1. Purpose

The purpose of this KYC Policy is to ensure that Maple PayExchange Inc. (“MPE Inc.”, “we”, “our”, “us”) complies with Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) requirements, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws, and related regulations in Canada.

This policy aims to:

• Verify the identity of customers and beneficial owners.
• Mitigate risks of money laundering, terrorist financing, and fraudulent activities.
• Ensure ongoing monitoring and reporting of suspicious activities.

2. Scope

This policy applies to:

• All customers (individuals and entities) using our money exchange services.
• All MPE Inc. employees, agents, and partners involved in onboarding, transactions, and customer support.

3. Regulatory Framework

This KYC policy is designed to comply with:

• Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and related regulations in Canada.
• Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) requirements.
• Applicable international standards (FATF Recommendations).

4. Customer Identification Program (CIP)

Identification requirements and verification methods for individuals and businesses are outlined to ensure proper KYC compliance for MPE Inc. customers.

4.1 Identification Requirements

For Individuals:

• Full legal name
• Date of birth
• Residential address
• Government-issued photo ID (e.g., passport, driver’s license)
• Contact information (phone number, email)
• Occupation

For Businesses/Entities:

• Legal name and business registration documents
• Address of principal place of business
• Nature of business
• Identification of beneficial owners (natural persons owning or controlling 25% or more)
• Names and IDs of directors/signatories

4.2 Verification Methods

• Documentary verification: Government-issued ID for individuals; incorporation documents for entities.
• Non-documentary verification: Phone verification, email confirmation, third-party database checks (credit bureau or government databases).

5. Risk-Based Approach and Risk Assessment Matrix

Enhanced Due Diligence (EDD) applies to PEPs, high-risk countries, and large or unusual transactions.

6. Suspicious Activity Indicators

• Transactions structured just under reporting thresholds.
• Customer reluctant to provide ID or gives false/inconsistent information.
• Large transfers to/from high-risk countries without clear purpose.
• Sudden increase in transaction volume inconsistent with customer profile.
• Use of third parties or multiple accounts without clear reason.