FINTRAC
Capital Precious Metals LTD is committed to full compliance with the anti-money laundering (AML) and counter-terrorist financing (CTF) regulations as outlined by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). This policy establishes the standards and procedures we follow to ensure adherence to these legal requirements.
Purpose
The purpose of this FINTRAC Compliance Policy is to:
- Mitigate the risk of money laundering, terrorist financing, and other illicit activities.
- Ensure compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).
- Protect the integrity of our operations and maintain trust with our clients.
Responsibilities
Capital Precious Metals LTD fulfills its FINTRAC compliance obligations through:
- Monitoring and Reporting Suspicious Transactions: Identifying unusual activities and reporting them to FINTRAC.
- Customer Due Diligence (Know Your Client – KYC): Verifying the identity of clients involved in significant transactions.
- Recordkeeping: Maintaining accurate records of transactions, identification, and reports.
- Staff Training: Educating employees on their responsibilities under this policy.
Key Compliance Measures
1. Client Identification
- Clients engaging in transactions that meet or exceed reporting thresholds must provide valid identification.
- Business clients are required to present proof of incorporation and identification for authorized representatives.
2. Monitoring Transactions
- All transactions are monitored to detect unusual or suspicious activity.
- Systems are in place to flag transactions that deviate from typical patterns or appear suspicious.
3. Reporting Obligations
- Suspicious Transaction Reports (STRs): Filed for any transaction where there are reasonable grounds to suspect money laundering or terrorist financing.
- Large Cash Transaction Reports (LCTRs): Filed for cash transactions of CAD 10,000 or more.
- Electronic Funds Transfer Reports (EFTRs): Filed for international transfers of CAD 10,000 or more.
4. Recordkeeping
- Records of all transactions, identification documents, and reports are maintained for a minimum of five years.
- These records are readily available for regulatory review or audits.
5. Compliance Officer
- A designated Compliance Officer oversees the implementation and maintenance of the compliance program.
- Regular reviews and updates to the program ensure alignment with FINTRAC requirements.
6. Employee Training
- Comprehensive training is provided to employees to ensure they understand AML/CTF laws, recognize suspicious activity, and fulfill reporting duties.
- Training materials are updated to reflect regulatory changes or company policy updates.
Non-Compliance
Non-compliance with FINTRAC regulations can result in severe penalties, reputational harm, and legal consequences. All employees must strictly adhere to this policy. Any breaches will be thoroughly investigated and addressed.
Policy Updates
Capital Precious Metals LTD reserves the right to update or amend this policy as necessary to comply with changes in legislation or operational requirements. Continued engagement with Capital Precious Metals LTD will signify acceptance of any updated policies.
Contact Information
For any questions regarding this policy, to report suspicious activity, or for further information, please contact:
Compliance Officer
Email: contact@capitalchain.ca
