AML Policy

1. Our Commitment

Coinberry is committed to preventing, detecting and deterring fraud, money laundering and terrorist financing. Coinberry has a no-tolerance fraud, money laundering and terrorist financing policy and actively engages the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), the Royal-Canadian Mounted Police (RCMP) and other law enforcement agencies when users engage in activities contrary to this policy.

Coinberry is a reporting entity under current Canadian anti-money laundering (AML) and counter terrorist financing (CTF) legislation and is registered as a Money Service Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

2. Compliance Program

Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations, Coinberry has an AML & CTF program that consists of these five elements

  1. Written policies and procedures: these list our responsibilities under the law, and what we are doing to meet them;
  2. A documented Risk Assessment: a document that describes and assesses the risk that our business could be used to launder money or finance terrorism;
  3. The appointment of a Compliance Officer: the person who is ultimately responsible to develop and maintain our AML and CTF compliance program;
  4. AML Compliance Effectiveness Reviews: testing and reporting completed either annually or every two years that assesses how well our compliance program is working; and
  5. Training: conducted at least annually to ensure that everyone understands his or her roles and responsibilities.
3. Operational Compliance

In addition to our documented program that consists of the five elements, Coinberry also operate in a FINTRAC compliant manner. This includes:

  • Collecting and recording client identification and know your customer (KYC) information, in accordance with legal requirements, prior to granting users access to our platform,
  • Reporting certain types of transactions to regulators and government agencies including, but not limited to, transactions suspect to be originating from or connected to terrorist, money laundering, tax evasion, fraud or other illegal activities,
  • Maintaining appropriate registration and licensing, and
  • Keeping all user and transaction records in a manner required by law.