Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) Policy Statement

RaspberryFX (hereinafter referred to as the “Company”) and its employees are committed to maintaining the highest standards of integrity and transparency in our operations as a Canadian Money Services Business (MSB). We recognize the importance of combating money laundering and terrorist financing to protect the integrity of the financial system and our society. Our commitment extends to full compliance with all applicable laws and regulations governing anti-money laundering (AML) and anti-terrorist financing (ATF) activities.

We are dedicated to implementing robust policies, procedures, and controls to detect, prevent, and report any suspicious activity that may be associated with money laundering, terrorist financing, or other illicit activities. Our commitment is based on the following principles:

• Compliance with Applicable Laws and Regulations: We will comply with all relevant legislation and regulations, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) guidelines, ministerial directives and the Canadian AML and ATF regime. We will also stay informed about any updates or changes to the regulatory framework to ensure ongoing compliance.
• Risk-Based Approach: We will conduct a thorough risk assessment of our operations, customers, products, and services to identify and understand the inherent risks associated with money laundering and terrorist financing. This assessment will help us develop and implement appropriate risk mitigation measures, policies, and controls.
• Customer Due Diligence (CDD): We will implement robust Know Your Customer (KYC) procedures to identify and verify the identity of our customers. We will obtain necessary information, conduct ongoing due diligence, and apply enhanced due diligence measures for higher-risk customers. Our CDD processes will be regularly reviewed and updated to align with evolving regulatory requirements.
• Transaction Monitoring and Reporting: We will establish and maintain a comprehensive transaction monitoring system to detect and report any suspicious transactions. This includes monitoring transaction patterns, amounts, frequency, and other relevant factors to identify activities that are inconsistent with the customer's profile or typical behavior. We will promptly report any suspicious transactions and meet our reporting obligations to FINTRAC in a timely manner.
• Employee Training and Awareness: We will provide regular and comprehensive training programs to all employees to ensure they are knowledgeable about AML policies, procedures, and regulatory requirements. Our training will focus on recognizing and reporting suspicious activities, understanding the risks associated with money laundering and terrorist financing, and staying updated on emerging trends and typologies.
• Internal Controls and Compliance Oversight: We will appoint a designated Compliance Officer responsible for overseeing and managing our AML program. The Compliance Officer will ensure adherence to AML policies, conduct internal audits, and report any non-compliance or suspicious activity to senior management and, where applicable, to FINTRAC. We will establish robust internal controls to monitor and assess our AML program's effectiveness and make improvements as needed.
• Cooperation and Reporting: We will actively cooperate with law enforcement agencies, regulatory authorities, and FINTRAC in their efforts to combat money laundering, terrorist financing, and other financial crimes. We will promptly respond to requests for information, provide necessary assistance in investigations, and maintain the confidentiality and security of sensitive information.