Complaint Handling Policy
Sentvia Services Ltd - 06/08/2025
1. Background
This policy sets out the procedures by which Sentvia Services Ltd ("Sentvia") receives, investigates, resolves, and monitors complaints from clients and other stakeholders.
It ensures compliance with:
- the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC guidance;
- the Retail Payment Activities Act (RPAA) and associated RPAR regulations;
- the Personal Information Protection and Electronic Documents Act (PIPEDA); and
- applicable consumer protection legislation.
The objective is to handle every complaint transparently, consistently, and fairly, while protecting client rights and maintaining confidence in Sentvia's operations.
2. Scope
This policy applies to:
- all employees, agents, and contractors of Sentvia;
- all departments and business lines, including compliance, operations, customer service, finance, and technology;
- all services offered to clients, including account onboarding, payment execution, currency conversion, fund transfers, technical support, and account management; and
- all individuals or entities who interact with Sentvia as clients, prospective clients, regulators, partners, or members of the public.
3. Definitions
| Term | Definition |
|---|---|
| Complaint | Any expression of dissatisfaction, whether written, verbal, or digital, made by a client or stakeholder regarding a service, action, inaction, or conduct of Sentvia or its personnel, where a response or resolution is explicitly or implicitly expected. |
| Complainant | The person or entity lodging the complaint. Includes current or former clients, their authorised representatives, and affected third parties such as beneficiaries or business partners. |
| Resolution | The final decision or action taken to address a complaint. May include a refund, explanation, service correction, apology, policy clarification, or referral to an external body. |
| Escalation | The process of forwarding a complaint to a higher authority within Sentvia (e.g., the MLRO) or to an external regulatory body where the complainant is not satisfied with the initial outcome. |
| MLRO | Money Laundering Reporting Officer. The designated officer responsible for AML/CFT compliance and regulatory reporting at Sentvia. |
Examples of Complaints
Complaints may include, but are not limited to:
- alleged financial loss resulting from services provided;
- delays in processing fiat or virtual currency transactions;
- access issues or account restrictions;
- technical errors on the platform;
- concerns about the application of AML/KYC policies;
- perceived unfair treatment, negligence, or misconduct by staff;
- privacy breaches, data security concerns, or confidentiality failures; and
- disagreement with internal decisions such as account freezes or service denials.
4. Submitting a Complaint
Complaints can be submitted by email to support@sentvia.com.
To allow a prompt and thorough investigation, the complainant should include:
- full legal name and preferred contact details;
- a clear description of the issue and the relevant dates;
- transaction IDs, account numbers, or reference codes where applicable; and
- any supporting evidence (e.g., screenshots, emails, communications).
5. Complaint Handling Procedure
Step 1: Acknowledgement
- The complaint is logged in the Complaint Register within 1 business day of receipt.
- An acknowledgement is sent to the complainant within 5 business days, including a unique reference number and an estimated resolution timeline.
Step 2: Investigation
- The complaint is assigned to a qualified investigator or compliance officer.
- All relevant documentation, communications, and internal system records are reviewed.
- The complainant may be contacted for further information or clarification.
- Sensitive or high-risk complaints (including any with potential AML/fraud implications) are escalated immediately to the MLRO.
Step 3: Resolution
Sentvia targets the following resolution timeframes:
| Complaint Type | Target Resolution Timeframe |
|---|---|
| Transaction-related complaints | 10 business days from acknowledgement |
| All other complaints | 20 business days from acknowledgement |
Written resolution is provided to the complainant and includes:
- a summary of the issue and findings;
- any remedial actions taken or the rationale for the decision; and
- next steps or escalation options.
Where resolution requires additional time, an interim update is provided before the target deadline.
Step 4: Escalation
If the complainant is not satisfied with the outcome, they may escalate the matter as follows:
| Stage | Escalation Route | When to Use |
|---|---|---|
| Internal escalation | Money Laundering Reporting Officer (MLRO) | Where the complainant is not satisfied with the initial resolution, or where the complaint raises AML/CFT, fraud, or regulatory concerns. |
| Regulatory escalation | FINTRAC, the Office of the Privacy Commissioner of Canada, or the applicable provincial/territorial consumer protection authority | Where internal escalation has not produced a satisfactory outcome, or where the complaint concerns regulatory compliance. |
| Legal / Ombudsman | Applicable ombudsman service or legal counsel | Where regulatory channels have been exhausted or the matter involves potential legal liability. |
6. Recordkeeping
All complaints and related documentation are retained for a minimum of 6 years, in line with PCMLTFA recordkeeping requirements.
The Compliance Department maintains a centralised Complaint Register. Each entry records:
- date received and date acknowledged;
- complainant details and contact information;
- nature and category of the complaint;
- all actions taken and internal communications;
- resolution outcome and date closed; and
- any regulatory referrals or escalations made.
7. Roles and Responsibilities
| Role | Responsibilities |
|---|---|
| Customer Support/Sales | Initial receipt, logging, and acknowledgement. Handles straightforward service-level complaints or escalates to Compliance. |
| Compliance Officer | Conducts detailed investigations, documents findings, ensures regulatory compliance, and prepares written resolutions. |
| MLRO | Handles all escalated complaints, approves high-risk resolutions, and reports to regulators (including FINTRAC) where required. Final internal authority on complaint outcomes. |
| Executive Management | Reviews quarterly complaint reports, identifies trends and systemic risks, and approves structural improvements. |
8. Privacy and Confidentiality
All complaint-related information is treated as strictly confidential and handled in accordance with PIPEDA and Sentvia's internal privacy protocols.
Access to complaint records is restricted to staff with a legitimate need to know. Personal information is encrypted at rest and in transit, and will not be shared with third parties unless legally required or where the complainant has given explicit consent.
9. Training and Awareness
All staff must complete mandatory training on this policy during onboarding and annually thereafter. Training is delivered through recognised institutions and covers:
- identifying and categorising complaints;
- intake, recording, and escalation procedures;
- communication standards and handling sensitive situations; and
- data protection and regulatory reporting obligations.
Completion of training is tracked by the Compliance Department. Staff who do not complete required training within the specified window are escalated to their line manager and the MLRO.
10. Monitoring and Review
Complaints are reviewed on a quarterly basis to identify trends, compliance gaps, or systemic risks. Root cause analysis is conducted on recurring issues.
This policy is reviewed at least annually by the MLRO, or immediately upon any regulatory change, material operational change, or instruction from FINTRAC or the Bank of Canada.