AML & COMPLIANCE POLICY

Chez Remit’s Anti Money Laundering, Counter terrorism and compliance Policy

As a money service business, we are subject to the following FINTRAC regulations and as such, our compliance policy aligns with the statutes of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations.

1.0 Compliance Officer

ChezRemit would employ a compliance officer to implement the compliance program and ensure that the companies’ business operations adheres to requisite FINTRAC regulations and related acts.

This individual would be saddled with the following responsibilities.

• Conduct risk assessment of the business activities and relationships
• Ensure that the compliance and risk assessment procedures are updated promptly to meet changing legislation and industry standards.
• Ensure that the organization and its staff adheres to the written compliance policies
• Prepare reports and Liaise with FINTRAC and other regulatory bodies
• Organize compliance trainings for staff, agents and other responsible officers / parties.
• Conduct Bi-annual review of the compliance program to test the effectiveness of policies and procedures, ongoing training and risk assessment.
• Ensure adequate documentation of the compliance process.

In order to be able to discharge these responsibilities, the compliance officer would be availed the necessary authority and access to resources in order to implement an effective compliance program and make any desired changes; and would possess knowledge of ChezRemit’s functions and structure; ML/TF risks and vulnerabilities as well as ML/TF trends and typologies and the sector's legal requirements under the PCMLTFA and associated Regulations.

2.0 Risk Assessment

ChezRemit Ltd would assess its relationships with its respective clients and classify such relationships as either Low risk, or High risk in regards to the possibility of a client committing Money laundering or Terrorist Financing.

The entire process would consist of the following activities:

• Client profiling
• Risk assessment
• Client identification controls & validations
• Transaction aggregation thresholds
• Government reporting controls & validations
• Possible structuring reporting
• Enhanced due diligence reporting

Depending on the risk classification of the client, varying actions would be undertaken to mitigate the risks that could emanate from such business relationships.

2.1 Risk Classification

2.1.1 High Risk: These are client relationships / transactions that are deemed to possess a greater possibility for money laundering and terrorist financing. The following transactions/ relationship types would be classified as high risk.

• Suspicious Transactions – These are transactions that appears unusual or presents some indicators that suggest acts to conceal money laundering and terrorist financing. To find more on suspicious transactions indicators, please refer to section 4.0
• Political exposed persons – Political office holders and immediate family members of political exposed persons would be classified as high risk as such individuals pose a greater risk of money laundering.
• Transfers made to certain countries / regions with high level of terrorist activities.

For such client relationships/ transactions classified as high risk, the following enhanced procedures would be taken.

• a. A report would be sent to FINTRAC (if required by the regulatory body)
• b. Customer would be requested to provide a valid means of identification (if this is not already provided)
• c. Enhanced monitoring would be conducted on this account
• d. An internal investigation would be conducted on the business relationship / transaction
• e. Upon observing that the client has broken any statute in either Canada, or any other related jurisdiction, the clients account could be closed after conclusion of investigation.

2.1.2 Low Risk: These are transactions that are deemed low risk, hence, reduced monitoring would be practiced with such an account.

Note: A low risk account could become a high risk account if it’s assessed to pose more risk (vice versa). Hence, would be subject to enhanced scrutiny.

3.0 Know your Customer

Prior to establishing a business relationship with a client, ChezRemit Ltd will request for requisite information / identification from a customer. Such would assist in ensuring that we are able to properly assess the risks associated with having a relationship with the customer.

We keep all client, transaction and corporate records for a minimum of 5 years.

3.1 Third Party Determination

If you are conducting a transaction on someone else's behalf, we are required to obtain information on the both parties: you and the person on whose behalf you are conducting the transaction.

4.0 Record keeping requirements

In line with regulatory requirements in Canada, we are mandated to keep the following information

1. Suspicious transaction report records: The following transactions are classified as suspicious transaction by ChezRemit Ltd.

• Customers performing transactions slightly below the $10,000 limit to avoid the transaction being reported to FINTRAC.
• Customer requests a transaction at a foreign exchange rate that exceeds the posted rate.
• Customer wants to pay transaction fees that exceed the posted fees.
• Customer exchanges currency and requests the largest possible denomination bills in a foreign currency.
• Customer knows little about address and contact details for payee, is reluctant to disclose this information, or requests a bearer instrument.
• Customer wants a cheque issued in the same currency to replace the one being cashed.
• Customer wants cash converted to a cheque and you are not normally involved in issuing cheques.
• Customer wants to exchange cash for numerous postal money orders in small amounts for numerous other parties.
• Customer enters into transactions with counter parties in locations that are unusual for the customer.
• Customer instructs that funds are to be picked up by a third party on behalf of the payee.
• Customer makes large purchases of traveler’s cheques not consistent with known travel plans.
• Customer makes purchases of money orders in large volumes.
• Customer requests numerous cheques in small amounts and various names, which total the amount of the exchange.
• Customer requests that a cheque or money order be made out to the bearer.
• Customer requests that a large amount of foreign currency be exchanged to another foreign currency.
• Customer purchases a large volume of money orders and changes payment type to avoid reporting requirements
• Any other transaction deemed to be suspicious by the Chief compliance officer.

2. Large cash transaction records ($10,000 and above)

3. Records for transactions of $3,000 or more

• a. If we receive $3,000 or more for the issuance of traveler’s cheques, money orders or other similar negotiable instruments
• b. If we cash $3,000 or more in money orders

4. Records of remitting or transmitting funds of $1,000 or more

5. Foreign currency exchange records

6. Internal memorandum received or created in the normal course of business

7. Records about ongoing service agreements

8. Reasonable measures records

5.0 Transaction reporting requirements

We report the following transactions to FINTRAC:

• Suspicious transactions
• Terrorist property
• Large cash transactions ($10,000 or above)
• Electronic funds transfers ($10,000 or above)

ADDITIONAL MEASURES WE TAKE TO PREVENT MONEY LAUNDERING AND TERRORIST FINANCING:

SCANNING AGAINST THE OSFI & OFAC WATCH LIST

It is our policy to check each transaction against the OSFI and OFAC watch lists. Any matched names are subject to further review by the compliance officer.