AML Policy

Anti-Money Laundering and Counter-Terrorist Financing Policy of FOTIFY PAY INC

FOTIFY PAY INC (hereinafter referred to as ‘FOTIFY PAY INC’) is committed to combatting money laundering and terrorist financing and ensuring that products and services offered by FOTIFY PAY INC are not misused for such purposes, including other fraud-related activities. It is strictly prohibited to provide any product, service, or execute any transaction for the benefit of individuals or entities included in international sanctions lists. Adherence to applicable laws and regulations relating to the prevention of money laundering and terrorist financing (hereinafter referred to as ‘AML/CTF’) is mandatory and fundamental to FOTIFY PAY INC’s strategy and compliance program.

FOTIFY PAY INC maintains strict and transparent standards and continuously strengthens its processes to ensure compliance with applicable AML/CTF laws and regulations. FOTIFY PAY INC reserves the right to reject any customer, payment, or business relationship that does not comply with this AML/CTF Policy, subject to the requirements of applicable laws and regulations.

Adherence to Applicable AML/CTF Laws and Regulations

FOTIFY PAY INC complies with the following key AML/CTF frameworks:
– Canada: Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and regulations, under the supervision of FINTRAC.
– United Kingdom: Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), under the supervision of the FCA and NCA.
– European Union: EU Anti-Money Laundering Directives (AMLD5 and AMLD6) and oversight by national Financial Intelligence Units (FIUs).

Customers are required to provide accurate and complete information and documentation to verify their identity, including information on payers and payees for each transaction. FOTIFY PAY INC may request additional information where necessary.

Risk-Based Approach

FOTIFY PAY INC applies a risk-based approach (RBA) to AML/CTF compliance, including:
– Customer Due Diligence (CDD) for all clients.
– Enhanced Due Diligence (EDD) for high-risk clients, transactions, or jurisdictions (e.g., politically exposed persons, FATF high-risk countries).
– Simplified Due Diligence (SDD) where permitted by law for low-risk situations.
This ensures resources are focused proportionately on higher-risk areas.

Monitoring and Suspicious Activity Reporting

FOTIFY PAY INC conducts ongoing monitoring of customer activity and transactions to identify unusual or suspicious patterns. Suspicious transactions are reported in accordance with applicable laws to the relevant Financial Intelligence Unit (FIU):
– FINTRAC (Canada).
– National Crime Agency (UK).
– National FIUs in EU Member States.

If customers fail to provide sufficient information or documentation, or fail to respond in a timely manner, FOTIFY PAY INC reserves the right to reject or block transactions.

Prohibited Activities

FOTIFY PAY INC has zero tolerance for customers engaging in:
– Intentional or negligent breaches of AML/CTF laws and regulations.
– Repeated unintentional breaches of AML/CTF laws.
– Misusing accounts for money laundering, terrorism financing, fraud, or tax offences.
– Refusing to provide sufficient information or documentation to demonstrate compliance.

FOTIFY PAY INC will suspend or terminate business relationships with customers who fail to meet compliance standards.

Sanctions Compliance

FOTIFY PAY INC will not establish or maintain relationships with individuals or entities subject to international sanctions. This includes sanctions lists issued by:
– United Nations Security Council (UN).
– European Union (EU).
– United States Office of Foreign Assets Control (OFAC).
– United Kingdom HM Treasury Sanctions List.
– Any other applicable national or international sanctions lists.

Special attention is paid to entities and individuals from countries identified by the Financial Action Task Force (FATF) as high-risk or non-cooperative.

Record Keeping

FOTIFY PAY INC maintains records of customer identification, transaction data, and AML/CTF compliance activities for at least five (5) years following the termination of the business relationship, or longer where required by law.

Training and Governance

FOTIFY PAY INC provides regular AML/CTF training to employees to ensure awareness of obligations and procedures. A designated Compliance Officer (Money Laundering Reporting Officer, MLRO) is responsible for oversight of the AML/CTF program, including monitoring compliance, submitting suspicious activity reports, and acting as the main point of contact for regulatory authorities.

Contact Information

If you have questions regarding this AML/CTF Policy, please contact us at:

Email: [email protected]
FOTIFY PAY INC
Address: 329 Howe St PMB 2118, Vancouver, BC, Canada V6C 3N2
License: M23631101