AML / KYC
framework.

A risk-based AML/ATF compliance framework for client onboarding, review and transaction monitoring.

// Operational policy

Controls are designed to support applicable obligations under the PCMLTFA, its regulations and applicable FINTRAC requirements.

  1. [01]

    Mandatory client identification and verification

    Client identity and, where applicable, entity, authority and beneficial ownership information must be verified before a service relationship or transaction can be considered.

    KYC / KYB
  2. [02]

    Risk classification

    Client, jurisdiction, counterparty and transaction factors inform the level of review, controls and ongoing monitoring required.

    Risk-based review
  3. [03]

    Sanctions, PEP and adverse-media screening

    Applicable sanctions, politically exposed person, adverse-media and other screening may be performed before and during a relationship or transaction.

    Screening
  4. [04]

    Source of Funds and Source of Wealth

    Information and supporting evidence relating to Source of Funds, Source of Wealth and transaction purpose may be required where appropriate.

    Due diligence
  5. [05]

    Enhanced Due Diligence

    Enhanced Due Diligence and additional measures may be applied where the risk profile, transaction context or applicable requirements require them.

    Conditional
  6. [06]

    Transaction monitoring and recordkeeping

    Transactions are subject to monitoring and review against the client profile, expected activity and applicable AML/ATF compliance obligations.

    Ongoing review
// Review materials

Information may be required to complete the review.

  • Identity documents
  • Corporate documents and authority evidence
  • Beneficial ownership details
  • Source of Funds and Source of Wealth information
  • Transaction purpose and settlement context
// Review outcome

PAYNOMIC FINANCE CORP. may request additional information, suspend or freeze processing, delay settlement, refuse onboarding, restrict activity, decline or terminate a transaction, or terminate a relationship where required by law, risk controls or compliance concerns. Reasons may not be provided where disclosure could interfere with AML/ATF, sanctions or other compliance obligations.

No anonymous activity.No execution without an appropriate review.
// Mandate review

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