Compliance Program, please contact:

Email: compliance@finnovapayments.com
Address: 5307 Victoria Drive, Suite 851, Vancouver BC V5P 3V6, Canada