Our compliance program
Our program includes:
A Compliance Officer, appointed by senior management, who is responsible for the program and has the authority and resources to run it.
Written policies and procedures that are kept up to date and approved by senior management.
A risk assessment of our customers, services, delivery channels and geographic exposure, used to decide where stronger measures are needed.
Ongoing training for every staff member who deals with customers or transactions, when they are hired and at least once a year after that.
An effectiveness review of the whole program at least every two years.
Knowing our customers
We verify every customer’s identity with valid, original, government-issued photo ID before we issue a loan or buy gold or jewellery. For money transfers, foreign exchange and other transactions, we verify identity whenever the law or Western Union requires it.
We do not carry out transactions for anonymous customers or under a false name.
We ask about the purpose of a transaction and the source of funds where the law requires it, or where something seems unusual.
Where required, we determine whether a customer is a politically exposed person, the head of an international organization, or a family member or close associate of one, and we apply stronger measures to higher-risk customers.
For businesses and other organizations, we confirm that the entity exists and take reasonable measures to identify its beneficial owners.
We keep customer information up to date and monitor ongoing business relationships.
Monitoring and reporting
We watch for signs of money laundering or terrorist financing, such as:
Transactions split into smaller amounts to avoid reporting thresholds
Customers who are unwilling to provide identification or information
Transactions that do not fit what we know about the customer
A third party directing or paying for a customer’s transaction
Transfers involving high-risk or sanctioned countries
We file reports with FINTRAC as the law requires, including:
Suspicious transaction reports: whenever we have reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist financing, whatever the amount.
Large cash transaction reports: where the law requires them, when we receive $10,000 or more in cash in a single transaction, or in several transactions that total $10,000 or more within 24 hours.
Terrorist property reports: when we know or believe that property is owned or controlled by, or on behalf of, a terrorist group or a listed person.
Any other report required of us under the PCMLTFA.
We do not tell customers that a report has been or will be made.
Sanctions screening
We screen customers and transactions against Canadian sanctions and terrorist lists, including those made under the Criminal Code, the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act and the United Nations Act. We do not deal with listed persons or entities, and we freeze and report their property as the law requires.
Record keeping
We keep identification, transaction and reporting records for at least five years, in a form that we can provide to FINTRAC within 30 days of a request.
Our right to refuse a transaction
We may refuse, delay or cancel any transaction, or end a customer relationship, if:
A customer will not provide the identification or information we need.
We cannot verify a customer’s identity.
We suspect that a transaction is related to money laundering, terrorist financing, fraud or another crime.
A transaction involves a sanctioned person, entity or country.
Cash, gold and jewellery
We may limit the amount of cash we accept or pay out in a single transaction or over a period of time.
Every purchase of gold, jewellery or other precious metals requires valid photo ID and is recorded. We do not buy items we believe to be stolen, and we cooperate with police investigations.
Staff responsibilities
All staff must follow this policy, complete AML/ATF training, and report any unusual or suspicious activity to the Compliance Officer right away. Failing to follow this policy may lead to discipline, up to and including dismissal.
Questions
Questions about this policy can be sent to our Compliance Officer at airportcashshop@gmail.com or (905) 793-6700.
