SENDNOW PAYMENTS LTD is committed to complying with all applicable laws and regulations relating to anti-money laundering (AML) and combating the financing of terrorism (CFT) in Canada. This AML Policy outlines our commitment to preventing our services from being used for illegal activities, such as money laundering or terrorist financing. This policy applies to all employees, contractors, and agents of SENDNOW PAYMENTS LTD.
Regulatory Framework
SENDNOW PAYMENTS LTD is a Money Services Business (MSB) registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations. We acknowledge our obligations to report suspicious transactions, keep accurate records, and implement internal controls to prevent money laundering and terrorist financing.
Risk Assessment
SENDNOW PAYMENTS LTD conducts an ongoing risk assessment to identify, understand, and mitigate the money laundering and terrorist financing risks associated with our operations. The risk assessment includes factors such as customer profiles, transaction patterns, and geographic locations. We regularly review and update the risk assessment to ensure its accuracy and effectiveness.
Risk Customer Due Diligence (CDD)
Customer Identification We perform robust customer identification procedures when establishing a business relationship or conducting occasional transactions. Our CDD measures include verifying the identity of individuals and businesses using reliable and independent sources of information, such as government-issued identification documents, utility bills, and beneficial ownership information.
Enhanced Due Diligence (EDD) For customers presenting a higher risk, based on our risk assessment, we implement enhanced due diligence measures. EDD includes obtaining additional information, conducting ongoing monitoring, and seeking senior management approval for higher-risk relationships. Examples of higher-risk factors include politically exposed persons (PEPs), high-value transactions, or customers from high-risk jurisdictions.
Ongoing Monitoring We continuously monitor customer transactions to detect and report any suspicious or unusual activities. This includes monitoring transaction patterns, account behaviour, and changes in customer activity. Our monitoring procedures enable us to promptly identify and report suspicious transactions to FINTRAC.
Reporting Obligations
SENDNOW PAYMENTS LTD is committed to fulfilling its reporting obligations as required by the PCMLTFA and its associated regulations. We maintain systems and processes to identify and report suspicious transactions, large cash transactions, and terrorist property to FINTRAC within the specified time frames. Our employees receive appropriate training to recognize and report suspicious activities effectively.
Record-Keeping
We maintain accurate and up-to-date records of customer information, transactions, and other relevant documentation as required by the PCMLTFA and its associated regulations. Records are securely stored and readily accessible for audit, inspection, or reporting purposes.
Training and Awareness
We provide regular AML and CFT training to our employees to ensure they understand their obligations and responsibilities. Training covers topics such as recognizing suspicious transactions, reporting requirements, and maintaining customer due diligence records. We also promote a culture of awareness and vigilance regarding AML and CFT issues throughout the organization.
Compliance Officer
SENDNOW PAYMENTS LTD designates a Compliance Officer responsible for overseeing the implementation of this AML Policy. The Compliance Officer ensures compliance with all applicable AML and CFT laws, regulations, and guidelines. They are also responsible for reporting any AML or CFT concerns or deficiencies to senior management and taking appropriate remedial actions.
Internal Controls and Audit
We have established internal controls and procedures to assess and mitigate the risks of money laundering and terrorist financing. These controls are regularly reviewed and updated to ensure their effectiveness. Additionally, we conduct periodic internal audits to assess the implementation of our AML and CFT measures, identify any gaps or weaknesses, and take corrective actions promptly.
Non-Retaliation
SENDNOW PAYMENTS LTD prohibits retaliation against any employee who reports concerns, suspicions, or violations of this AML Policy. We encourage open communication and provide channels for employees to report such matters without fear of reprisal.
Cooperation with Authorities
We cooperate fully with law enforcement agencies, regulatory authorities, and FINTRAC in their investigations or inquiries related to money laundering, terrorist financing, or any other criminal activities. We provide timely and accurate information as required by law.
Updates and Communication
SENDNOW PAYMENTS LTD regularly reviews and updates this AML Policy to ensure its compliance with evolving laws, regulations, and best practices. We communicate any changes or updates to employees and provide appropriate training to ensure understanding and adherence.
Conclusion
By implementing and adhering to this AML Policy, SENDNOW PAYMENTS LTD demonstrates its commitment to preventing money laundering and terrorist financing in accordance with Canadian laws and regulations. We continuously strive to maintain effective controls, conduct thorough due diligence, and foster a culture of compliance and vigilance throughout our organization. If you have any questions or concerns regarding our AML Policy, please contact us by email: support@sendnow.moneyour Compliance Officer.