Anti-Money Laundering Policy
We work hard to ensure that every purchase on CBlocks is safe, secure, and doesn't support terrorists.
CBlocks Technologies Unlimited Liability Company (“Company”) has developed an anti-money laundering policy that goes beyond legislative requirements and reflects management's principles on managing money laundering and terrorist financing risks.
1. Status as Money Service Business in Canada
We are not classified as a Money Services Business, however we take the same precautions to protect our users.
Our Company has been notified by Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) that we are not engaged as a Money Service Business (“MSB”) in Canada as per the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“PCMLTFA”) and its associated Regulations. We check the FINTRAC website regularly for information on the status of regulations and the need for virtual currency businesses such as ours to register as MSBs in Canada.
Despite FINTRAC’s affirmation that we are not a MSB, we recognize the importance of maintaining a strong KYC-AML process. We have adopted a set of procedures designed to fit within the framework set forth by FINTRAC’s requirements, should our MSB status change.
2. The Proceeds of Crime (Money Laundering) and Terrorist Financing Deterrence Act (“PCMLTFA”)
Just a few steps to ensure we are doing our best to prevent money laundering
Our Company has certain record keeping, identification and reporting requirements. Our Company has chosen to implement and maintain a compliance regime which includes:
- The appointment of a chief anti-money laundering officer;
- The development and application of compliance policies and procedures.
- Instituting lifetime purchase limits of $1000 CAD for any customer or entity that wishes to conduct business.
- Executing Know Your Customer (“KYC”) procedures on all customers that meet qualifying guidelines;
- An assessment of our risks as it relates to money laundering and terrorist financing;
- Monitor transactions for potentially suspicious and attempted suspicious activities for purposes of filing Suspicious Transaction Reports (a “STR”);
- Maintaining and providing written, on-going compliance training for our employees; and
- A regular review of our compliance regime to test its effectiveness related to money laundering and terrorist financing every 2 years.
3. Appointment of a Chief Anti-Money Laundering Officer
Getting the right person for the job.
Under the PCMLTFA requirements, CBlocks has a chief anti-money laundering officer (“CAMLO”), who is responsible for the implementation of our compliance regime. The CAMLO has the authority and the resources to ensure the ongoing compliance of our organization as it relates to money laundering and terrorist financing identification and prevention.
4. Ongoing Monitoring of Business Relationships
If you purchase one of our service offerings, we consider you a business relationship. So, we will treat each and every relationship with the same respect and security.
We regard a business relationship to be with any customer that places an order with us. For any customer who conducts any transaction, we:
- Ascertain the identity of the individual; or
- Confirm the existence of a corporation or other entity.
The identity of the individual customer is ascertained by:
- Collecting the customer’s name and billing address, via address verification service (“AVS”), a multi-layered fraud prevention system;
- Verifying that the customer’s name and shipping address match their billing details; and
- Requiring the customer’s signature for delivery.
The customer’s country of residence is verified by shipping only to those with a billing and shipping address in Canada.
CBlocks considers all accounts/wallets to be business relationships and accordingly, follows the regulatory requirements of:
- Risk rating all our business relationships;
- Conducting ongoing monitoring of the business relationship at a frequency commensurate to our clients’ risk; and
- Keeping a record of the measures that we have taken to monitor the relationship and the information we obtained as a result.
5. Record Keeping
There is no limit to when and if we will submit information to FINTRAC. We will always report suspicious activity.
While we are not required to register with FINTRAC as a MSB, we monitor for and keep track of any suspicious activity. We may notify FINTRAC of any such suspicious activity, although there is no obligation to do so. We expect this policy to change, in the event that our status as MSB changes.
6. KYC Processes
This is a long read, but we outline how we identify you. When we identify you. What we do if you're a business, non-profit, or just a regular Jim.
CBlocks strictly imposes a purchase limit of $1,000 CAD per customer, in aggregate.
Accounts are only made available to entities with a Canadian billing and mailing address with Canadian debit or credit card in order to mitigate against the risk of money laundering and terrorist financing activities.
Customers are verified by way of order and payment processing (see Section 4). We verify that the customer’s billing and shipping addresses match, and we ship exclusively to addresses in Canada.
7. Record Maintenance
We keep our records in a safe and secure place to easily help with preventing money laundering or terrorist transactions.
While we are not required to register with FINTRAC as a MSB, we maintain an effective recordkeeping system, in case there is a need to provide FINTRAC with timely access to pertinent data. We keep records for up to 365 days from initial activity and back up our records on an hourly basis. Should such a need arise, our records have to be kept in such a way that they can be provided to FINTRAC within 30 days of a request to examine them.
8. Suspicious Transaction Reports
We will report anything we deem as suspicious to FINTRAC. As a member of the Canadian community we will do our part to help compat terrorism and money laundering.
While we are not required to register with FINTRAC as a MSB, we may report any transactions or attempted transaction that we suspect relates to money laundering or terrorist activity financing regardless of the amount.
The CAMLO has the authority to notify with FINTRAC of any suspicious transactions and will maintain a log of any such notifications.
Tax evasion is also considered a predicate offense for money laundering; accordingly, if we suspect transactions are being undertaken to avoid or evade paying income taxes we may report the transactions as suspicious to FINTRAC.
9. Continual Monitoring of Business Relationships
As part of our efforts to prevent money laundering or terrorist funding we will continually monitor each transactin that happens on CBlocks.
If in the course of reviewing and monitoring customer transactions we identify unexplainable, unusual activity, patterns or have any questions, we will work to obtain further information so that these questions are satisfactorily answered and/or we will report the activity internally to the CAMLO who is required to maintain a record/log of all internally reported and perform a review to determine if a notification should be provided to FINTRAC. If we have not reached a clear understanding of the sources and movement of funds, it may result in the account being permanently closed. This will be followed by terminating the relationship with the de-marketed account owner and placing them on the de-market list without the right of re-opening a new account unless authorized by the senior management and the CAMLO.