Anti-Money Laundering Policy

Vianta Payments Ltd. (“Vianta”) is committed to preventing money laundering and the financing of terrorism (ML/TF). We operate a risk-based AML/CTF compliance program, approved by senior management and administered by a dedicated AML Compliance Officer, to detect, deter, and report financial crime across our services.

Vianta is a Money Services Business (MSB) registered with, and supervised by, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

• FINTRAC MSB registration: N300000245
• Incorporated in Canada: BC1578557
• Registered office: 2nd Floor, Suite 203, 2121 160 St, Surrey, BC V3Z 9N6, Canada

We renew our FINTRAC registration every three years and maintain our program in line with regulatory change.

Our program is built on Canadian law and international standards, including:

• Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations
• Retail Payment Activities Act (RPAA)
• Applicable Canadian, United Nations, European Union, and United States sanctions regimes
• Financial Action Task Force (FATF) standards

Grounded in a risk-based approach, our program includes:

• Senior-management oversight and a dedicated AML Compliance Officer as the central point of contact for FINTRAC
• Customer due diligence (CDD) and Know Your Customer (KYC) checks
• Sanctions and watch-list screening
• Ongoing transaction monitoring
• Suspicious transaction reporting to FINTRAC
• Record-keeping and data retention
• A documented staff training program
• Regular independent review of the program’s effectiveness

Before and during a business relationship, and proportionate to assessed risk, we:

• Verify the identity of the business and its authorised representatives against independent, credible sources
• Identify beneficial owners holding 25% or more of an organisation
• Establish the purpose and intended nature of the relationship and expected activity
• Request source of funds and source of wealth where higher risk is present
• Identify politically exposed persons (PEPs) and apply enhanced due diligence
• Where virtual-currency activity is involved, verify wallet ownership and screen it using blockchain analytics

Services are provided on a non-face-to-face basis, and we may request additional information or documentation at any time.

We screen customers, beneficial owners, and counterparties against applicable sanctions and watch lists — including those maintained by OFAC, the United Nations, the European Union, and Canada’s OSFI — before onboarding and on an ongoing basis. We do not establish or maintain relationships with sanctioned persons or entities, or provide services into comprehensively sanctioned jurisdictions. Transactions involving sanctioned parties are blocked and reported to the relevant authorities.

We monitor transactions on a risk-sensitive basis for activity inconsistent with what we know about a customer. Where we have reasonable grounds to suspect a transaction is related to money laundering or terrorist financing, we file a Suspicious Transaction Report (STR) with FINTRAC; there is no monetary threshold for suspicious-transaction reporting.

In line with Canadian requirements, we also:

• Transmit required originator and beneficiary information with electronic funds transfers of CAD 1,000 or more (the “Travel Rule”)
• Report large cash transactions of CAD 10,000 or more (Vianta does not currently accept cash from customers)

We will not establish or maintain a relationship with, among others:

• Persons or entities on international sanctions lists (OFAC, UN, EU, OSFI)
• Customers in comprehensively sanctioned jurisdictions
• Shell companies with no identifiable beneficial owner or legitimate business purpose
• Anonymous customers, or those unwilling to provide required identification
• Customers whose source of funds or wealth cannot be satisfactorily established
• Customers presenting falsified or suspect documents, or suspected of involvement in illegal activity

We retain customer identification, beneficial-ownership, transaction, and related records for a minimum of five years, in accordance with the PCMLTFA.

All staff complete AML/CTF training appropriate to their role, refreshed on a regular schedule so they can recognise and escalate suspicious activity. Information collected for AML/CTF purposes is handled confidentially and used only to meet our legal obligations to prevent money laundering and terrorist financing.

Questions about this policy or our AML/CTF program can be directed to our compliance team at compliance@payvianta.com.