Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy

Last updated: October 20, 2026

Operator: AURONEX Finance INC.

Corporate Registration Number: 1001662431

FINTRAC MSB Registration Number: N300002169

Introduction

AURONEX Finance INC. (“Auronex”, the “Company”, “we”, or “us”) is a Canadian Money Services Business registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under registration number N300002169.

This Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) Policy outlines the principles and measures adopted by Auronex to prevent its services from being used for money laundering, terrorist financing, sanctions evasion, financial fraud, and other unlawful activities.

The Company's AML/CFT framework is based on applicable Canadian legislation, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), its associated regulations, and relevant sanctions requirements.

The Policy applies to the Company's financial services, including international money remittance, currency exchange, and virtual currency services, where offered.

Definitions

Anti-Money Laundering (AML) — laws, regulations, policies, and procedures intended to prevent the concealment or legitimisation of funds obtained through unlawful activities.

Counter-Terrorist Financing (CFT) — legal and regulatory measures designed to prevent funds or other financial resources from being used to support terrorist activities or organisations.

Client Due Diligence (CDD) — procedures used to identify and verify Clients, understand their business activities, and assess the risks associated with establishing or maintaining a business relationship.

Enhanced Due Diligence (EDD) — additional verification, assessment, and monitoring measures applied to Clients or Transactions presenting elevated money laundering or terrorist financing risks.

Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) — Canada's financial intelligence unit and regulatory authority responsible for supervising compliance with applicable anti-money laundering and counter-terrorist financing obligations.

Know Your Customer (KYC) — procedures for identifying and verifying individual Clients and authorised representatives.

Know Your Business (KYB) — procedures for verifying legal entities, their ownership structures, directors, representatives, and business activities.

Politically Exposed Person (PEP) — an individual who holds or has held a specified prominent public position or function, as defined by applicable legislation.

Risk-Based Approach (RBA) — a methodology used to identify, assess, and manage money laundering and terrorist financing risks according to the characteristics of Clients, Transactions, products, services, and jurisdictions.

Suspicious Activity — activity or a Transaction that raises concerns regarding potential money laundering, terrorist financing, sanctions evasion, or related unlawful conduct.

Suspicious Transaction Report (STR) — a report submitted to FINTRAC where the applicable legal threshold for reporting a suspicious Transaction or attempted Transaction is met.

Client Due Diligence (CDD) and Enhanced Due Diligence (EDD)

Auronex's customer due diligence framework requires identification and verification of Clients in accordance with applicable Canadian regulatory requirements.

Before establishing a business relationship or providing Services, the Company may require Clients to submit identification documents, corporate registration records, and information regarding their business activities.

For corporate Clients, verification may include:

  • Legal name and registration details;
  • Business address and jurisdiction of incorporation;
  • Identification of directors and authorised representatives;
  • Ultimate beneficial ownership and control structure;
  • Nature and purpose of the business relationship;
  • Expected transaction volumes and payment activities;
  • Source of funds and, where appropriate, source of wealth.

Additional documentation may be requested to verify the legitimacy of a Client's activities or the purpose of a Transaction.

Enhanced due diligence measures apply where higher-risk circumstances are identified. Such measures may include additional identity verification, supporting documentation, assessment of beneficial ownership, source-of-funds enquiries, and increased Transaction monitoring.

The Company may decline to establish or continue a business relationship where satisfactory verification cannot be completed or where the associated risks cannot be adequately managed.

Ongoing Due Diligence (ODD)

Customer due diligence is an ongoing process throughout the business relationship.

Auronex's compliance framework provides for reviewing Client information and assessing whether it remains accurate, complete, and consistent with the nature of the relationship.

Additional reviews may be required where there are material changes to:

  • Corporate ownership or management;
  • Business activities and operating jurisdictions;
  • Expected or actual Transaction patterns;
  • Client risk classification;
  • Regulatory or sanctions-related circumstances.

Clients may be required to provide updated identification documents, corporate information, or explanations regarding specific Transactions.

Where significant discrepancies or risk indicators arise, the Company may conduct additional verification or reassess the business relationship.

Transaction Monitoring

Auronex's AML/CFT framework includes Transaction monitoring and review procedures designed to identify unusual or potentially suspicious activity.

Monitoring measures are applied according to the nature of the Services, the Client's risk profile, applicable legal requirements, and the characteristics of individual Transactions.

Particular attention may be given to:

  • Transactions inconsistent with a Client's declared business activities;
  • Unusual payment amounts, frequencies, or transaction patterns;
  • Transactions involving higher-risk jurisdictions;
  • Payments involving unidentified or unusual counterparties;
  • Unclear or insufficiently documented sources of funds;
  • Unusual virtual currency transfers or wallet activity;
  • Attempts to circumvent verification or reporting requirements.

The Company may request invoices, agreements, payment explanations, beneficial ownership information, or other supporting documents to assess a Transaction.

Where necessary, Transactions may be delayed, declined, or subjected to further review in accordance with applicable laws and contractual obligations.

Suspicious or unusual activity may result in a reassessment of the Client's overall risk classification.

Risk-Based Approach (RBA)

Auronex's AML/CFT framework incorporates a risk-based approach to identifying and managing financial crime risks.

Client and Transaction risks are assessed by considering relevant factors, including:

  • Client identity and beneficial ownership;
  • Nature of the Client's business activities;
  • Geographic locations and jurisdictions involved;
  • Products and financial services requested;
  • Payment methods and Transaction characteristics;
  • Source and destination of funds;
  • Politically exposed person status;
  • Sanctions exposure and adverse information;
  • Historical Transaction patterns, where available.

Clients presenting higher levels of risk may be subject to enhanced due diligence and additional monitoring requirements.

Risk assessments may be reviewed and updated where material new information, unusual activity, or changes in applicable regulatory requirements are identified.

Auronex reserves the right to decline onboarding, restrict Services, or terminate a business relationship where the associated risks are unacceptable or cannot be adequately mitigated, subject to applicable law.

Sanctions Regime and Client Screening

Auronex's compliance framework includes screening measures intended to identify persons, entities, and Transactions subject to applicable financial sanctions and restrictions.

Relevant screening may include Clients, directors, authorised representatives, beneficial owners, and counterparties, as appropriate.

Screening and verification measures may consider:

  • Applicable Canadian sanctions lists;
  • Relevant international sanctions requirements;
  • Politically exposed persons and related persons;
  • Adverse media and publicly available risk information;
  • Regulatory and law enforcement notices.

Additional screening or review may be conducted where changes in sanctions requirements, Client information, or Transaction circumstances create new risk concerns.

Auronex may refuse, restrict, suspend, or decline Transactions involving sanctioned persons, prohibited activities, or jurisdictions subject to applicable legal restrictions.

The Company cooperates with competent authorities and fulfils applicable sanctions-related reporting and disclosure obligations.

AML Compliance Officer

Auronex's AML/CFT compliance framework provides for the appointment of a Compliance Officer responsible for overseeing the implementation and maintenance of the Company's compliance program.

The Compliance Officer's responsibilities include:

  • Developing and maintaining internal AML/CFT policies and procedures;
  • Overseeing Client identification and due diligence processes;
  • Assessing money laundering, terrorist financing, and sanctions evasion risks;
  • Reviewing unusual or potentially suspicious activities;
  • Overseeing applicable regulatory reporting obligations;
  • Coordinating compliance training;
  • Maintaining and updating risk assessments;
  • Supporting periodic reviews of the effectiveness of the compliance program.

The Compliance Officer may cooperate with FINTRAC, law enforcement agencies, regulators, and other competent authorities in accordance with applicable legal requirements.

Suspicious Activity Reporting

Auronex is subject to applicable reporting obligations under Canadian anti-money laundering and counter-terrorist financing legislation.

Where the relevant legal reporting threshold is met, the Company is required to submit Suspicious Transaction Reports to FINTRAC in accordance with applicable reporting requirements.

The Company may also be required to submit other prescribed reports relating to specified financial transactions and activities.

Employees and authorised representatives must escalate potentially suspicious activity through the Company's internal compliance procedures.

Auronex may request additional information, restrict certain Transactions, or take other appropriate measures where financial crime concerns arise.

Information regarding suspicious activity and regulatory reporting is handled confidentially in accordance with applicable law.

The Company cooperates with lawful requests from regulatory, judicial, and law enforcement authorities.

AML Training

Auronex's AML/CFT compliance framework includes ongoing training requirements for employees and other authorised persons whose responsibilities may involve Clients, financial Transactions, or compliance-related activities.

Training is intended to support an understanding of:

  • Applicable AML/CFT legislation and regulatory obligations;
  • Customer identification and due diligence requirements;
  • Recognition of unusual or suspicious Transaction activity;
  • Sanctions compliance and financial crime risks;
  • Internal escalation and regulatory reporting procedures;
  • Record-keeping and confidentiality obligations;
  • Responsibilities associated with individual roles.

Training content and frequency are determined according to the relevant responsibilities, operational requirements, and identified compliance risks.

The training program is subject to review and updates to reflect changes in applicable legislation, regulatory guidance, and emerging financial crime risks.

Record-Keeping

Auronex is subject to record-keeping requirements under applicable Canadian legislation, including the PCMLTFA and associated regulations.

Records may include:

  • Client identification and verification documents;
  • Corporate registration and beneficial ownership information;
  • Business relationship and risk assessment records;
  • Transaction instructions and supporting documents;
  • Records of applicable regulatory reports;
  • Relevant compliance reviews and monitoring information.

Records are retained for the periods prescribed by applicable legislation. Depending on the record category, retention periods may be calculated from the date a record is created, the completion of a Transaction, or the termination of a business relationship.

Many records subject to FINTRAC requirements must be retained for at least five years, with the applicable starting point determined by the relevant legal provision.

Client and Transaction information is handled in accordance with applicable privacy, confidentiality, and information security obligations.

Such information may be disclosed to authorised personnel, financial service providers, regulatory bodies, or competent authorities where permitted or required by law.

Conclusion

AURONEX Finance INC. recognises the importance of preventing money laundering, terrorist financing, sanctions evasion, and other financial crimes within the financial services sector.

The Company maintains an AML/CFT compliance framework intended to address applicable regulatory obligations and the risks associated with its business activities.

Policies, procedures, and risk assessments are reviewed and updated as necessary to reflect regulatory developments, changes in business operations, and identified financial crime risks.

Questions About This AML/CFT Policy?

For questions regarding this Policy or the Company's compliance requirements, please contact:

AURONEX Finance INC.

7030 Woodbine Avenue, Suite 500
Markham, Ontario L3R 6G2
Canada

Email: legal@auronex.ca

Phone: +1 (289) 378-1950

Regulatory Information

Legal Entity: AURONEX Finance INC.

Corporate Registration Number: 1001662431

FINTRAC MSB Registration Number: N300002169

AURONEX Finance INC. is registered with FINTRAC as a Money Services Business (MSB), subject to confirmation of its current registration status and registered activities.

Registration with FINTRAC does not constitute a banking licence, government endorsement, or guarantee of the Company's financial services.

Auronex is not a bank. Services are subject to applicable regulatory requirements, Client eligibility, operational availability, and any relevant third-party financial institution arrangements.

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