AML/KYC/POLICY PAGE

   AML/CTFCompliance Program

1. Introduction
1.1 Purpose

The purpose of Swiftier?s Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Compliance Program is to establish a comprehensive framework to prevent, detect, and report money laundering and terrorist financing activities. This program is designed to comply with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) regulations, international standards, and industry best practices, ensuring that Swiftier operates with the highest levels of compliance and integrity
1.2 Scope

This program applies to all Swiftier operations, employees, contractors, and third parties acting on behalf of the company. It encompasses all aspects of the business, including customer onboarding, transaction processing, monitoring, and reporting obligations to mitigate money laundering and terrorist financing risks.
2. AML/CTF Policies and Procedures
2.1 Customer Due Diligence (CDD) and Know Your Customer (KYC)

2.1.1 Customer Identification and Verification

? Swiftier will conduct rigorous customer identification and verification procedures before establishing a business relationship or processing any transactions.

? Acceptable forms of identification include government-issued photo identification, proof of residence, and, where applicable, proof of business registration or source of funds.

? All customer information will be verified against reliable, independent sources and recorded in a secure, auditable format.

2.1.2 Enhanced Due Diligence (EDD)

? For high-risk customers, such as politically exposed persons (PEPs), individuals from high-risk jurisdictions, or entities with complex ownership structures, Swiftier will implement Enhanced Due Diligence procedures.

? EDD measures include obtaining additional documentation, understanding the source of funds and wealth, and increased scrutiny of transactions.

? Ongoing monitoring will be conducted to detect any unusual activities that might indicate money laundering or terrorist financing.

2.1.3 Ongoing Monitoring and Review

? Continuous transaction monitoring will be conducted using an automated system designed to detect patterns indicative of suspicious activities.

? The system will flag high-risk transactions for manual review by compliance personnel.

? Regular reviews of customer risk profiles will be conducted to ensure they accurately reflect the risk presented by each customer.
2.2 Record-Keeping and Documentation

2.2.1 Retention of Records

? Swiftier will maintain detailed records of all transactions, customer identification, and communications for a minimum of five years following the date of the transaction or the termination of the business relationship.

? All records will be securely stored and protected against unauthorized access, ensuring compliance with FINTRAC requirements and privacy laws.

2.2.2 Documentation of Compliance Activities

? All compliance-related activities, including customer identification, transaction monitoring, and reporting, will be documented and reviewed periodically for accuracy and completeness.

? Detailed records of decision-making processes, actions taken, and communications will be maintained to support internal and external audits.
2.3 Reporting Obligations

2.3.1 Suspicious Transaction Reporting (STR)

? Employees must report any transaction or activity that raises suspicion of money laundering or terrorist financing to the Compliance Officer immediately

? The Compliance Officer will investigate all reports and, if warranted, file a Suspicious Transaction Report (STR) with FINTRAC within the specified timeframe.

2.3.2 Large Cash Transaction Reporting (LCTR)

? Any cash transactions of CAD 10,000 or more, whether in a single transaction or a series of related transactions, must be reported to FINTRAC within 15 days.

? Swiftier will have procedures in place to aggregate multiple transactions that might cumulatively exceed the reporting threshold.

2.3.3 Terrorist Property Reporting (TPR)

? Any assets suspected to be owned or controlled by a terrorist or terrorist organization will be immediately reported to FINTRAC.

? Swiftier will take all necessary steps, including freezing the assets, to ensure no further transactions occur until regulatory clearance is obtained.
3. Internal Controls and Risk Management
3.1 Risk-Based Approach (RBA) to AML/CTF

3.1.1 Customer Risk Assessment

? A risk-based approach will be employed to evaluate each customer?s potential for money laundering or terrorist financing activities.

? Customers will be categorized into risk levels (low, medium, high) based on a variety of factors, including geographic location, transaction behavior, and the nature of the business.

3.1.2 Transaction Risk Assessment

? Transactions will be monitored in real-time to detect unusual or high-risk activities.

? High-risk transactions will be reviewed manually by compliance staff to ensure they are legitimate and do not pose a risk of money laundering or terrorist financing.
3.2 Internal Audit and Independent Review

3.2.1 Regular Internal Audits

? Swiftier will perform regular internal audits of its AML/CTF compliance program to assess the effectiveness of its controls, policies, and procedures.

? The internal audit will cover all aspects of the compliance program, including customer onboarding, transaction monitoring, and reporting.

3.2.2 Independent External Review

? An independent external review of Swiftier?s AML/CTF program will be conducted every two years by a qualified third party to identify potential gaps and recommend improvements.

? The results of the external review will be documented, and Swiftier will implement all necessary changes to strengthen its compliance posture.
4. Training and Awareness
4.1 Comprehensive Employee Training

4.1.1 Mandatory Training Program

? All employees, including senior management and directors, will receive AML/CTF training upon joining Swiftier and annually thereafter.

? Training will cover regulatory requirements, recognizing suspicious activity, and the responsibilities of employees in preventing money laundering and terrorist financing.

4.1.2 Specialized Training for Key Roles

? Employees in high-risk roles or those involved in customer interactions will receive specialized training tailored to their responsibilities.

? This training will focus on enhanced due diligence, handling high-risk transactions, and the use of Swiftier?s transaction monitoring tools.
4.2 Ongoing Education and Awareness Initiatives

? Regular updates on emerging trends in money laundering and terrorist financing, changes in regulations, and updates to internal policies will be provided to all employees.

? Swiftier will host periodic workshops, webinars, and scenario-based training exercises to enhance employee awareness and skills.
5. Designation of a Compliance Officer
5.1 Appointment and Responsibilities

5.1.1 Compliance Officer Role

? Swiftier will appoint a Compliance Officer with the authority and resources necessary to oversee the AML/CTF compliance program effectively.

? The Compliance Officer will be responsible for developing and maintaining the program, conducting risk assessments, and ensuring all reporting obligations are met.

5.1.2 Responsibilities of the Compliance Officer

? Maintain up-to-date knowledge of all relevant AML/CTF regulations and industry best practices.

? Conduct regular compliance risk assessments and report findings to senior management.

? Lead the development and implementation of AML/CTF policies and procedures, including regular updates based on audit findings and regulatory changes.
6. Enhanced Controls and Safeguards
6.1 Transaction Monitoring and Reporting Systems

6.1.1 Advanced Monitoring Tools

? Swiftier will implement advanced transaction monitoring tools with machine learning capabilities to identify suspicious patterns and automate alerts for compliance review.

? The system will integrate with other internal tools to provide a comprehensive view of all customer activities and potential risks.

6.1.2 Comprehensive Reporting

? The monitoring system will provide comprehensive reporting capabilities, allowing the Compliance Officer to analyze trends, assess risks, and decide on escalations and regulatory reporting.
6.2 Enhanced Fraud Prevention Measures

6.2.1 Real-Time Fraud Detection

? Real-time fraud detection tools will monitor all transactions for signs of fraud or financial crime, including account takeovers and identity theft.

? Immediate measures will be taken to mitigate any detected fraud, including account freezing and investigation.

6.2.2 Collaborative Efforts

? Swiftier will collaborate with other financial institutions and regulatory bodies to share information on emerging threats and enhance collective defenses against financial crime.
7. Continuous Improvement and Program Updates
7.1 Regular Review and Updates

? The AML/CTF compliance program will be reviewed and updated regularly, at least annually, or whenever there are significant changes in regulations, business activities, or risk exposure.

? The Compliance Officer will oversee the update process and ensure all employees are informed of any changes to policies or procedures.
7.2 Feedback and Continuous Improvement

? Employees will be encouraged to provide feedback on the effectiveness of the compliance program and suggest improvements.

? Swiftier will use feedback from internal audits, external reviews, and employee suggestions to continuously improve its compliance framework.
8. Conclusion

Swiftier?s AML/CTF Compliance Program reflects its commitment to maintaining a secure and compliant operational environment. By adhering to FINTRAC guidelines, implementing robust internal controls, and fostering a culture of compliance, Swiftier aims to protect its customers, partners, and stakeholders from the risks associated with money laundering and terrorist financing. This comprehensive approach will ensure Swiftier?s application for regulatory licensing is successful and that it remains compliant in all its