AML/ KYC Policy
AML/ KYC Policy
FIRST VIEW PAYMENTS LIMITED, is a company incorporated in Canada and is registered with FINTRAC under registration number M23164429. As a regulated Company, we are required to comply with the applicable anti-money laundering and countering financing of terrorism legislations in Canada, in order to prevent any exposures to money laundering and terrorist financing and also ensuring compliance with the international standards.
Customer Due Diligence
In our efforts to counter money laundering and terrorist financing and be in compliance with the applicable Legislations, we apply the following due diligence measures:
- identification of customers or persons participating in an occasional transaction and verification of the submitted information;
- identification and verification of a representative of a customer or person participating in an occasional transaction and their right of representation;
- identification of the beneficial owner and, for the purpose of verifying their identity, taking measures to the extent that allows the Company to make certain that it knows who the beneficial owner is, and understands the ownership and control structure of the customer or of the person participating in an occasional transaction;
- understanding of business relationships, an occasional transaction or operation and, where relevant, gathering information thereon;
- gathering information on whether a person is a politically exposed person, their family member or a person known to be close associate;
- monitoring of a business relationship.
KYC Procedures
In compliance with the applicable Legislation, we will ask for certain minimum identification information from each customer which opens an account with the Company.
This minimum information may include:
- Full name;
- Email address;
- Phone number;
- Gender;
- Date of birth;
- Country of birth;
- Citizenship;
- Residential address;
- Profession.
- Identity document information;
- Information on your source of funds.
The Company will request from customers relevant documentation to verify the above information:
Upon establishing a relationship with a legal entity, the following information shall be collected:
- Company Name;
- Company Industry;
- Company jurisdiction;
- Date of Incorporation;
- Payment types;
- Information for payments from & payments to;
- Company address;
- Company number;
- Website;
- Controlling persons and their legal capacity;
- Authorised representatives (other than controlling persons) and their legal capacity;
- Information on Directors & Shareholders;
- Shareholders and ultimate beneficial owners (UBO);
- Source of entity’s funds;
- Funds Flow;
- Company Structure;
- Financial Statements;
- Business model;
- Other information which may be required for conducting identification and verification of the legal entity.
The Company applies enhanced due diligence measures for clients considered to be high risk. Therefore, we might request from you additional information and/or documentation.
Restricted Business and jurisdictions
To minimize any risk of money laundering and terrorist financing our Company does not provide services to clients that their activities are associated with any high risk or banned activities. For example:
- Unlicensed Gambling, casinos, betting companies.
- Unlicensed Financial Institutions
- Non-regulated Charities.
- Clients who are involved in adult entertainment;
- Clients dealing with weapons;
- Companies with bearer shares form;
- Client accounts in the name of a third person;
- Shell banks;
- Clients listed in sanction lists (i.e. OFAC, UN, European)
- Clients from the following jurisdictions:
Afghanistan | American Samoa | Anguilla | Armenia | Azerbaijan | |
Bahamas | Barbados | Belarus | Belize | Benin | Bonaire, Saint Eustatius and Saba |
Botswana | Bouvet Islands | British Indian Ocean Territory | Burkina Faso | Burundi | Cambodia |
Cameroon | Central African Republic | Chad | Christmas Islands | Cocos Islands | Colombia |
Comoros | Congo (Republic of) | Congo | Cook Islands | Crimea | Cuba |
Djibouti | Dominica | Egypt | El Salvador | Equatorial Guinea | Eritrea |
Ethiopia | Fiji | Ghana | Guam | Guinea | Guinea Bissau |
Haiti | Heard Island and McDonald Islands | Iran | Iraq | Jamaica | Kiribati |
Lebanon | Liberia | Libya | Mali | Mauritius | Morocco |
Myanmar | Netherland Antilles | New Caledonia | Nicaragua | Niger | Nigeria |
Norfolk Island | North Korea | Northern Mariana Islands | Pakistan | Palau | Palestine |
Panama | Russian Federation | Rwanda | Saint Martin | Saint Pierre and Miquelon | Samoa |
Seychelles | Sierra Leone | Sint Maarten | Somalia | South Georgia and the South Sandwich Islands | South Sudan |
Sudan | Syria | Tajikistan | Tokelau | Trinidad and Tobago | Turkmenistan |
Uganda | Ukraine | United States Minor Outlying Islands | US Virgin Islands | Uzbekistan | Vanuatu |
Venezuela | Western Sahara | Yemen | Zambia | Zimbabwe |
The above list is not exhaustive. The Company might not accept clients dealing with other high business activities which are not align with its risk appetite.
Sanctions Screening
The Company performs through market leading databases sanction screening of all of its potential customers on the same matching rules, as for PEP screening.
The Company will perform screening, at minimum, against the following sanctions lists:
- Politically exposed persons (including relatives & close associates) (market leading global PEP database aligned to regulatory guidance since 2002 and 3rd, 4th and 5th EU directives).
- UN Sanctions;
- EU Sanctions;
- Unique Sanctions Ownership Research (entities owned or controlled by OFAC or EU sanctioned individuals) not available through other providers
- Special Interest Persons – people indicted, charged or arrested for specific types of criminal conduct
All matches (true hits) will be escalated to a Compliance Officer for further action and processing.
Monitoring and Ongoing Customer Due Diligence
We will continuously monitoring your transactions and overall behavior while you are using our services. We also put the best efforts to ensure that your information is up to date, so we may request to occasionally update your personal data during the course of our business relationship. We also may take an appropriate action such as suspending your account or transaction for further investigation if we deem it necessary in order to protect you and the Company from any potential illegal activity.
In an effort to prevent money laundering and other illegal activity, we do not permit any cash transactions, regardless of their stated purpose or any fiat transaction, i.e. transferring any fiat amounts from one client to another client.
We have the right to cancel or deny a transaction at any point if there are suspicions regarding its legality.
Data Retention
The Company will store your personal data collected for the purpose of establishing business relationship with you for minimum period of 5 years from the date of terminating your business relationship with the Company.
You may find additional information on collection and storage of your personal data in the Company’s Privacy Policy.
By applying for an account with us you agree to promptly provide us with all the information that we reasonably request in order to comply with all applicable laws and regulations relating to anti-money laundering.