Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy

1. Introduction to the Policy and Objectives

Sentvia Services Ltd ("Sentvia") is a cryptocurrency payment processor registered as a Money Services Business ("MSB") in Canada. Sentvia operates in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA") and applicable regulations and guidance issued by the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC").

Sentvia is committed to preventing its products and services from being used for money laundering, terrorist financing, or other financial crime. The Company maintains a zero-tolerance approach to such activity and has implemented a risk-based AML/CTF compliance framework designed to identify, mitigate, and manage financial crime risks in line with Canadian regulatory requirements and international standards.

This Policy sets out Sentvia's high-level AML/CTF principles and does not disclose confidential operational procedures or security controls.

This AML policy applies to all employees, directors, officers, contractors, and associated persons as well as customers who have participated in the mandatory onboarding process. By adhering to this policy, Sentvia ensures that its services are not exploited for illicit activities and maintain the highest standards of integrity and compliance.

2. Definitions of Money Laundering and Terrorism Financing

Money laundering is the process of disguising or concealing the true origins and ownership of the proceeds from criminal activities, so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets, thereby avoiding prosecution, conviction and confiscation of criminal funds. In Canada, money laundering is defined as the intentional act of:

  • Converting or transferring property derived from criminal activity to conceal its origin;
  • Concealing or disguising the true nature of property derived from criminal activity;
  • Acquiring, possessing, or using property derived from criminal activity;
  • Aiding and abetting in the commission of any of the above activities.

Terrorist Financing is the act of providing financial support to terrorist organizations or terrorists and involves the solicitation, collection, or provision of funds with the intention that they may be used to support terrorist acts or organizations. Funds may stem from both legal and illicit sources.

Financing of Terrorism is when a person intentionally commits any of the following:

  • Any acts above mentioned if they are aware that the proceeds are wholly or partly owned by an organization or person involved in an act of terrorism.
  • Providing or collecting, preparing or obtaining proceeds or facilitating their obtainment with the intent to use them or knowing that such proceeds will be used wholly or partly in an act of terrorism.

3. Governance

Sentvia has a designated Money Laundering Reporting Officer (MLRO). The MLRO is responsible for developing, implementing, and enforcing Sentvia's AML/CTF policy. The MLRO will monitor Sentvia's compliance with AML obligations, overseeing communication and training for employees, and participation of all employees in implementation of the established prevention measures. The MLRO will also ensure that the firm keeps and maintains all of the required AML records and will ensure that Suspicious Activity Reports (SARs) are filed with the relevant statutory authorities when appropriate. The MLRO has primary responsibility for overseeing the implementation and effectiveness of Sentvia's AML/CTF framework and reports material matters to senior management in accordance with Sentvia's governance arrangements.

4. Prevention Procedures

Sentvia implements a layered AML prevention framework based on a risk-based approach. The main money laundering and terrorism financing prevention procedures are as follows:

  • Know Your Customer procedures;
  • Customer Identification;
  • Monitoring of the financial transactions performed by Customers;
  • Identification and escalation of unusual or suspicious transactions;
  • Keeping of information about transactions performed by Customers;
  • Providing timely information and training to Sentvia staff;
  • Internal Controls

5. List of Applicable Laws, Regulations and International Legislation

This AML policy is in compliance with the following laws and international standards:

  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
  • Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR)
  • Guidance, directives, and policy interpretations issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
  • Financial Action Task Force (FATF) Recommendations, including guidance relevant to virtual assets and virtual asset service providers

Where Sentvia operates or expands into additional jurisdictions, this Policy may be supplemented by jurisdiction-specific procedures to address local regulatory requirements.

6. Obligations

Sentvia, along with its employees and associated persons, is obligated to comply with the Global Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy, as well as the laws and regulations that support it.

7. Compliance and Reporting

Failure to comply with this Policy or applicable AML/CTF procedures may result in internal disciplinary action, up to and including termination of employment or contractual relationships, and may expose individuals and Sentvia to regulatory, civil, or criminal consequences under applicable law.

Any attempt to circumvent this Policy is strictly prohibited. All employees and associated persons are required to promptly report any actual or suspected breach of this Policy, as well as any suspected money laundering, terrorist financing, or other financial crime concerns, to the Money Laundering Reporting Officer (MLRO) or an appropriately designated compliance representative.

Material breaches, including instances where regulatory requirements may not have been met, are escalated to the MLRO for review, assessment, and, where necessary, further action in accordance with Sentvia's internal compliance procedures.

8. Commitment

Sentvia is committed to maintaining high standards of integrity, transparency, and regulatory compliance. Through continuous risk assessment, strong governance, and a culture of compliance, Sentvia seeks to protect its customers, counterparties, and the financial system from abuse.

9. Transaction Monitoring

Sentvia applies a risk-based transaction monitoring framework in accordance with applicable Canadian anti-money laundering and counter-terrorist financing legislation, regulatory guidance, and relevant international standards. In line with the Know Your Transaction (KYT) principle, Sentvia monitors customer activity on an ongoing basis to identify unusual or potentially suspicious behavior.

Transaction monitoring applies to all customers, products, services, delivery channels, and transaction types. Requests for additional information or clarification from customers form part of Sentvia's routine compliance processes and are conducted proportionately based on the assessed risk of the customer or activity.

Sentvia maintains a multi-layered transaction monitoring framework that combines automated monitoring tools and manual review processes. Monitoring measures are designed to identify indicators of potential money laundering, terrorist financing, sanctions breaches, or other financial crime risks, including but not limited to:

  • Unusual transaction patterns or volumes
  • Activity inconsistent with a customer's known profile or expected behavior
  • Exposure to higher-risk jurisdictions, counterparties, or typologies
  • Structuring, layering, or other behavior indicative of financial crime risks

Alerts generated through transaction monitoring systems are subject to review by the Compliance function. The review process includes an assessment of relevant contextual information, such as customer risk profile, transactional history, and supporting documentation, to determine whether the activity is reasonable or warrants further escalation.

Where activity cannot be reasonably explained or presents indicators of suspicion, the matter is escalated in accordance with Sentvia's internal escalation and reporting procedures. Appropriate actions may include enhanced monitoring, requests for additional information, restriction of activity, or reporting to the relevant authorities, as required by law.

Sentvia periodically reviews and enhances its transaction monitoring framework to ensure it remains effective, proportionate, and aligned with regulatory expectations, emerging risks, and the evolving nature of its products and services.

10. Reporting of Suspicious Activity

Suspicious activity refers to any conduct or transaction that gives rise to a knowledge, suspicion, or reasonable grounds to suspect that funds or activity are related to money laundering, terrorist financing, or other financial crime. All employees and associated persons of Sentvia, regardless of role, seniority, or location, are required to promptly escalate any such knowledge or suspicion to the Money Laundering Reporting Officer (MLRO) in accordance with Sentvia's internal reporting procedures. Failure to comply with these reporting obligations may result in internal disciplinary action and may expose individuals and Sentvia to regulatory or legal consequences under applicable law.

11. Confidentiality of Information

Employees must follow any instructions given to them regarding the disclosure that they have made and must not make any further investigation themselves. Sentvia is prohibited from disclosing that we have escalated suspicious activity, or that any report, internal or external, is filed to any person except the MLRO as violations of this principle may prejudice the investigation.

12. External Reporting

Following the escalation, the MLRO will evaluate the activity and determine if there are sufficient grounds to file an external report. Where sufficient grounds exist, the MLRO in the relevant jurisdiction will submit an external report to the local financial intelligence unit without delay, in accordance with applicable legal requirements.

13. Record Keeping

A record will be kept of any internal reports submitted to the MLRO that have not been externally filed, including details of any action taken. Similarly, for all externally filed reports, Sentvia will keep records, including any inquiries in respect to disclosures, and any communication that has been sent and received in relation to the submitted report. Records of internal and external reports, related communications, and any actions taken will be securely stored and maintained in compliance with Canadian law.

14. AML and CTF Training

Training on the AML / CTF regulations and guidelines is an important aspect of the tools to identify any risks in this space. Training is to ensure a consistent approach to periodically assessing AML training needs, delivering, tracking, documenting and reporting on training results.

Business managers, the first line of defense, are primarily responsible for understanding and assessing key risks and effective implementation and ongoing operation of internal controls. Compliance, as a second line of defense control function, provides independent oversight of adherence to AML laws and regulations.

The Firm will take reasonable care to provide appropriate anti-money laundering training for its staff who handle, or are managerially responsible for the handling of, transactions which may involve money laundering.

Training will be conducted at the following frequencies:

  • Induction training for all new joiners
  • Refresher training (at least annually) for all staff
  • Key revisions training (at every key revision impacting the AML operations)

15. Risk Assessment

Sentvia maintains a documented risk assessment process to identify, assess, and manage the risks of money laundering and terrorist financing associated with its business activities. This process supports the application of proportionate and effective AML/CTF controls in line with applicable Canadian legal and regulatory requirements.

An enterprise-wide risk assessment is conducted at least annually to evaluate Sentvia's exposure to money laundering and terrorist financing risks. The assessment considers, among other factors:

  • The nature, scale, and complexity of business operations
  • The products and services offered
  • Delivery channels and onboarding methods, including digital processes
  • Geographic exposure relating to customers, counterparties, and transactions
  • Characteristics of the customer base, including elevated risk factors

Identified risks are categorised using defined risk levels, with appropriate mitigation measures applied in accordance with Sentvia's risk-based AML/CTF framework.

The outcomes of the risk assessment are documented in a written report, reviewed by senior management, and updated at least annually or more frequently where material changes to the business, regulatory environment, or risk profile occur.

16. Compliance Effectiveness Review Plan

Sentvia maintains a Compliance Effectiveness Review process designed to assess whether its Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) framework is operating effectively and in accordance with applicable Canadian legal and regulatory requirements.

The Compliance Effectiveness Review evaluates the design and effectiveness of Sentvia's AML/CTF policies, procedures, and controls, including governance arrangements, transaction monitoring, reporting processes, record-keeping practices, training programs, and enterprise-wide risk assessment activities.

Reviews are conducted at least every two years, and more frequently where warranted due to regulatory developments, changes to Sentvia's business model, or the identification of material deficiencies or emerging risks.

As part of the review process, Sentvia assesses, on a risk-based basis:

  • The adequacy and effectiveness of AML/CTF policies, procedures, and internal controls
  • Compliance with applicable reporting obligations to FINTRAC
  • The quality, scope, and frequency of AML/CTF training
  • The effectiveness of transaction monitoring and escalation processes
  • The accuracy, completeness, and retention of required records
  • The ongoing relevance and update of the enterprise-wide risk assessment

Compliance Effectiveness Reviews are performed by an independent internal function or a suitably qualified external party with appropriate AML/CTF expertise. Findings and recommendations are documented and reported to senior management, and appropriate remediation actions are implemented and monitored to completion.