Anti-Money Laundering (AML) & Counter-Terrorism Financing (CTF) Policy

S-Interio Limited
Effective Date: January 1st, 2025

1. Policy Statement

S-Interio Limited (“S-Interio”, “we”, “our”, or “the Company”) is fully committed to complying with all applicable laws and regulations aimed at combating money laundering and the financing of terrorism. As a licensed Canadian Payment Service Provider (PSP), we recognize our obligation to help prevent, detect, and report suspicious activities that could indicate money laundering, terrorist financing, fraud, or other financial crimes.

Our AML/CTF program is designed in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and follows guidance from the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). We also align our procedures with international standards, including those set by the Financial Action Task Force (FATF).

 2. Objectives

This policy seeks to:

• Prevent and detect the use of S-Interio’s services for illicit purposes.
• Ensure full regulatory compliance in every jurisdiction in which we operate.
• Foster a culture of compliance and risk awareness throughout the organization.
• Safeguard the integrity of the global financial system.
 

 3. Scope of the Policy

This policy applies to:

• All employees, management, and contractors of S-Interio.
• All products, services, and platforms provided by S-Interio.
• All business relationships and customer types (retail and commercial).
• All jurisdictions where we conduct business, with a focus on Canada and Latin America.
 

 4. Governance & Responsibility

S-Interio has appointed a Compliance Officer responsible for the implementation and oversight of the AML/CTF framework. The Compliance Officer ensures that the policy is kept up-to-date, regularly audited, and aligned with regulatory changes.

The responsibilities of the Compliance Officer include:

• Overseeing the customer due diligence (CDD) process.
• Monitoring transactions and reviewing suspicious activity alerts.
• Filing reports to FINTRAC and other authorities as required.
• Training staff on AML/CTF compliance.
• Conducting internal audits and risk assessments.
 
 
 5. Risk-Based Approach (RBA)

S-Interio adopts a Risk-Based Approach to AML/CTF, meaning we:

• Assess and categorize customers, products, delivery channels, and geographies by risk level.
• Apply enhanced due diligence (EDD) and controls where higher risk is identified.
• Continuously review and update our risk assessments.

Risk indicators include, but are not limited to:

• High transaction volumes inconsistent with the client profile.
• Use of shell companies or complex ownership structures.
• Dealings in high-risk jurisdictions.
• Unusual transaction patterns or behavior.
 

 6. Customer Due Diligence (CDD) & KYC

We conduct thorough Know Your Customer (KYC) procedures before establishing a relationship with any client. Our KYC measures include:

• Verifying identity and legal existence of individuals and entities.
• Verifying source of funds and nature of business activities.
• Screening against global sanctions and watchlists (UN, OFAC, EU, etc.).
• Identifying and monitoring Politically Exposed Persons (PEPs) and their close associates.

We implement:

• Standard Due Diligence for low-risk customers.
• Enhanced Due Diligence (EDD) for high-risk customers, PEPs, and certain jurisdictions.

CDD is performed not only at onboarding but also throughout the customer lifecycle.

 

7. Ongoing Monitoring of Transactions

S-Interio uses automated and manual monitoring systems to:

• Detect unusual, suspicious, or high-risk activity.
• Flag transactions that meet FINTRAC reporting thresholds.
• Review customer behavior against expected norms.
• Escalate alerts to the Compliance Officer for investigation.

Monitoring is risk-based and focuses on transaction amounts, frequency, destination countries, counterparties, and changes in customer behavior.

 

8. Reporting Obligations

S-Interio meets all mandatory reporting requirements, including:

• Suspicious Transaction Reports (STRs)
• Large Virtual Currency Transaction Reports (LVCTRs)
• Large Cash Transaction Reports (LCTRs)
• Terrorist Property Reports

Reports are submitted to FINTRAC promptly and in compliance with legislative timelines and confidentiality protocols.

 
9. Record-Keeping Requirements

We maintain detailed records of:

• Customer identification documents.
• Transaction histories.
• Risk assessments and due diligence results.
• Internal reports and investigations.

These records are retained for a minimum of 5 years from the date of transaction or termination of the business relationship, in line with Canadian regulatory requirements.

 10. Employee Training

All employees receive regular training on:

• AML/CTF laws and responsibilities.
• Identifying red flags and suspicious behaviors.
• Internal reporting procedures.
• Proper handling of client information.

Training is tailored to specific roles and updated annually or as regulations change.

 11. Sanctions Screening and PEP Checks

We conduct real-time screening against:

• Domestic and international sanctions lists.
• Government-issued PEP databases.

Clients found to be on sanctions lists or with significant PEP exposure are subject to enhanced review and approval by the Compliance Officer.

 12. Cooperation with Authorities

S-Interio fully cooperates with national and international regulators and law enforcement agencies. We respond promptly to lawful information requests and support investigations where applicable.

 13. Internal Controls & Review

We have robust internal controls in place, including:

• Segregation of duties.
• Independent audits and risk assessments.
• Regular review and testing of the AML/CTF program.
• Incident tracking and policy revision mechanisms.

 

14. Review of the Policy

This AML Policy is reviewed at least annually or upon significant regulatory or business changes. Updates are made to reflect evolving threats and compliance obligations.

 15. Contact Us

For questions, concerns, or to report suspicious activity, please contact our Compliance Department:

compliance@s-interio.com
www.s-interio.com

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