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: