Our AML Policy Explains
I. Our AML Policy
Bistrapay's AML policy prohibits and actively prevents money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Criminal Code and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and the Canadian Financial Supervision and Resolution Authority.
Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally-derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets.
In general, money laundering occurs in three stages: placement, layering, and integration.
- During the placement stage, cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions.
- During the layering stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin.
- During the integration stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.
Our AML policies, procedures, and internal controls are designed to ensure compliance with all applicable AML/PCMLFTA rules and will be reviewed and updated on a regular basis to ensure that appropriate policies, procedures, and internal controls are in place to account for both changes in regulations and changes in our business.
II. Our AML/PCMLFTA Requests and Compliance
By using the Bistrapay services and app, you agree that Bistrapay will respond to every Financial Crimes Enforcement Network (Criminal Code and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)) request concerning accounts and transactions that occurred during the use of our service or app by immediately searching our records to determine whether we maintain or have maintained any account for, or have engaged in any transaction with, each individual, entity, or organization in question.
Bistrapay will review, maintain and implement procedures to protect the security and confidentiality of requests from The Criminal Code and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) similar to those procedures established to satisfy the requirements of AML/PCMLFTA with regard to the protection of customers’ nonpublic information.
We understand that we have 14 days (unless otherwise specified by the Money Laundering and Terrorist Financing Prevention Act office from the transmission date of the request) to respond to AML/PCMLFTA requests.
We will designate through the AML/PCMLFTA Contact System (Bistrapay) one or more persons to be the point of contact (POC) for AML/PCMLFTAs and will promptly update the POC information following any change in such information.
Unless otherwise stated in the AML/PCMLFTA or specified by the Criminal Code and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), we are required to search those documents outlined in the Criminal Code and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)'s FAQ.
If we find a match, Bistrapay will report it to the Criminal Code and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) via the Criminal Code and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)'s web-based Secure Information Sharing System within 14 days or within the time requested by the Criminal Code and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) in the request.
If the search parameters differ from those mentioned above (for example, if the Criminal Code and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) limits the search to a geographic location), Bistrapay will structure our search accordingly.
III. Customers Who Refuse To Provide Information for AML/PCMLFTA Request
If a potential or existing customer either refuses to provide the requested information or appears to have intentionally provided misleading information, Bistrapay will not open a new account and will consider closing any existing account after considering the risks involved. In either case, our AML Compliance Officer will be notified so that we can determine whether we should report the situation to AML/PCMLFTA.
IV. Required Customer Information
Prior to verifying an account, Bistrapay's AML Compliance Officer will collect the following information for all accounts, if applicable, for any person, entity, or organization that is opening a new account and whose name is on the account:
- Full name
- Date of birth (for an individual)
- An address, which will be a residential or business street address (for an individual), a Post Office (APO) or Fleet Post Office (FPO) box number, or the residential or business street address of next of kin or another contact individual (for an individual who does not have a residential or business street address), or a principal place of business, local office, or other physical location (for a person other than an individual)
- An identification number, which will be a taxpayer identification number (for U.S. persons), or one or more of the following: a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or other similar safeguard.
