AML and KYC statement

1. Our commitment

Nomos Pay is committed to preventing its services being used for money laundering, terrorist financing, sanctions evasion or other financial crime. We treat this as a condition of operating, not as an optional extra.

This statement summarises our approach so that customers, partners, counterparties and their advisers can understand what we do and what we will ask of them. It is a summary and not a complete description of our controls.

Our detailed anti-money laundering and counter-terrorist financing programme, including our risk assessment, thresholds, monitoring rules and internal procedures, is confidential. Publishing it would help the people it is designed to stop.

2. Regulatory framework

We are establishing our compliance programme to meet the obligations applicable to a money services business operating from Canada, including those under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations, together with applicable sanctions legislation.

Our registration details, including our FINTRAC money services business registration number [FINTRAC MSB REGISTRATION NUMBER], will be published on this page and on our compliance page once confirmed.

Registration means we are subject to obligations and to supervision. It is not an endorsement, an approval of our services, or a guarantee of any outcome, and it does not make us a bank.

3. Programme elements

1. A compliance officer with the seniority and authority to carry out the role, including the authority to stop a transaction or a relationship.
2. Written policies and procedures, kept current with changes in law and in our business.
3. A documented risk assessment covering our products, customers, delivery channels, geographies and counterparties.
4. A training programme for staff, with records of attendance.
5. An independent effectiveness review of the programme, carried out periodically as required.

4. Know your customer

We verify the identity of every customer before an account becomes fully operational, and we refresh that information over time.

• Individuals: identity verification using government identification and, where required, a liveness check and proof of address.
• Businesses: verification of the entity, its formation documents and registered details, together with the identity of directors and of every beneficial owner meeting the applicable ownership or control threshold.
• Beneficial ownership: we trace ownership through intermediate entities to the ultimate natural persons, and take reasonable measures to confirm the accuracy of the information.
• Purpose and nature: we ask what the account is for, the expected activity, volumes, currencies, counterparties and jurisdictions.
• Source of funds and, where the risk requires it, source of wealth.
• Enhanced due diligence for higher-risk relationships, including politically exposed persons and higher-risk jurisdictions or activities.

5. Screening

We screen customers, beneficial owners, directors and, where relevant, counterparties against applicable sanctions lists, politically exposed person lists and adverse media sources, both at onboarding and on an ongoing basis.

For digital assets, we also use blockchain analytics to assess the risk associated with deposit and withdrawal addresses and their exposure to sanctioned entities, darknet markets, mixers and known theft.

A screening alert may cause a transaction to be delayed, refused, blocked or reported, and may cause an account to be restricted while we review it.

6. Transaction monitoring

We monitor activity on an ongoing basis against the profile you gave us at onboarding. Monitoring looks for patterns that are unusual for the customer, including transactions inconsistent with a stated business purpose, structuring to stay below reporting thresholds, rapid movement in and out, unexpected counterparties or jurisdictions, and activity following a period of dormancy.

Alerts are reviewed by our compliance function. Review may involve asking you for further information about a transaction, its purpose or its counterparty.

7. Reporting obligations

Where the law requires it, we report to the relevant authority. Reports we may be required to file include suspicious transaction reports, large virtual currency transaction reports, large cash transaction reports where applicable, electronic funds transfer reports, and reports concerning the property of listed persons or entities.

Reporting thresholds and timing are set by law. Where transactions must be aggregated within a defined period for threshold purposes, we apply that aggregation.

Where we file a report, the law may prohibit us from telling you that we have done so, or from explaining why a transaction was delayed or refused. If our answer to a question seems incomplete, that may be the reason, and it is a legal requirement rather than a choice.

8. Travel rule

For transfers at or above the applicable threshold, we are required to obtain, hold and transmit prescribed information about the originator and the beneficiary, and to receive that information on incoming transfers. This applies to electronic funds transfers and to virtual currency transfers.

Where required information is missing from an incoming transfer, we take reasonable measures to obtain it and apply our written policies to decide whether the transfer should proceed, be suspended or be rejected.

9. Record keeping

We retain identity records, transaction records, compliance decisions and supporting documentation for the periods required by applicable law, and we keep them in a form that can be produced to an authority on request.

These retention obligations override a request for deletion. Our Privacy Policy explains how this interacts with your privacy rights.

10. What this means for you

• You will be asked for identification documents, and businesses will be asked for ownership and activity information, before an account is opened.
• You may be asked for further information later, including about a specific transaction or counterparty, and prompt responses avoid delays.
• Transactions may be delayed, refused or reported where our obligations require it.
• Accounts may be restricted or closed where we cannot satisfy our obligations, or where required by law or by a partner.
• We cannot support the activities listed in our Acceptable Use Policy.

11. Contact

Compliance enquiries, including diligence requests from banking partners, providers and auditors, should be sent to [COMPLIANCE EMAIL]. If you are unhappy with how a matter has been handled, our Complaints Policy explains how to raise it formally.

Entity and contact details

These details will be completed and confirmed by counsel before publication. Where a placeholder appears below, the information has not yet been confirmed and must not be relied upon.