Compliance Policies

Advapay Canada has developed and helped to implement over 50 compliance programs for Money Services Businesses operating in a wide range of business models: neo-banks and e-wallets, crypto-fiat wallets, remittance and money transfer operators, card issuers and acquirers. The policies we have written are fully compliant and accepted by all banks, including Tier-1 banks in the USA and Europe.

What is a compliance program

Compliance program is a set of policies, procedures, and controls put in place by Money Services Businesses to ensure compliance with regulatory requirements. Appointment of the compliance officer is another vital element of the compliance program.

Why having a compliance program is mandatory

Having a robust compliance program is mandatory to operate legally, manage risk, and protect the reputation of the business. A comprehensive compliance program also helps to increase business’s credibility in the eyes of banking partners.

What you should not do

Operate without a compliance program. It is illegal, and you risk having your MSB registration revoked.

Use a compliance program developed for other jurisdictions. They will not meet Canadian requirements.

Use policies based on generic templates. It will be impossible to implement for your unique business model and bank account applications will be rejected.

Integral parts of a compliance program

Our services include, but are not limited as to:

Written AML/CTF Policies and Procedures
MSBs must develop and implement written policies and procedures that outline how they will identify, assess, mitigate, and monitor money laundering and terrorist financing risks. These policies and procedures should be tailored to the specific nature and size of the MSB's operations.
Know Your Customer (KYC) Procedures
MSBs are required to establish procedures for verifying the identity of their customers and conducting ongoing due diligence. This includes collecting information such as name, address, date of birth, and occupation, as well as monitoring transactions for suspicious activity.
Risk Assessment
MSBs should conduct a thorough assessment of the money laundering and terrorist financing risks associated with their business activities, customers, products, services, and delivery channels.
Reporting Obligations
MSBs must have procedures in place for reporting certain transactions to FINTRAC, including large cash transactions, electronic funds transfers, and suspicious transactions. These reports help authorities detect and prevent money laundering and terrorist financing activities.
Record-Keeping Obligations
MSBs must maintain records of customer transactions, identification documents, and any other relevant information for a specified period as required by law.
Employee Training
MSBs should provide regular training to employees on their obligations under AML/CTF laws and regulations, as well as how to recognize and report suspicious transactions.
International Aspect
For MSBs that are operating across the globe, the policies must exceed local regulatory requirements in order to satisfy banking partners in different jurisdictions. We take a customized approach to developing supplementary policies in accordance with the best AML practises in the world to give our clients access to international markets.

How we write custom compliance programs

Preparing drafts of the policies based on the list of services, the nature of the client's business, and the client base.

Going through 2-3 rounds of feedback from clients, during which we gradually detail the policies and align them with the vision of stakeholders while remaining compliant with regulations.

Delivery of the final version to the client.

Updating the policies in case of changes in the business model or regulatory rules.