CRABSI PAYMENTS CORP., a company established under the laws of Canada, is registered at 80 Atlantic Ave, Toronto, Ontario, Canada, M6K1X9 under the registration number 1000491725, and was incorporated on 05.04.2023. The company operates through its website: https://crabsi.com.

This AML Compliance Policy (hereinafter referred to as the “Policy”) has been developed in line with international anti-money laundering (AML) standards and applicable Canadian laws, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

CRABSI PAYMENTS CORP. (hereinafter referred to as the “Company”) is committed to preventing money laundering, terrorist financing, and related financial crimes through robust internal controls, procedures, and compliance measures.

The Policy establishes:

• Obligations for the Company and its employees.
• Processes for client verification, risk assessment, and transaction monitoring.
• Measures to ensure compliance with FINTRAC requirements.

The Policy applies to all clients utilizing the Company’s services.

Approval and Review

This Policy is approved and updated annually by the Company’s senior management to align with regulatory changes and industry best practices.

Control Methods

The Company employs a set of control methods to:

• Verify client identity and assess risks during onboarding and throughout the business relationship.
• Monitor transactions to detect and prevent suspicious activities.

Control methods include Know-Your-Client (KYC), Know-Your-Business (KYB), and Know-Your-Transaction (KYT) procedures, as prescribed by AML legislation and internal guidelines.

Client Identification

The Company conducts initial verification based on identification documents provided by clients:

• For individuals: Full name, government-issued ID, date of birth, address, tax residency, source of funds, and political exposure status.
• For legal entities: Corporate registration details, beneficial ownership and board management information, and documentation confirming the authority of representatives.

Verification is conducted using official sources, state registries, or notarized documents when required. Clients must be prepared to provide:

• Proof of identity (passport, national ID card, or driver’s license).
• Proof of address (utility bills, bank statements, or rental agreements).
• Source of funds (bank statements, pay slips, or investment records).
• For legal entities: Certificates of incorporation, shareholder and director registers, and corporate structure diagrams.

Unsupported Countries and Activities

The Company does not provide services to individuals or entities from unsupported countries listed in Exhibit A. Additionally, clients involved in restricted activities listed in Exhibit B are prohibited from transacting with the Company.

Commercial Relationships

A business relationship is initiated only after the client agrees to comply with this Policy. The Company ensures continuous risk assessment throughout the client relationship, adjusting risk scores as circumstances change.

Transaction Monitoring

The Company monitors all transactions, including internal and cross-border transactions, using automated tools. Clients may be required to provide additional documentation or explanations for specific transactions. Examples include:

• Invoices or contracts supporting a transaction.
• Proof of the relationship between parties in a transaction.
• Explanation of the purpose of funds.

Failure to comply may result in transaction denial.

High-Risk Clients

The Company conducts enhanced due diligence (EDD) for high-risk clients, which may include:

• Detailed scrutiny of transactions.
• Verification of beneficial ownership through multiple layers of documentation.
• Ongoing monitoring of account activities.

Document Retention

The Company retains all documents related to client verification, transactions, and business relationships for at least five years after the termination of the relationship.

Beneficial Ownership

Beneficial ownership information is collected for all legal entities, ensuring transparency and compliance with AML requirements. If beneficial ownership cannot be determined, the client is classified as high-risk.

Reference Sources

The Company follows FINTRAC’s guidelines for record-keeping and client verification: Record Keeping Guidance.

Reporting to FINTRAC

We have established internal controls to identify and report suspicious activity to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). All employees are required to report any suspicious activity that they become aware of to the Compliance Officer and to the relevant authorities. 

Reporting Procedures

Reports are submitted electronically using FINTRAC’s designated systems. All reports are retained for five years.

Compliance Officer

The Compliance Officer oversees the implementation of this Policy, including:

• Client and transaction monitoring.
• Reporting to FINTRAC.
• Conducting training for employees.

Client Obligations

Clients are required to:

• Provide accurate and complete information during onboarding.
• Submit additional documentation when requested, including proof of identity, address, and source of funds.
• Comply with the Company’s transaction monitoring requirements.

Failure to comply may result in service denial or termination of the business relationship.

Prohibited Transactions

The Company does not permit transactions involving:

• Anonymous or pseudonymous accounts.
• Funds originating from or directed to countries listed in Exhibit A.
• Activities outlined in Exhibit B.

Examples of Restricted Activities

Examples of restricted activities include:

• Fraudulent or unlawful business operations.
• Trade in arms, munitions, or illicit goods.
• Cryptocurrency mining or Ponzi schemes.
• Transactions involving unregulated charities or high-value goods dealers.

Exhibit A: Unsupported Countries

• Abkhazia
• Afghanistan
• Antarctica
• Barbados
• Burkina Faso
• Cameroon
• Chad
• Congo (the Democratic Republic of the)
• Crimea
• Cuba
• Haiti
• Iran (the Islamic Republic of)
• Iraq
• Jamaica
• Korea (the Democratic People’s Republic of)
• Mali
• Mozambique
• Myanmar
• Pakistan
• Palestine, State of
• Panama
• Russian Federation (the)
• Somalia
• South Ossetia
• South Sudan
• Syrian Arab Republic (the)
• Togo
• Trinidad and Tobago
• Vanuatu
• Yemen

Exhibit B: Restricted Activities and Customers

The Company does not enter into any transaction with clients performing restricted activities:

• Any unlawful or fraudulent business or activity.
• Any business that violates applicable local, national, federal, or international law or regulation.
• Intellectual property or proprietary rights infringement.
• Any activities that harm or attempt to harm minors in any way.
• Trade, production, or mediation in the trade of weapons and munitions.
• Trade of antiques, works of art, numismatic values.
• Trade of jewellery, precious metals, and precious gems.
• Trade of monetary objects (banknotes) and stamps.
• Trade of ferrous, non-ferrous, and rare metals; their wares; and precocious stones.
• Trade of tobacco products.
• Illegal/pirated audio or video records.
• Hosting, file copying, or unlicensed IPTV.
• Telecommunications manipulation equipment including jamming devices.
• Trafficking of humans or related actions.
• Counterfeit (forged) goods.
• Goods and services of a sexual nature.
• Production or recycling of explosive and nuclear fuel.
• Production or trade in radioactive materials.
• Provision of money services (e.g., cash desks, currency exchange offices, money transfer agents, or other service providers offering money transfer opportunities).
• Financial services related to loan restructuring, debt recovery, or loan amendments.
• Investment services and incidental investment services.
• Provision of reinsurance services.
• Provision of cash-in-transit services.
• Cryptocurrency production (mining).
• Ponzi schemes.
• Intermediation in real property transactions.
• Drugs and drug paraphernalia, narcotic or narcotic-like substances.
• Operation of drugstores and pharmacies; trade in medications, patented drugs, and pharmaceutical products.
• Unregulated charities, political or religious organizations, ICOs, crowdfunding, and other unregulated organizations.
• Dealers of high-value precious goods.

Additionally, the following customers are prohibited:

• Shell banks.
• Individuals or entities on relevant sanctions lists issued by countries in compliance with UN resolutions or other unilateral sanctions (e.g., UK, US).
• Individuals or entities whose identity cannot be verified or who refuse to provide required verification information.
• Customers with bearer shares or undisclosed nominee shareholders.

This Policy is subject to regular updates to ensure alignment with regulatory changes. For questions or further details, please contact the Compliance Officer.