Outline for counsel: the headings and the points each section must cover. The final wording needs legal drafting.
1. Our registration
YYGROUP EXCHANGE LTD.British Columbia company, incorporation no. BC1450942Registered with FINTRAC as a money services business, registration no. M24028670Business address on the FINTRAC registry: Długa 29, 02-004 Warsaw, PolandCorrespondence address: 5577 153A St, Surrey, BC V3S 5K7, Canada
- Registered services: money transferring and virtual currency dealing.
2. Our compliance program
- A compliance officer: name or title
- Written policies and procedures.
- A documented risk assessment.
- Ongoing training.
- An effectiveness review at least every two years.
3. Knowing our clients
- Identity verification for every client before we send anything.
- Beneficial owners of companies: everyone who owns or controls 25% or more.
- Politically exposed persons and heads of international organisations.
- Third-party determination.
- Ongoing monitoring of the business relationship.
4. Sanctions
- Screening against Canadian sanctions lists. other lists
- Ministerial directives issued under the Act.
5. Reports we file with FINTRAC
- Suspicious transaction reports, with no minimum amount.
- Large virtual currency transaction reports: 10,000 CAD or more, in one transaction or within 24 hours.
- Electronic funds transfer reports for international transfers of 10,000 CAD or more.
- Terrorist property reports.
- Cash: we don’t accept cash
6. The travel rule
- Required information travels with the virtual currency transfers we send.
- For transfers we receive, we take reasonable measures to get that information.
7. Record keeping
- We keep records for at least five years.
8. What this means for you
- We may ask for more information.
- We may refuse or stop a transaction.
- We can’t always tell you why.
9. Contact the compliance officer
- compliance email