AML &
Compliance
Program.
Public overview of the risk-based AML/ATF controls supporting PAYNOMIC FINANCE CORP.'s non-custodial OTC digital asset brokerage services.
This summary reflects the Company’s signed AML/CTF Policy, Operational Procedures Manual and Enterprise-Wide Risk Assessment. It does not expand the services offered through this website.
Paynomic Finance Corp. maintains an Anti-Money Laundering and Anti-Terrorist Financing compliance program designed to meet applicable requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), its regulations and guidance issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Paynomic has designated a Compliance Officer responsible for the administration, oversight and effectiveness of the AML/ATF compliance program.
- [01]EWRA
Enterprise-Wide Risk Assessment
The Company maintains an EWRA that assesses inherent and residual risk across client types, products and services, geographies, delivery channels, transaction patterns and third-party dependencies. It is reviewed at least annually and when material changes occur.
- [02]KYC / KYB
Client due diligence and third-party determination
Before a relationship or transaction is considered, Paynomic applies client identification and verification, entity and authority review where applicable, beneficial-ownership review, and an assessment of the purpose and intended nature of the relationship. Paynomic may assess whether a client is acting on behalf of another individual or entity and may require supporting documentation.
- [03]Risk tiering
Risk-based controls
Client risk ratings determine the level of review, monitoring and approval required. Higher-risk cases may require Enhanced Due Diligence, senior approval, additional documentation and more frequent review.
- [04]Screening
Screening and source review
Controls may include sanctions, PEP, Head of International Organization (HIO) and adverse-media screening, together with Source of Funds, Source of Wealth and transaction-purpose review where appropriate. PEPs, HIOs, family members and close associates may be subject to Enhanced Due Diligence.
- [05]Ongoing review
Monitoring and escalation
Transactions and client activity are reviewed against the client profile and expected activity. Alerts, unusual activity and material red flags are documented, investigated and escalated through defined case-management procedures.
- [06]Accountability
Recordkeeping, reporting and Travel Rule
Records obtained through KYC, KYB, transaction monitoring and compliance reviews are retained in accordance with applicable legal and regulatory requirements. The program maintains procedures for identifying, escalating and reporting suspicious transactions where required by applicable law. It also maintains records, audit trails and escalation documentation designed to support applicable AML/ATF recordkeeping and reporting obligations, including obligations arising under the PCMLTFA, its regulations and applicable FINTRAC requirements. Where applicable, Paynomic may collect, verify and transmit originator and beneficiary information in accordance with applicable Travel Rule obligations.
- [07]Effectiveness
Training and independent review
Relevant personnel receive periodic AML/ATF training appropriate to their responsibilities. The AML/ATF Program is subject to periodic effectiveness reviews and independent testing designed to assess the adequacy and practical operation of its policies, procedures, risk assessment, monitoring, escalation and reporting controls.
Compliance review is not a service guarantee.
- Service access remains subject to onboarding, compliance review and contractual arrangements.
- Completion of KYC/KYB does not guarantee client acceptance or transaction execution.
- Paynomic may request additional information or apply Enhanced Due Diligence.
- Transactions may be delayed, rejected, restricted or terminated where required by law or risk controls.
- Additional compliance documentation may be provided to financial institutions and counterparties upon request, subject to confidentiality requirements.
- Paynomic does not provide custody, wallet, banking, lending or payment-account services.
Paynomic Finance Corp. is incorporated in British Columbia under incorporation number BC1541366 and is registered with FINTRAC as a Money Services Business under registration number C10001625. Paynomic is a non-custodial OTC digital asset broker. It does not provide banking services, deposit-taking services, savings products, lending services, custody services, investment management services or securities brokerage services. Funds received from clients are accepted solely for the purpose of settling OTC digital asset transactions.
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