ANTI-MONEY LAUNDERING (AML) AND KNOW YOUR CUSTOMER (KYC) POLICY

Date of Last Update: 8th October 2024 

GENERAL PAYMENTS GATE LIMITED, a company incorporated in Canada and operating under the brand name VIP 360 (hereinafter referred to as “the Company”), is regulated by FINTRAC under License Number M22457458. As a regulated entity, the Company is committed to full compliance with the applicable Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) laws and regulations in Canada, as well as international standards aimed at mitigating the risk of money laundering, terrorist financing, and other illicit financial activities. 

Purpose 

The purpose of this Anti-Money Laundering and Know Your Customer (KYC) Policy (hereinafter referred to as “the Policy”) is to set forth the Company’s obligations and procedures for preventing and mitigating money laundering, terrorist financing, and other related illegal activities. This Policy is designed to ensure that the Company complies with all relevant AML/CFT legislation, including but not limited to, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), and corresponding regulatory requirements. 

Customer Due Diligence (CDD)

In compliance with AML/CFT laws, the Company employs a comprehensive Customer Due Diligence (CDD) program. CDD measures are taken to ensure that the identities of our customers are adequately verified and that the Company has sufficient information to assess the risk associated with each customer. 

The Company undertakes the following CDD measures: 

1. Customer Identification: Identifying the customer or any person participating in a transaction and verifying the accuracy of the information provided. 
2. Representative Verification: Identification and verification of any representative acting on behalf of a customer or participant, along with their legal authority to act. 
3. Beneficial Ownership: Identifying the beneficial owner(s) of a legal entity and applying reasonable measures to verify their identity to the extent necessary to ensure that the Company is aware of the ownership and control structure. Business
4. Relationship Understanding: Obtaining adequate information to understand the nature and purpose of the business relationship or transaction. 
5. Politically Exposed Persons (PEPs): Screening customers and determining whether they, their family members, or close associates qualify as politically exposed persons (PEPs). 
6. Ongoing Monitoring: Monitoring the business relationship on a continuous basis to detect suspicious activities and ensure compliance. 

Know Your Customer (KYC) Procedures

As part of the Company’s KYC procedures, the following minimum information will be collected from each customer when opening an account: 

• Full Name; 

• Email Address; 

• Phone Number; 

• Gender; 

• Date of Birth; 

• Country of Birth; 

• Citizenship; 

• Residential Address; 

• Profession; 

• Identity Document Information; 

• Information on the Source of Funds. 

Verification of Legal Entities

For customers who are legal entities, the Company will collect and verify the following information: 

• Company Name; 

• Company Industry and Jurisdiction; 

• Date of Incorporation; 

• Payment Methods Used; 

• Payment Sources and Beneficiaries; 

• Registered Address; 

• Company Identification Number; 

• Website (if applicable); 

• Information on Controlling Persons and their Legal Authority; 

• Authorized Representatives and their Legal Capacity; 

• Information on Directors and Shareholders; 

• Identification of Ultimate Beneficial Owners (UBOs); 

• Source of Entity’s Funds; 

• Business Model and Flow of Funds; 

• Financial Statements; 

• Company Structure. 

The Company reserves the right to request additional documentation or information from customers, particularly for clients deemed to be higher-risk, to ensure compliance with enhanced due diligence (EDD) requirements. 

Enhanced Due Diligence (EDD)

For customers identified as presenting a higher risk of money laundering or terrorist financing, the Company applies enhanced due diligence (EDD) measures. These may include, but are not limited to, requesting additional documentation or conducting more in-depth checks on the customer’s financial background, business activities, and source of funds. 

Prohibited Business Activities and Jurisdictions

In alignment with the Company’s risk management framework, services will not be provided to clients or entities engaged in high-risk or illegal activities, including but not limited to: 

• Unlicensed gambling, casinos, or betting services; 

• Unlicensed financial institutions; 

• Non-regulated charities; 

• Businesses involved in adult entertainment; 

• Clients dealing with arms or weapons; 

• Companies issuing bearer shares; 

• Clients opening accounts for third parties; 

• Shell banks; 

• Clients listed on international sanctions lists (such as OFAC, UN, or EU sanctions). 

The Company will not provide services to customers located in or operating from jurisdictions with inadequate AML/CFT controls, including but not limited to the following countries: Afghanistan, American Samoa, Barbados, Belarus, Botswana, Cambodia, Cayman Islands, Democratic People’s Republic of Korea (North Korea), Ethiopia, Fiji, Ghana, Guam, Guyana, Iceland, Iran, Iraq, Jamaica, Lao PDR, Mongolia, Myanmar, Nicaragua, Oman, Pakistan, Palau, Panama, Russian Federation, Samoa, Sri Lanka, Syria, The Bahamas, Trinidad and Tobago, Tunisia, Uganda, US Virgin Islands, Vanuatu, Yemen, Zimbabwe.

This list is non-exhaustive, and the Company reserves the right to reject clients or transactions from other jurisdictions or business activities that present an unacceptable risk. 

Sanctions Screening

The Company conducts sanctions screening for all customers using market-leading databases. Screening is carried out at account opening and on an ongoing basis, and includes checks against the following lists: 

• Politically Exposed Persons (PEPs), including their close relatives and associates; 

• United Nations (UN) Sanctions; 

• European Union (EU) Sanctions; 

• Office of Foreign Assets Control (OFAC) and related ownership research; 

• Individuals charged or convicted of specific types of criminal activity (Special Interest Persons). 

In the event of a match (“true hit”), the case will be escalated to the Company’s Compliance Officer for further investigation and appropriate action. 

Ongoing Monitoring and Account Surveillance

The Company continuously monitors customer transactions and behaviors during the course of its business relationship with the customer. As part of its ongoing due diligence, the Company may periodically request updated customer information to ensure compliance with current legal obligations and to detect any suspicious or unusual activity. 

The Company reserves the right to suspend transactions or account activities for further investigation if any illegal or suspicious activity is suspected. Additionally, the Company prohibits the use of cash for any transaction, and will not allow the transfer of fiat currency between customers. 

Data Retention

In accordance with applicable laws and regulations, the Company will retain personal data and documentation collected for the purpose of establishing a business relationship for a minimum period of five (5) years from the date of termination of the business relationship. 

Further details regarding data collection and retention can be found in the Company’s Privacy Policy. 

Legal Obligations

By applying for an account with the Company, you agree to promptly provide all information and documentation reasonably requested to ensure compliance with applicable AML/CFT laws and regulations. Failure to provide such information may result in the termination of services or rejection of your application.