XELTOX ENTERPRISES LTD, a limited company, whose registered office is at 422 Richards Street, Unit 170, Vancouver, British Columbia, V6B 1L4 Canada, (hereinafter referred to as the “Website”), incorporated under the laws of Canada, with registration number BC1368872, being a Money Services Business authorized and regulated by Financial Transactions and Reports Analysis Centre of Canada (hereinafter referred to as the FINTRAC) with license number M2269585 is committed to maintaining effective prevention and detection measures to assist the law enforcement authorities in combating financial crime. Website adopted a rigorous set of policies and procedures to meet Website's legal obligations under the Canadian, EEA, United Kingdom’s anti-money laundering and counter terrorist legislation.
Money laundering is a process, i.e. any action or attempt to commit an action in which money and property (assets) obtained as a result of criminal activity are disguised as coming from a legitimate source. In fact, money laundering is a process in which 'dirty money' obtained as a result of criminal activity turns into 'clean money', the criminal origin of which is difficult to trace. There are three recognized stages in the process of money laundering.
There are three stages in the process of money laundering:
Money laundering begins with the proceeds obtained criminally from the main crime. The main offense includes, but is not limited to, tax evasion, drug trafficking, bribery, fraud, forgery, murder, robbery, counterfeiting, securities manipulation and copyright infringement. A money laundering offence may include property or income derived from illegal activities that took place outside of Canada.
What is terrorist financing? Under Canadian law, terrorist activity financing is when you knowingly collect or provide property, such as funds, either directly or indirectly, to terrorists. The main objective of terrorist activity is to intimidate a population or compel a government to do something. Terrorists need financial support to carry out terrorist activities and achieve their goals. Many of the techniques used to perform money laundering are also used within terrorist financing, including, but not limited to obscuring the direction of funds and the use of third parties. They need to disguise their money as coming from another source and put it into a form that cannot be easily traced so that it is useable.
Website has implemented policies, procedures and controls aimed at deterring criminals from using Website for the laundering of proceeds of crime. These policies and procedures are tailored to the risk posed by individual clients
Website has established Customer Due Diligence procedures to identify the users of its services and, in relation to higher-risk clients, the principal beneficial owners and origins of funds. These procedures include knowing the nature of our clients’ businesses and being alert to abnormal transactions
In summary, Website has adopted its CDD policies in order to successfully carry out the following:
Unexplained or abnormal transactions or activities that are suspected of being linked to criminal activity will be reported to the Compliance Officer in writing without delay, who will determine whether to report the suspicions to FINTRAC.
All personnel must be informed of their individual and collective responsibilities and Website’s anti- money laundering policies. Personnel are provided with training to enable them to understand the vulnerabilities of Website’s business and to recognize and report suspicious activities.
Website keeps records of who has been trained and the timing and form of training sessions. We retain all records verifying the identity of our clients for at least 5 years following the end of the business relationship. We also retain the records of any internal reports of suspicion submitted to the Compliance Officer and any disclosures made to FINTRAC.
All Money Services Businesses (MSBs) in Canada are reporting entities in accordance with the Law and are required to:
What is risk? - Risk can be defined as the likelihood of an event and its consequences. In simple terms, risk can be seen as a combination of the chance that something may happen and the degree of damage or loss that may result from such an occurrence. In the context of money laundering/terrorist financing (ML/TF), risk means:
All clients default to low risk, UNLESS risk factors are present such as; Automatic high-risk characteristics – if any of the flags below are present the client is high risk.
Client characteristics, product, service, delivery channel:
Geography:
Other suspicious transaction indicators:
The following are some samples of some general and industry-specific indicators that might lead you to have reasonable grounds to suspect that a transaction is related to a money laundering or terrorist activity financing offence. The presence of one or more of these factors does not indicate the transaction is suspicious and reportable to FINTRAC, but that a deeper look should be taken.
General indicators. The following are a few examples of general indicators that might lead us to suspect that a transaction is related to a money laundering or terrorist activity financing offence. It will not be just one of these factors alone, but a combination of several factors in conjunction with what is normal and reasonable in the circumstances of the transaction or attempted transaction.
To mitigate and control ML risk related to client, Website does not provide services and refuse account opening for the following clients with unacceptable risk level:
In accordance with internal AML Procedure has clients of two risk categories, i.e., low risk clients and high risk clients. For high risk client EDD must be performed
A high-risk client is someone:
Website is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. Website will therefore screen against the relevant sanctions lists in the jurisdictions in which we operate.
Website has no AML Risk Appetite for establishing or maintaining a customer or a counterparty relationship with a natural person or legal entity designated on any of the below lists or where otherwise prohibited by applicable law or regulation:
In addition, Website pays particular attention to entities from countries which are on the list of noncooperative countries and territories drawn up by the Financial Action Task Force (FATF) and to monetary operations or transactions performed by or on behalf of them.
Website does not open accounts and does not provide services to clients from the following countries:
Website AML policy includes customer’s and beneficial owner’s due diligence and ongoing AML monitoring and AML reporting policies. At various points in time, Website may request information regarding the transactions carried out through the customer’s account opened at Website and the parties of the respective payment. If the customer may not respond sufficiently or within a timely manner Website also reserves the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.