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AML/ KYC Policy

GENERAL PAYMENTS GATE LIMITED, a company incorporated in Canada is registered by FINTRAC under the registration number M22457458. As a registered with FINTRAC 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.
  • Identitiy document information;
  • Information on your soruce 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:
  1. Afghanistan
  2. American Samoa
  3. Angola
  4. Anguilla
  5. Bahamas
  6. Barbados
  7. Belarus
  8. Belize
  9. Benin
  10. Bonaire, Saint Eustatius
  11. and Saba
  12. Botswana
  13. British Indian Ocean
  14. Territory
  15. Burkina Faso
  16. Burundi
  17. Cambodia
  18. Cameroon
  19. Central African Rep
  20. Chad
  21. Christmas Island
  22. Cocos (Keeling) Islands
  23. Colombia
  24. Congo (Brazzaville)
  25. Congo, the Democratic Republic
  26. Cook Islands
  27. Cuba
  28. Djibouti
  29. Dominica
  30. Egypt
  31. El Salvador
  32. Equatorial Guinea
  33. Eritrea
  34. Ethiopia
  35. Fiji
  36. Gaza Strip (Palestinian
  37. Territory)
  38. Ghana
  39. Guam
  40. Guinea
  41. Guinea Bissau
  42. Haiti
  43. Iran, Islamic Republic of
  44. Iraq
  45. Jamaica
  46. Kiribati
  47. Lebanon
  48. Liberia
  49. Libya
  50. Mali
  51. Myanmar
  52. New Caledonia
  53. Nicaragua
  54. Niger
  55. Nigeria
  56. Norfolk Island
  57. North Korea
  58. North Mariana Islands
  59. Pakistan
  60. Palau
  61. Panama
  62. Russian Federation
  63. Rwanda
  64. Saint Barthelemy
  65. Saint Martin (French part)
  66. Saint Pierre and Miquelon
  67. Samoa
  68. Seychelles
  69. Sierra Leone
  70. Somalia
  71. South Sudan
  72. St Maarten
  73. Sudan
  74. Syria
  75. Tajikistan
  76. Tokelau
  77. Trinidad & Tobago
  78. Turkmenistan
  79. Uganda
  80. United States Virgin
  81. Islands
  82. Vanuatu
  83. Venezuela
  84. West Bank (Palestinian Territory)
  85. Western Sahara
  86. Yemen
  87. Zambia
  88. Zimbabwe
  89. Western Sahara
  90. Yemen
  91. Zambia
  92. 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.