Anti-Money Laundering and Counter-Terrorist Financing Policy

Easy Transfers Inc. (“we”, “us”, or “our”) is a registered Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). This Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy outlines our commitment to preventing money laundering and terrorist financing in compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations.

1. Commitment to Compliance

We are committed to maintaining the highest standards of integrity and compliance. Our AML/CFT program is designed to detect and prevent the use of our services for money laundering or terrorist financing activities. We operate exclusively within Canada and serve clients in full compliance with Canadian federal law.

2. Risk Assessment

We conduct an ongoing risk assessment of our business activities, focusing on the nature of our services (OTC stablecoin-to-CAD and CAD-to-stablecoin conversions), client profiles, and transaction patterns. As a domestic-focused MSB, we assess risks associated with:

High-volume transactions
Transactions involving non-face-to-face clients
Unusual or complex transaction patterns

3. Know-Your-Client (KYC) Program

We verify the identity of all clients before establishing a business relationship or conducting a transaction. Our KYC process includes:

Collecting full legal name, date of birth, and residential address.
Verifying identity using government-issued photo identification (e.g., passport, driver’s license).
Confirming the source of funds for high-value transactions.
Maintaining records of all identification documents for a minimum of 5 years after the end of the business relationship.

4. Client Due Diligence (CDD)

We apply enhanced due diligence for higher-risk clients or transactions, including:

Additional verification of identity and source of funds.
Ongoing monitoring of transaction activity.
Senior management approval for high-risk relationships.

5. Suspicious Transaction Reporting

We are required to report any transaction that we suspect may be related to money laundering or terrorist financing to FINTRAC. This includes transactions that are unusual, complex, or lack economic justification. Our compliance officer reviews all flagged transactions promptly.

6. Record Keeping

We maintain accurate and complete records in accordance with PCMLTFA requirements:

Client identification records: retained for 5 years after the end of the relationship.
Transaction records: retained for 7 years.
Suspicious transaction reports: retained for 7 years.

7. Terrorist Property Reporting

If we have reasonable grounds to suspect that a client is listed on the Canadian Consolidated Terrorist List or that property is owned or controlled by a terrorist, we will immediately freeze the assets and report to FINTRAC.

8. Compliance Officer

A designated Compliance Officer is responsible for overseeing the implementation and maintenance of this AML/CFT Policy. The officer ensures staff training, internal audits, and reporting obligations are fulfilled.

9. Training

All employees and contractors receive regular training on AML/CFT obligations, red flags, and reporting procedures. Training is updated to reflect changes in regulations and emerging risks.

10. No International Exposure

Easy Transfers Inc. operates exclusively within Canada. We do not provide services to clients or counterparties outside of Canada, nor do we engage in cross-border financial activities beyond domestic stablecoin-to-CAD conversions.

11. Contact Us

For questions regarding this AML/CFT Policy, please contact our Compliance Officer:

Easy Transfers Inc.
9 Valhalla Inn Rd, M9B 0B2
Toronto, Ontario, Canada
Email: info@easytransfers.ca
Phone: +1 (437) 262-1025

Supervisory Authority

Our activities are regulated by:

Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
https://www.fintrac-canafe.gc.ca