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AML commitment statement

STATEMENT

Money laundering and terrorist activity financing (ML/TF) pose significant risks to the stability and integrity of the Canadian and global financial systems. As a registered Money Services Business (“MSB”) in Canada, ZERO BOOST PAYMENTS CORP., Incorporation No BC1515420, at #250 - 997 Seymour St. Vancouver, BC, Canada V6B 3M1 (“COMPANY”) is subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“PCMLTFA”) and the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (“PCMLTFR”), and is supervised by the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”).

COMPANY is registered in FINTRAC as money service business under the No. C100000720 and is subject to AML regulations.

COMPANY recognizes its statutory obligation to detect, deter and prevent money laundering and terrorist financing and to report prescribed transactions and activities to FINTRAC. COMPANY has a duty to its customers, shareholders, employees and regulators to ensure that its products and services are not used to facilitate financial crime.

COMPANY is committed to identifying, assessing, detecting, deterring, and managing financial crime risks and to implementing proportionate, risk-based measures to address these risks across all jurisdictions in which it operates, in accordance with Canadian AML/ATF legislation and FINTRAC guidance.

RISK APPETITE

COMPANY maintains a zero-tolerance approach to deliberate or wilful non-compliance with AML/ATF laws and to knowingly facilitating financial crime.

COMPANY will not tolerate:

  1. Failure to take reasonable and prescribed steps to verify the identity of customers, beneficial owners, authorized persons and other relevant parties in accordance with PCMLTFR requirements;
  2. Knowingly accepting funds from, or engaging in business relationships where there are reasonable grounds to suspect that property is the proceeds of crime or related to terrorist activity financing;
  3. Failure to conduct ongoing monitoring of business relationships and transactions, as required under Canadian AML/ATF legislation;
  4. Failure to investigate and assess indicators that funds or transactions may be linked to money laundering, terrorist activity financing or sanctions evasion;
  5. Onboarding or maintaining relationships with customers who provide false, altered, misleading, incomplete or inconsistent information;
  6. Failure to submit required reports to FINTRAC, including Suspicious Transaction Reports (STRs), Large Cash Transaction Reports (LCTRs), Electronic Funds Transfer Reports (EFTRs), Terrorist Property Reports, or other prescribed reports within the statutory timeframes;
  7. Establishing or maintaining relationships, offering products or services, or executing transactions involving individuals or entities subject to Canadian sanctions or terrorist listings under applicable legislation.

COMPANY applies a documented, risk-based approach consistent with FINTRAC expectations and Canadian regulatory requirements.

AML COMPLIANCE FRAMEWORK

In accordance with section 9.6 of the PCMLTFA and Part 1.1 of the PCMLTFR, COMPANY maintains a comprehensive written compliance program appropriate to its size, nature and complexity as an MSB.

COMPANY’s AML/ATF compliance framework includes, at a minimum, the following mandatory elements:

  1. Written Compliance Policies and Procedures
    Documented policies and procedures that are kept up to date and approved by senior management, addressing all applicable legislative and regulatory requirements.

  2. Risk Assessment
    A documented assessment of inherent and residual money laundering and terrorist financing risks, considering:

    1. Clients and business relationships;

    2. Products, services and delivery channels;

    3. Geographic exposure;

    4. Other relevant risk factors identified by FINTRAC.

The risk assessment is reviewed periodically and updated when material changes occur.

  1. Risk Mitigation Measures
    Development and implementation of risk mitigation controls proportionate to the identified level of risk, including enhanced measures where higher risk is identified.

  2. Compliance Officer
    Appointment of a designated Compliance Officer with the authority and resources necessary to implement and oversee the AML/ATF compliance program.

  3. Ongoing Compliance Training
    A documented training program for employees and agents, tailored to their roles and responsibilities, conducted at least annually and updated as necessary.

  4. Effectiveness Review
    A biennial (at minimum) independent review of the compliance program to test its effectiveness, with documented findings and remedial actions.

AML POLICY

COMPANY has developed and implemented a formal AML/ATF Policy designed to ensure compliance with the PCMLTFA, PCMLTFR, applicable sanctions legislation, and FINTRAC guidance, and to safeguard COMPANY from being used to facilitate financial crime.

COMPANY’s AML Policy:

  1. Promotes strong governance, accountability and effective ML/TF risk management;
  2. Establishes a documented risk-based approach consistent with Canadian AML/ATF legislation;
  3. Provides a structured framework for identifying, assessing, mitigating and monitoring ML/TF risks;
  4. Defines mandatory standards and controls applicable to COMPANY and its affiliates, employees and agents;
  5. Ensures compliance with statutory reporting, record-keeping, client identification and ongoing monitoring obligations;
  6. Establishes escalation, investigation and reporting procedures for suspicious or prescribed transactions;
  7. Provides clear allocation of roles and responsibilities, including those of senior management and the Compliance Officer.

CORE AML/ATF CONTROLS

COMPANY’s AML/ATF program includes, but is not limited to:

  1. Risk Management

  1. Risk identification, assessment, measurement and mitigation;

  2. Periodic reassessment of risk exposure;

  3. Oversight and governance controls.

  1. Client Due Diligence (CDD)

  1. Identity verification of individuals and entities in accordance with prescribed methods;

  2. Identification and verification of beneficial owners;

  3. Determination of third-party involvement;

  4. Politically Exposed Person (PEP), Head of International Organization (HIO), and close associate determinations;

  5. Sanctions screening in accordance with applicable Canadian legislation;

  6. Collection of purpose and intended nature of business relationship information;

  7. Ongoing monitoring of business relationships.

  1. Enhanced Measures

  1. Enhanced Due Diligence (EDD) for high-risk clients or transactions;

  2. Additional source of funds and source of wealth inquiries where required;

  3. Increased transaction monitoring and senior management approval where applicable.

  1. Ongoing Monitoring

  1. Continuous monitoring of transactions to detect suspicious activity;

  2. Periodic review and updating of client information;

  3. Identification of trigger events requiring additional due diligence.

  1. Reporting Obligations

  1. Suspicious Transaction Reports (STRs);

  2. Large Cash Transaction Reports (LCTRs);

  3. Electronic Funds Transfer Reports (EFTRs);

  4. Terrorist Property Reports;

  5. Other prescribed regulatory reports submitted to FINTRAC within statutory deadlines.

  1. Record Keeping

  1. Maintenance of required records for prescribed retention periods;

  2. Secure storage of records in compliance with Canadian regulatory requirements;

  3. Documentation of decision-making processes relating to risk assessments and reporting determinations.

  1. Third-Party Reliance and Outsourcing

  1. Due diligence on third-party service providers;

  2. Contractual controls to ensure compliance with AML/ATF obligations;

  3. Oversight mechanisms to monitor outsourced functions.

  1. Technology and Monitoring Tools

  1. IT solutions supporting identity verification;

  2. Automated transaction monitoring systems;

  3. Screening tools for sanctions, PEPs and adverse media;

  4. Model governance and testing controls to manage system risk.

  1. Governance and Personnel

  1. Appointment of a qualified Compliance Officer;

  2. Defined reporting lines to senior management;

  3. Clear delineation of roles and responsibilities across the organisation;

  4. Escalation procedures for potential ML/TF concerns.

SANCTIONS AND TERRORIST PROPERTY COMPLIANCE

COMPANY complies with applicable Canadian sanctions legislation, including measures implemented under the United Nations Act and the Special Economic Measures Act.

COMPANY maintains procedures to:

  1. Screen customers and transactions against applicable sanctions lists;

  2. Freeze property where legally required;

  3. Submit required terrorist property reports;

  4. Escalate potential sanctions matches for investigation.

CONTINUOUS IMPROVEMENT

COMPANY is committed to continuously reviewing and enhancing its AML/ATF compliance program to reflect:

  1. Legislative amendments;

  2. Updated FINTRAC guidance;

  3. Emerging ML/TF typologies;

  4. Internal audit findings;

  5. Industry best practices.

Senior management exercises oversight of the AML/ATF framework to ensure that it remains effective, proportionate and compliant with Canadian regulatory requirements.