AML Policy

Our commitment

Caibo Inc. (“Caibo”) is committed to detecting and preventing money laundering, terrorist financing, and other financial crime. We maintain an AML/ATF compliance program appropriate to our business as a Money Services Business.

Regulatory framework

Caibo is registered with FINTRAC as a Money Services Business (MSB registration number C100000990) and is subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations.

Compliance officer

We have appointed a Compliance Officer responsible for the AML/ATF program, its implementation, and its ongoing effectiveness.

Risk-based approach

Our program applies a risk-based approach, assessing and mitigating money-laundering and terrorist-financing risks across customers, products, channels, and geographies.

Customer due diligence (KYC / KYB)

We verify the identity of every customer before providing the Service. For businesses, we perform Know-Your-Business (KYB) checks and identify and verify beneficial owners (UBOs).

Ongoing monitoring

We monitor activity on an ongoing basis to identify unusual or suspicious transactions, and we apply enhanced measures to higher-risk relationships.

Sanctions screening

We screen customers and transactions against applicable sanctions and watchlists, including OFAC and Canadian lists, before funds move.

Regulatory reporting

We file the reports required by law, which may include:

• Suspicious Transaction Reports (STRs);
• Large Cash and Large Virtual Currency Transaction Reports, where applicable;
• Terrorist Property Reports; and
• Travel-rule records for qualifying transactions (generally CAD 1,000 and above).

Recordkeeping

We keep the records required by law for the mandated periods, generally five years.

Training and independent review

Relevant staff receive AML/ATF training, and the program is subject to periodic independent review, as required by law.

Contact

AML and compliance enquiries: compliance@caibo.ca.

Caibo Inc., 18 King Street East, Suite 1400, Toronto, Ontario M5C 1C4, Canada.