AML & CTF Basics

Money laundering involves taking money obtained by committing a crime and disguising the source to make it appear legitimate. Under the Criminal Code of Canada, it is illegal to launder money or knowingly assist in laundering money. The PCMLTFA and subsequent international regulatory boards require us to take appropriate measures to prevent criminal activity. According to the law, as a money service business, we must report all suspicious funds.

Terrorist financing is the movement of funds to pay for terrorist activities. Although the source of the funds is not always criminal, the use of funds tends to be. The Criminal Code of Canada states the following, it is illegal to knowingly assist in the financing of terrorism and to have terrorist funds or property. All known or suspected accumulation of terrorist properties in our possession must be reported immediately. CendMate operates within Canada and does not interact with countries listed as “Terrorist Friendly” by FINTRAC.

CendMate's Commitment

CendMate reports to and follows the guidelines of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). CendMate is committed to preventing, detecting, and deterring money laundering and terrorist financing. We have constructed policies to report standards and obligations, facilitate efficient record keeping, conduct extensive information collection, monitor staff responsibilities, and provide appropriate staff training. It is the responsibility of every employee (including contract and part-time employees) to comply with this program and all related Canadian legislation. FINTRAC is a Canadian federal initiative that regulates our industry to ensure that we are meeting our obligations. They have the power to review our documentation and to levy significant penalties if we are not compliant. Individuals that deliberately attempt to circumvent the law may also be charged criminally in addition to monetary penalties.

KYC Policy

CendMate must verify the identity of customers for certain activities and transactions according to the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR). CendMate can confirm the identity of a customer by relying on an identity document where it is “valid and authentic.” We can confirm identification using acceptable documents, presented in an electronic format, so long as they can be authenticated. The individual's information is collected, and any suspicious transaction is reported to FINTRAC and further investigated by our compliance team. We refuse any transaction where required documents are not provided.

The Identification document must fit the following requirements:

• Issued by a provincial, territorial or federal government in Canada or an equivalent foreign government; Valid (not expired)
• Bears a unique identifier number (such as a driver's license number)
• Bears the name of the individual being identified
• Bears a photo of the individual being identified.

We must also collect and record the following information:

• Customer full name (no initials, short forms, or abbreviations)
• Customer's occupation (this should be as detailed as possible, without abbreviations or acronyms)
• The purpose of our business relationship with the customer (if applicable)
• Customer's date of birth (if this appears on the identification document, the date of birth that we record must match the document)
• Complete home address (post boxes, office addresses, and general delivery addresses are not acceptable for this purpose; if the customer wishes to provide a separate mailing address, we can collect this as well, but we must always record the full home address)
• The type of document used to identify the customer
• Place that the identification was issued (province, territory or state and country, not a city)
• Unique identification number (such as the driver’s license number)
• Expiry date of the identification provided (if the document has an expiry date; if it does not, please make a note to say that there was no expiry date on the document)
• The date on which we verified the document

If a customer has been identified previously and the information in our records is up to date (the identification document used has not expired), and we can verify the customer's identity, then we do not need to request identification to complete a transaction.

Anti-Fraud Initiative

In addition to ensuring our customers are verified via our KYC procedures, CendMate actively works to identify and cease fraudulent activity. If we suspect a customer is transacting under fraudulent pretenses, we contact that individual, investigate their reasoning for the purchase, and deny the transaction if it is ruled to be fraudulent in origin and report the transaction to FINTRAC.