Anti-Money Laundering and Anti-Terrorist Financing Policy

Our Regulatory Status

The company operates under multiple registrations:

• Money Services Business (MSB): Registered with FINTRAC under number C100000702, effective July 23, 2025
• Payment Service Provider (PSP): Registered with the Bank of Canada as a payment service provider under the Retail Payment Activities Act, effective October 30, 2025

Subject to comprehensive oversight including PCMLTFA, Retail Payment Activities Act, Canada's sanctions regime, and ongoing supervision by Canadian financial authorities.

Understanding Money Laundering and Terrorist Financing

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.

Our Commitment

Invincible Pay recognizes AML/ATF compliance as both legal obligation and fundamental responsibility. The comprehensive program is designed to:

• Prevent and detect money laundering and terrorist financing through robust controls, monitoring systems, and staff training
• Comply with all applicable laws including PCMLTFA, Retail Payment Activities Act, Criminal Code, Anti-Terrorism Act, United Nations Act, Special Economic Measures Act, and related regulations
• Implement robust customer due diligence with identity verification and risk assessments
• Monitor transactions comprehensively to detect unusual patterns or suspicious activity
• Report to FINTRAC as required
• Screen against sanctions lists
• Maintain comprehensive records
• Invest in staff training and resources
• Continuously improve policies, procedures, and systems
• Cooperate with authorities

Our Compliance Program

Built on strong governance, comprehensive policies and procedures, advanced technology, and compliance culture.

Leadership and Oversight

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.

Risk-Based Approach

Different customers, products, services, delivery channels, and geographic locations present varying money laundering and terrorist financing risks. Comprehensive risk assessments examine:

• Product and service vulnerability to misuse
• Delivery channel vulnerability (online, mobile, etc.)
• Geographic customer locations and transaction destinations
• Customer types and risk profiles
• Transaction patterns, volumes, and characteristics
• Emerging threats and trends

Customer Due Diligence

Identity verification precedes all business relationships with due diligence commensurate with assessed risk levels. Procedures include:

• Identity Verification: Using reliable, independent sources for government-issued identification
• Beneficial Ownership: Identifying natural persons who ultimately own or control entity customers
• Purpose and Nature of Business Relationship
• Source of Funds and Wealth: For higher-risk relationships
• Enhanced Due Diligence: When heightened risks are identified

Ongoing Monitoring

Continuous monitoring of customer transactions and activities throughout business relationship duration. Includes:

• Automated transaction monitoring systems
• Regular account and business relationship reviews
• Periodic customer information updates
• Enhanced monitoring for higher-risk customers
• Transaction analysis against expected activity
• Alert investigation and potential suspicious activity escalation

Sanctions Screening

All customers and beneficial owners are screened against:

• The Consolidated Canadian Autonomous Sanctions List
• United Nations Security Council Sanctions Lists
• Lists maintained under the Criminal Code of Canada
• Other relevant domestic and international sanctions lists

Screening occurs before new customer onboarding, periodically throughout business relationships, and whenever sanctions lists update.

Politically Exposed Persons

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.

Reporting

Reports filed with FINTRAC include:

• Suspicious Transaction Reports
• Large Virtual Currency Transaction Reports
• Electronic Funds Transfer Reports
• Terrorist Property Reports

Record Keeping

Comprehensive records maintained for legally prescribed periods (generally five years). Records are accurate, complete, readily accessible, securely stored, and capable of prompt retrieval.

Training and Awareness

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 Review

Independent compliance program effectiveness reviews occur at least every two years.

Our Services

Invincible Pay provides payment processing and e-wallet services including: e-wallet accounts, payment processing, fund transfers, and virtual currency services.

Customer Responsibilities

Service users agree to:

• Provide accurate information
• Cooperate with verification procedures
• Use services legitimately
• Respond to inquiries
• Report changes
• Comply with applicable laws

Geographic and Jurisdictional Considerations

Risk-based approach considering: customer country, fund jurisdictions, FATF assessments, sanctioned jurisdictions, high-risk countries.

Ministerial Directives

Compliance with all PCMLTFA-issued ministerial directives regarding high-risk jurisdictions.

Canadian Sanctions Compliance

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.

Technology and Innovation in Compliance

Leveraging: automated monitoring, data analytics, digital identity verification, sanctions screening systems, secure record keeping.

Privacy and Data Protection

Personal information collected and used only for legitimate compliance purposes. Appropriate safeguards implemented. AML/ATF law compliance takes precedence over privacy in required cases.

Consequences of Non-Compliance

Criminal penalties (up to 10+ years imprisonment), administrative monetary penalties (up to $500,000 per violation), asset seizure, license revocation, reputational damage, civil liability.

International Cooperation

Alignment with FATF, Egmont Group, and bilateral/multilateral agreements.

Red Flags and Suspicious Activity Indicators

Common indicators including: inconsistent transactions, complex patterns, avoidance attempts, reluctance to provide information, false documentation, high-risk jurisdictions, rapid fund movement, etc.

Employee Responsibilities and Culture of Compliance

All personnel must understand and comply with policies, complete training, maintain alertness, report concerns, cooperate with investigations, and maintain confidentiality.

Whistleblower Protection

Confidential reporting channels without retaliation. Retaliation is prohibited.

Continuous Improvement and Policy Updates

Regular policy reviews, monitoring regulatory developments, tracking emerging threats, learning from experience, industry engagement, technology assessment, staff feedback.

Commitment to Transparency

Public policy statement demonstrating integrity operation and full Canadian law compliance.

Contact Information

Email: info@invinciblepay.com

Phone: +1 (587) 288-5511

Mailing Address: Invincible Payment Systems Limited, Attention: Compliance Department, 200-4909 50 Street, Red Deer, Alberta, T4N 6X2, Canada

Website: invinciblepay.com