Invincible Pay commits to maintaining highest compliance standards with applicable AML and ATF laws, preventing illicit service use and protecting Canadian financial system integrity.
The company operates under multiple registrations:
Subject to comprehensive oversight including PCMLTFA, Retail Payment Activities Act, Canada's sanctions regime, and ongoing supervision by Canadian financial authorities.
Money laundering involves three stages: placement (introducing illegal funds), layering (obscuring sources through complex transactions), and integration (using "cleaned" money in legitimate commerce).
Terrorist financing involves collecting or providing funds with intention for terrorist use or knowledge they will be used for such activities. Unlike money laundering, terrorist financing may involve legitimate fund sources.
Both activities threaten financial system integrity, national security, and public safety.
Invincible Pay recognizes AML/ATF compliance as both legal obligation and fundamental responsibility. The comprehensive program is designed to:
Built on strong governance, comprehensive policies and procedures, advanced technology, and compliance culture.
A dedicated Chief Compliance Officer (also Chief Anti-Money Laundering Officer) oversees the compliance program and reports directly to the Chief Executive Officer with necessary authority, resources, and independence. Senior management and Board of Directors provide ongoing oversight.
Different customers, products, services, delivery channels, and geographic locations present varying money laundering and terrorist financing risks. Comprehensive risk assessments examine:
Identity verification precedes all business relationships with due diligence commensurate with assessed risk levels. Procedures include:
Continuous monitoring of customer transactions and activities throughout business relationship duration. Includes:
All customers and beneficial owners are screened against:
Screening occurs before new customer onboarding, periodically throughout business relationships, and whenever sanctions lists update.
Specific identification and risk mitigation procedures for PEPs, HIOs, and their family members and close associates. Enhanced measures include senior management approval, enhanced due diligence, and intensive ongoing monitoring.
Reports filed with FINTRAC include:
Comprehensive records maintained for legally prescribed periods (generally five years). Records are accurate, complete, readily accessible, securely stored, and capable of prompt retrieval.
All employees receive comprehensive AML/ATF training including initial training, role-specific training, annual refresher training, ad-hoc training, red flag identification, and escalation procedures.
Independent compliance program effectiveness reviews occur at least every two years.
Invincible Pay provides payment processing and e-wallet services including: e-wallet accounts, payment processing, fund transfers, and virtual currency services.
Service users agree to:
Risk-based approach considering: customer country, fund jurisdictions, FATF assessments, sanctioned jurisdictions, high-risk countries.
Compliance with all PCMLTFA-issued ministerial directives regarding high-risk jurisdictions.
Full compliance with sanctions under United Nations Act, Special Economic Measures Act, Justice for Victims of Corrupt Foreign Officials Act. Zero tolerance for sanctions violations.
Leveraging: automated monitoring, data analytics, digital identity verification, sanctions screening systems, secure record keeping.
Personal information collected and used only for legitimate compliance purposes. Appropriate safeguards implemented. AML/ATF law compliance takes precedence over privacy in required cases.
Criminal penalties (up to 10+ years imprisonment), administrative monetary penalties (up to $500,000 per violation), asset seizure, license revocation, reputational damage, civil liability.
Alignment with FATF, Egmont Group, and bilateral/multilateral agreements.
Common indicators including: inconsistent transactions, complex patterns, avoidance attempts, reluctance to provide information, false documentation, high-risk jurisdictions, rapid fund movement, etc.
All personnel must understand and comply with policies, complete training, maintain alertness, report concerns, cooperate with investigations, and maintain confidentiality.
Confidential reporting channels without retaliation. Retaliation is prohibited.
Regular policy reviews, monitoring regulatory developments, tracking emerging threats, learning from experience, industry engagement, technology assessment, staff feedback.
Public policy statement demonstrating integrity operation and full Canadian law compliance.
Email: compliance@invinciblepay.com
Phone: 672-886-1422
Mailing Address: Invincible Payment Systems Limited, Attention: Compliance Department, 200-4909 50 Street, Red Deer, Alberta, T4N 1X8, Canada
Website: invinciblepay.com
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