3.1 Our Regulatory Obligations
NEMOPAY GLOBAL CORP. is a Money Services Business registered with the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”), MSB Registration No. C100001197. As a registered MSB, NEMOPAY is subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“PCMLTFA”) and its Regulations.
NEMOPAY is also a payment service provider registered under Canada’s Retail Payment Activities Act (“RPAA”) with the Bank of Canada. These frameworks require NEMOPAY to maintain a risk-based compliance program designed to detect and deter money laundering, terrorist financing, sanctions violations and related financial crime.
3.2 Customer Identification
Before providing regulated services, NEMOPAY must verify the identity of customers and, where applicable, their authorized representatives. For corporate customers, this includes verifying the legal existence, registration and basic corporate information of the entity. Identification checks are carried out before access to financial services is granted.
Acceptable identification documents and information requirements will be communicated to customers during the onboarding process. NEMOPAY uses a risk-based approach and may apply standard or enhanced verification measures depending on the customer profile, transaction activity and applicable risk factors.
3.3 Beneficial Ownership
For legal entities, NEMOPAY is required to identify and verify the individuals who ultimately own or control the entity (“beneficial owners”). This includes collecting information about ownership percentages, the nature of control, and supporting corporate records. NEMOPAY must maintain beneficial ownership records in accordance with applicable law.
Customers that are legal entities must provide accurate and complete beneficial ownership information and must notify NEMOPAY promptly of any material changes.
3.4 Customer Due Diligence and Enhanced Due Diligence
NEMOPAY applies a risk-based approach to customer due diligence (“CDD”). Standard CDD is applied to all customers. Enhanced due diligence (“EDD”) is applied to higher-risk customers, including politically exposed persons (“PEPs”), heads of international organizations, customers with complex ownership structures, customers from higher-risk jurisdictions, or customers engaged in higher-risk business activities.
EDD may involve additional documentation, source-of-funds verification, source-of-wealth assessment, senior management approval and more frequent ongoing monitoring.
3.5 Politically Exposed Persons and Heads of International Organizations
NEMOPAY screens customers and associated individuals against PEP databases and maintains enhanced monitoring procedures for PEPs, heads of international organizations, and their family members and close associates. Where a PEP relationship is identified, NEMOPAY applies EDD measures and, in certain cases, may require senior management approval before proceeding.
3.6 Sanctions Screening
NEMOPAY screens customers, beneficial owners, authorized representatives and transaction counterparties against applicable sanctions and restricted-party lists, including lists administered by Global Affairs Canada, the United Nations, OFAC and other applicable authorities. NEMOPAY will not provide services to, or process transactions involving, sanctioned persons, entities, countries or territories.
If a sanctions concern is identified, NEMOPAY may refuse, delay, block, restrict or terminate services and may report the matter to competent authorities as required by law.
3.7 Source of Funds and Source of Wealth
Depending on risk profile, transaction activity, regulatory requirements or applicable EDD triggers, NEMOPAY may request information and documentation about the source of the funds used in transactions and the source of wealth of the customer or beneficial owner. This is a standard requirement under Canadian AML/CTF law and does not imply wrongdoing.
3.8 Ongoing Monitoring
NEMOPAY conducts ongoing monitoring of customer relationships and transaction activity throughout the business relationship. Monitoring includes transaction pattern analysis, profile updates, periodic review of customer information and event-driven reviews triggered by unusual or inconsistent activity.
Unusual or inconsistent activity may result in requests for additional information, transaction restrictions, account review or escalation to NEMOPAY’s compliance function. NEMOPAY may apply transaction limits and activity controls as part of its ongoing risk management.
3.9 Regulatory Reporting
As required by Canadian law, NEMOPAY files reports with FINTRAC and other competent authorities. Applicable report types include:
- Suspicious Transaction Reports (STRs): where there are reasonable grounds to suspect that a transaction or attempted transaction is related to the commission or attempted commission of a money laundering or terrorist financing offence. There is no minimum dollar threshold for STRs.
- Large Cash Transaction Reports (LCTRs): required when NEMOPAY receives cash of CAD 10,000 or more from, or on behalf of, the same person or entity within a 24-hour period, whether in a single transaction or multiple transactions.
- Electronic Funds Transfer Reports (EFTRs): required for international electronic funds transfers of CAD 10,000 or more, both sent at a client’s request and received for deposit into a client account.
- Virtual Currency Transaction Reports (VCTRs): required for virtual currency transactions equivalent to CAD 10,000 or more.
- Terrorist Property Reports: required where NEMOPAY knows or has reasonable grounds to believe that it holds property owned or controlled by a terrorist, terrorist group or listed entity.
NEMOPAY is prohibited by law from informing a customer that a suspicious transaction report or other regulatory report has been or may be made in relation to them or their transaction. This prohibition applies regardless of the circumstances.
3.10 Travel Rule: Electronic Funds Transfers and Virtual Currency
Under PCMLTFA Regulations, the Travel Rule requires the collection, retention and, where applicable, transmission of originator and beneficiary information for certain transfers. This applies to NEMOPAY’s money transfer and virtual currency activities as follows.
Electronic Funds Transfers: For international EFTs of CAD 1,000 or more initiated at a client’s request, NEMOPAY is required to include the originator’s name, account number and address (or other prescribed identifiers) with the transfer instruction sent to the receiving financial entity. NEMOPAY is also required to retain this information for a minimum of five years. Where NEMOPAY receives an international EFT of CAD 1,000 or more on behalf of a client, it must take reasonable measures to obtain and retain the originator information if it is not included in the transfer message.
Virtual Currency Transfers: For virtual currency transfers of CAD 1,000 or more (or equivalent in virtual currency), NEMOPAY is required to collect and retain the originator’s and beneficiary’s name, account or wallet address, and other prescribed information. Where technically feasible, NEMOPAY must also transmit this information to the receiving virtual asset service provider.
NEMOPAY is registered with FINTRAC as a Money Services Business authorized to deal in virtual currencies. All applicable AML/CTF obligations apply to NEMOPAY’s virtual currency services, including customer identification, beneficial ownership verification, sanctions screening, transaction monitoring, virtual currency transaction reporting and Travel Rule compliance.
Virtual currency transactions may be subject to additional controls and verification requirements.
3.11 Record-Keeping
NEMOPAY maintains AML/CTF records in accordance with applicable law. Customer identification and due diligence records are retained for a minimum of five years after the end of the business relationship. Transaction records are retained for a minimum of five years from the date of the transaction. All records are maintained in a manner that allows them to be produced to FINTRAC or other competent authorities upon request.
3.12 Customer Cooperation
Customers are required to:
- Provide complete, accurate and up-to-date information during onboarding and throughout the business relationship.
- Promptly notify NEMOPAY of any material changes affecting corporate structure, beneficial ownership, business activities, jurisdiction of operations or other information previously provided.
- Cooperate with reasonable compliance, verification, monitoring and information requests.
- Not provide false, misleading or incomplete information.
Failure to cooperate may result in the refusal, restriction, suspension or termination of services.
3.13 Contact
For AML/KYC and compliance matters: Email: compliance@nemopayglobal.com NEMOPAY GLOBAL CORP., 1100 W 73rd Ave, Vancouver, BC V6P 6G5, Canada