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

INDEX

1. Introduction to the Policy and Objectives
2. Definitions of Money Laundering and Terrorism Financing
3. Governance
4. Prevention Procedures
5. List of Applicable Laws, Regulations and International Legislation
6. Obligations
7. Compliance and Reporting
8. Commitment
9. Transaction Monitoring
10. Reporting of Suspicious Activity
11. Confidentiality of Information
12. External Reporting
13. Record Keeping
14. AML and CTF Training
15. Risk Assessment
16. Compliance Effectiveness Review Plan

1. Introduction to the Policy and Objectives

Sentvia Services Ltd (“Sentvia”) is a cryptocurrency payment processor, duly registered and authorized as a Money Services Business (MSB) under Canadian law. In accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and regulatory requirements enforced by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), Sentvia is licensed to offer a range of financial and virtual asset services. These include foreign exchange dealing, money transferring, payment service provider functions, and dealing in virtual currencies. Sentvia operates in full compliance with Canadian regulatory standards to ensure the secure and lawful facilitation of cryptocurrency-related transactions. Sentvia maintains a zero-tolerance approach to money laundering and terrorist financing activities and is committed to implementing and enforcing effective internal controls to counter such activities. It is the policy of Sentvia to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under local, national and international laws and its implementing regulations. The goals of Sentvia’s Money Laundering and Terrorism Financing Prevention Policy, its implementation procedures and measures are regulated in this Policy. Our AML and CTF policies, procedures, and internal controls are designed to ensure compliance with applicable Canadian legislation as well as relevant international standards. These will be regularly reviewed and updated to reflect changes in regulatory requirements and the evolution of our business operations.

This AML policy applies to all employees, directors, stakeholders 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. The Policy applies globally throughout the Sentvia Group, aligning with pertinent global standards and international guidelines. Each legal entity within the Sentvia Group may supplement this Policy with appendices to detail the implementation of additional relevant local rules and regulations. All employees and Associated Persons of Sentvia, irrespective of their department or job role, including consultants and contractors, are required to comply with this Policy.

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 designated the Chief Compliance Officer (CCO) as its Anti- Money Laundering Compliance Officer. The CCO is  responsible for developing, implementing, and enforcing Sentvia’s AML/CTF policy. The CCO 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 CCO 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 CCOis vested with full responsibility and authority to enforce Sentvia’s AML program.

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 of suspicious transactions and termination thereof.
• 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:

• Law on the Prevention of Money Laundering and Terrorist Financing of the Canada
• Law on the Implementation of Economic and other International Sanctions of the Canada
• Proceeds of Crime (Money Laundering) and Terrorist Financing Act
• Resolution of the Government of the Canada "On the approval of the list of criteria for regarding a customer as causing a low risk of money laundering and/or terrorist financing and of criteria for determining the existence of a high risk of money laundering and/or terrorist financing and of the rules to identify the Customer and the beneficiary as well as several interrelated monetary operations and on the establishment of a procedure for providing information about the noticed evidence of potential money laundering and/or terrorist financing, violations of the Law on the Prevention of Money Laundering and Terrorist Financing of the Canada and sanctions taken against offenders”.
• Resolution of the Government of the Canada "On the approval of the list of criteria on the basis whereof a monetary operation or transaction is considered suspicious or unusual and of the practice statement for suspending suspicious monetary operations and transactions and submitting information about the suspicious or unusual monetary operations or transactions to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)".
• Resolution of the Government of the Canada "On the approval of the rules for keeping the register of suspicious or unusual monetary operations and transactions of the customer and identification of the criterion that characterises large-scale permanent and regular monetary operations".
• 5th and 6th EU Anti-Money Laundering Directives (AMLD5 and AMLD6), 
• Guidance from the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
• The FATF Standards: FATF Recommendations (November 2023)
• Canada’s AML/ATF Regime Strategy (2023–2026)
• FATF Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (October 2021)

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 and any underlying procedures may result in personal liability, such as fines and imprisonment, as well as  internal disciplinary measures   from an internal warning up to and including employment termination for employees and termination of the relationship for relevant third parties. In addition, it may expose Sentvia to civil and criminal liability, fines, reputational damage, operational risk, and other serious consequences.

Any circumvention of this policy is absolutely prohibited.  Any deviation from this policy must be approved by the AML Compliance Officer and appropriately documented. Sentvia expects all employees and Associated Persons to report any violation or suspected violation of this policy, as well as suspected financial crime or potentially suspicious activity to the Chief Legal Risk Compliance Officer (CLRCO) or the respective local Money Laundering Reporting Officer (MLRO). Material breaches, including, but not limited to situations in which a regulatory requirement has not been met, must also be reported to the MLRO for further review.

8. Commitment

By fostering a culture of compliance and vigilance, Sentvia reinforces its commitment to upholding the highest standards of integrity and responsibility, to minimize risks to both individuals and the organization as a whole.

9. Transaction Monitoring

Acting in compliance with the international and national requirements regulating the prevention of money laundering and terrorist financing, Sentvia follows the Know Your Transaction (KYT) principle.  Therefore, Sentvia’s request to provide information should be considered as a routine process that applies to all customers.  

Sentvia utilises a multilayered transaction screening framework, a Transactions Monitoring Program called “Elliptic”.  The program shall, on a risk score analytic approach, screen for the applicable red flags and assign a risk score accordingly. The Compliance Team will perform the necessary analysis of the alerted account’s information, including associated transactions, to determine if any unusual or suspicious activity was observed.

10. Reporting of Suspicious Activity

A suspicious activity can be defined as any action or activity which may result in the belief or knowledge that a customer is involved or planning to be involved in a crime or some other type of dishonest behavior. Sentvia requires all its employees, irrespective of their location, grade, or function, who know, suspect, or have reasonable grounds for knowing or suspecting that a person (whether a customer or an employee) is engaged in money laundering, terrorist financing, or other form of financial crime to escalate the matter immediately to the Money Laundering Reporting Officer (MLRO). Failure to report will lead to serious consequences for the employee and Sentvia.

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 as soon as practically possible.

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. AML and CTF Training

Risk Assessment identifies and measures the risks of money laundering and terrorist financing that Sentvia may face, ensuring appropriate controls are applied.

Sentvia conducts an annual risk assessment to evaluate the specific risks of money laundering and terrorist financing that the Company faces. The assessment considers factors such as:

• Nature and size of business operations
• Types of products and services offered
• Delivery channels used (e.g., online onboarding)
• Geographic locations of customers and transactions
• Characteristics of customer base (e.g., PEPs, high-risk countries)

Risk categories are rated as High, Medium, or Low, with corresponding mitigation measures implemented.

The findings are documented in a written Risk Assessment Report, which is reviewed by senior management and updated annually or when significant changes occur.

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16. Compliance Effectiveness Review Plan

Compliance Effectiveness Review Plan is a scheduled process that checks whether Sentvia's Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) program is working as required by Canadian law. The review will evaluate policies, procedures, training, transaction monitoring, record-keeping, and risk assessments.

Reviews are conducted at least every two years and include identifying any weaknesses and correcting them to keep the compliance program strong and up to date.
Sentvia will conduct a compliance effectiveness review at least once every two years or more frequently based on changes in regulations, business model, or identified deficiencies.

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The Compliance Effectiveness Review will::

• Evaluate the adequacy and effectiveness of AML/CTF policies, procedures, and controls
• Test reporting accuracy to FINTRAC (e.g., STRs, LCTRs, LVCTRs, EFTRs)
• Assess the quality and frequency of AML training
• Review transaction monitoring processes and technology
• Confirm the maintenance of accurate and complete records
• Verify Risk Assessment updates

The review will be conducted by an independent internal resource or an external consultant with AML/CTF expertise. Findings will be reported to senior management, with remedial action plans developed and tracked to resolution.

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