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Compliance Statement

AML POLICY

FINTRAC Regulation coming force June 1st, 2020

The Financial Transaction and Reports Analysis Centre of Canada (FINTRAC) is Canada’s anti money laundering (AML) and counter terrorist financing (CTF) financial intelligence unit (FIU) and regulator. 

 

The Government of Canada has made changes to what services make an individual or an entity an MSB in Canada to include virtual currency services; however, these changes are now in force.

 

 Individuals and entities engaged in the business of dealing in virtual currency services will be MSBs, and will need to Voluntarily register in advance of June 1, 2020 with FINTRAC.

 

Coin Maple Inc. is a registered money services business with MSB registration number: M19601455 with Initial date of registration on: 2019-11-28

 

 Our Interpretation of Compliance

 

That being said, as a registered MSB we do have obligations to our partners to undertake a compliance program to ensure that we are proactive with the new changes that are being proposed by the New Retail Framework from the Department of Finance Canada, that the MSB regulations as administered by FINTRAC which is now extended to crypto currencies.

 

These activities include;

 

  • Assigning a Compliance Officer,
  • Acquiring Board level approval for the compliance program,
  • Know Your Customer and Customer Due Diligence,
  • Limits and control based on client verification levels,
  • A documented Risk Assessment
  • Transaction Record Keeping,
  • Periodic reviews of the effectiveness of our Compliance Programs and Operations.
  • Ongoing monitoring for suspicious activity relating Proceeds of Crime, Money Laundering, and Terrorist Financing,
  • Not conducting and prohibiting any relationship/accounts with Shell Banks.
  • Ongoing Training for all employees, staff, and Management (including board of directors), and,
  • Voluntary reporting to FINTRAC for suspicious activity.

 

 If you have any questions related to our compliance program, please feel free to contact us using our contact form.

 

 Last updated: June 2nd, 2020

KYC POLICY

Individual Accounts Verification:

We currently verify the identity of all users through one of the following methods:

 

Manual Verification (By our KYC team)

 

As part of the account sign up process, all our clients are asked to upload to our site the Canadian government issued photo ID, Selfie photo with a signature. Our compliance team may ask for any additional documents such as proof of address or a second ID. All documents must appear to be valid and unaltered in order to be acceptable.  If any information has been redacted, it is not acceptable. 

Corporations Accounts Verification:

 

For Institutional clients, we are obligated to confirm the existence of the entity, and the entity’s beneficial ownership.

Corporations:

In order to confirm the existence of a corporation as well as the corporation’s name and address, we require the following documents:

  • Power to bind the corporation – Articles of incorporation (with Full names of all Directors and at least 3 Authorized Signatories (if any)
  • Proof of existence:

 

  1. Certificate of Corporate Status (if incorporated within the previous 12 months);
  2. Corporation Profile Report;
  3. A record that has to be filed annually under provincial securities legislation; corporation’s published annual report signed by an independent audit firm; or
  4. A letter or a notice of assessment from a municipal, provincial, territorial or federal government.

 

  • Proof of address (utility bill, bank statement or any government record) – if not in the first or second bullet above
  • Trade name registration, if applicable
  • Beneficiary ownership attestation (BOA) form and ID on the ultimate beneficiary. Also, names and addresses of the individuals who are the beneficial owners, for example directors or shareholders, i.e. any actual person who owns or controls, directly or indirectly, 25% or more of the corporation’s shares, if nobody controls – information confirming that there is no actual person.
  • Signed Corporate Resolution
  • Completed the CoinMaple signup application form.

 

Entities other than a Corporation

We confirm the existence of an entity other than a corporation by referring to a partnership agreement, articles of association or any other similar record that confirms the entity’s existence. In confirming an entity’s existence, we must be able to refer to a paper or electronic record and retain a copy of it. Verbal confirmation is not sufficient. Electronic records must be from a public source and we must record the type and source and corporation’s registration number. 


Not-for-profit organization 
If the entity is a not-for-profit organization, we also have to do the following:

  1. Determine whether or not the entity is a registered charity for income tax purposes 

  2. If that entity is not a registered charity, determine whether or not it solicits charitable financial 
donations from the public