AML/KYC Policy

FluxPay, a trade name of Ideation House Financial Services Limited (CBCA Corporation No. 1419582-5, FINTRAC MSB Registration No. M22512329), is committed to the highest standards of Anti-Money Laundering (AML), Know Your Customer (KYC), and Counter-Terrorist Financing (CTF) compliance. As a registered Money Services Business (MSB) with FINTRAC, we maintain comprehensive policies and procedures to detect and prevent financial crime.

Our registered MSB services include Foreign Exchange Dealing and Money Transferring.

FluxPay operates in compliance with the following Canadian federal legislation and regulations:

• Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
• Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR)
• FINTRAC Guidance and Directives
• Criminal Code of Canada (Part II.1 — Terrorism)
• United Nations Act (UNA)
• Special Economic Measures Act (SEMA)
• Justice for Victims of Corrupt Foreign Officials Act (JVCFOA)

3.1 Know Your Business (KYB) Procedures

Before onboarding any merchant, FluxPay conducts comprehensive due diligence:

• Verification of business registration and legal status
• Confirmation of Existence using the Confirmation of Existence Method as prescribed by FINTRAC
• Collection and verification of beneficial ownership information
• Assessment of the nature and purpose of the business relationship
• Verification of authorized signatories

3.2 Identity Verification

We verify the identity of all directors, officers, and beneficial owners through:

• Government-issued photo identification (passport, driver's license, or equivalent)
• Independent electronic verification methods
• Dual-process verification for high-risk relationships
• Ongoing verification as required by FINTRAC guidelines

3.3 Business Relationship Assessment

For each merchant relationship, we assess:

• Expected transaction volumes and patterns
• Geographic risk factors
• Industry and business model risk
• Source of funds and wealth where applicable

Enhanced measures are applied in higher-risk situations including:

4.1 High-Risk Business Categories

• Cannabis-related businesses (where legally permitted)
• iGaming and online gambling operators
• Money services businesses and payment facilitators
• Businesses operating in high-risk jurisdictions

4.2 Politically Exposed Persons (PEPs)

• Domestic and foreign PEPs, and heads of international organizations
• Family members and close associates of PEPs
• Enhanced ongoing monitoring for PEP relationships
• Senior management approval required for PEP relationships

4.3 High-Risk Jurisdictions

• Countries identified by FATF as having strategic deficiencies
• Jurisdictions subject to Canadian sanctions
• Countries with elevated corruption or terrorism financing risk

5.1 Transaction Monitoring

• Automated monitoring of all transactions for unusual patterns
• Risk-based thresholds calibrated to merchant profiles
• Real-time alerts for transactions exceeding prescribed thresholds
• Review of large cash transactions and electronic funds transfers

5.2 Business Relationship Review

• Periodic review of all merchant relationships
• Ongoing monitoring triggers per FINTRAC guidance (two or more transactions within a five-year period)
• Update of KYC documentation at regular intervals
• Reassessment of risk ratings based on transaction history

6.1 Reporting Obligations

FluxPay is required to file Suspicious Transaction Reports with FINTRAC when there are reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing.

6.2 Internal Reporting

• All employees must report suspicious activity to the Compliance Officer
• The Compliance Officer reviews and determines whether to file an STR with FINTRAC
• Reports are filed within the prescribed timeframe
• All reports are documented and retained in accordance with record-keeping requirements

FluxPay maintains all records as required by the PCMLTFA and PCMLTFR:

• Client identification records: minimum 5 years from date of last transaction
• Transaction records: minimum 5 years from date of transaction
• Suspicious transaction reports: minimum 5 years from filing date
• Large cash transaction reports and electronic funds transfer reports
• Compliance program documentation including policies, risk assessments, and training records

8.1 Screening Requirements

FluxPay screens all merchants and transactions against Canadian sanctions lists including:

• Criminal Code of Canada (Part II.1) listed entities
• United Nations Act (UNA) regulations
• Special Economic Measures Act (SEMA) regulations
• Justice for Victims of Corrupt Foreign Officials Act (JVCFOA) regulations
• Consolidated Canadian Autonomous Sanctions List

8.2 Screening Process

• Screening at onboarding and on an ongoing basis
• Real-time screening of transactions where applicable
• Immediate escalation of potential matches
• Prohibition of transactions involving sanctioned parties or jurisdictions

9.1 Training Program

• All employees receive AML/KYC/CTF training upon hiring
• Annual refresher training for all staff
• Specialized training for compliance and operations teams
• Training records maintained as required

9.2 Compliance Program Effectiveness Review

• Independent review of the compliance program every two years as required by PCMLTFA
• Assessment of policies, procedures, risk assessment methodology, and training
• Recommendations implemented and tracked
• Results reported to senior management