Anti-Money Laundering &

Anti-Terrorist Financing Policy

Invincible Payment Systems Limited (operating as Invincible Pay) is committed to maintaining the highest standards of compliance with all applicable anti-money laundering (AML) and anti-terrorist financing (ATF) laws and regulations. We are dedicated to preventing our services from being used for illicit purposes and protecting the integrity of the Canadian financial system.

Our Regulatory Status

Invincible Pay operates under multiple regulatory registrations, demonstrating our commitment to compliance and transparency:

Money Services Business (MSB): Registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under registration number C100000702, effective July 23, 2025.
Payment Service Provider (PSP): Registered with the Bank of Canada as a Payment Service Provider, subject to the Retail Payment Activities Act.

As a registered MSB and PSP, we are subject to comprehensive regulatory oversight, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its accompanying regulations, the Retail Payment Activities Act, Canada's sanctions regime, and ongoing supervision by Canadian financial authorities.

Understanding Money Laundering and Terrorist Financing

Money laundering is the process of making illegally obtained funds appear legitimate by disguising their true origin. It typically involves three stages: placement (introducing illegal funds into the financial system), layering (conducting complex transactions to obscure the source), and integration (using the "cleaned" money in legitimate commerce).

Terrorist financing involves collecting, providing, or making available funds or other assets with the intention that they be used, or with knowledge that they will be used, to carry out terrorist activities. Unlike money laundering, terrorist financing may involve funds from legitimate sources.

Both activities pose serious threats to the integrity of financial systems, national security, and public safety. As a financial services provider, we play a critical role in detecting and preventing these activities.

Our Commitment

Invincible Pay recognizes that effective AML/ATF compliance is not merely a legal obligation but a fundamental responsibility to our customers, our partners, the Canadian financial system, and society at large. We are committed to operating with the highest ethical standards and maintaining a culture of compliance throughout our organization.

Our comprehensive AML/ATF program is designed to:

Prevent and detect money laundering and terrorist financing: Through robust controls, monitoring systems, and staff training, we actively work to identify and prevent illicit activities before they occur.
Comply with all applicable laws and regulations: We maintain full compliance with the PCMLTFA, Retail Payment Activities Act, Criminal Code, Anti-Terrorism Act, United Nations Act, Special Economic Measures Act, and all related regulations and ministerial directives.
Implement robust customer due diligence: We verify the identity of all customers and conduct appropriate risk assessments to understand the nature and purpose of business relationships.
Monitor transactions comprehensively: Our systems and procedures enable us to detect unusual patterns, behaviors, or transactions that may indicate suspicious activity.
Report to authorities as required: We fulfill all reporting obligations to FINTRAC, including suspicious transaction reports, large virtual currency transaction reports, and electronic funds transfer reports.
Screen against sanctions lists: We maintain current sanctions screening procedures to ensure compliance with Canadian and international sanctions regimes.
Maintain comprehensive records: We keep detailed records of customer identification, transactions, and compliance activities in accordance with legal retention requirements.
Invest in our people: We provide ongoing training and resources to ensure all staff members understand their compliance responsibilities and can effectively identify red flags.
Continuously improve: We regularly review and update our policies, procedures, and systems to address emerging risks and evolving regulatory expectations.
Cooperate with authorities: We maintain open lines of communication with law enforcement and regulatory agencies and respond promptly to all lawful requests for information.

This commitment extends to every level of our organization, from our Board of Directors and senior management to every employee and contractor who represents Invincible Pay.

Our Compliance Program

Our AML/ATF compliance program is built on a foundation of strong governance, comprehensive policies and procedures, advanced technology, and a culture of compliance. The program addresses all aspects of our business operations and is regularly tested, reviewed, and updated to ensure continued effectiveness.

Leadership and Oversight

We have appointed a dedicated Chief Compliance Officer (also serving as Chief Anti-Money Laundering Officer) who is responsible for overseeing our compliance program and ensuring adherence to all regulatory requirements. The Chief Compliance Officer reports directly to our Chief Executive Officer and has the authority, resources, and independence necessary to fulfill this critical function.

Our senior management team, including our Board of Directors, provides ongoing oversight and support for compliance initiatives. Senior management receives regular reports on compliance activities, emerging risks, and the overall effectiveness of the compliance program. They are ultimately responsible for ensuring that adequate resources are allocated to compliance and that a strong compliance culture permeates the organization.

Risk-Based Approach

We recognize that different customers, products, services, delivery channels, and geographic locations present varying levels of money laundering and terrorist financing risk. Therefore, we have adopted a risk-based approach that allows us to focus our resources and apply enhanced measures where risks are highest.

We conduct comprehensive risk assessments that examine all facets of our business, including:

The products and services we offer and their vulnerability to misuse
The delivery channels through which we provide services (online, mobile, etc.)
The geographic locations where our customers are based and where transactions are sent
The types of customers we serve and their risk profiles
Transaction patterns, volumes, and characteristics
Emerging threats and trends in money laundering and terrorist financing

These risk assessments are documented, reviewed regularly (at least every two years), and updated whenever significant changes occur in our business or the risk environment. The results inform our policies, procedures, and the allocation of compliance resources.

Customer Due Diligence

Understanding our customers is fundamental to detecting and preventing money laundering and terrorist financing. We verify the identity of all customers before establishing business relationships and conduct appropriate due diligence commensurate with the assessed risk level.

Our customer due diligence procedures include:

Identity Verification: We use reliable, independent sources to verify that customers are who they claim to be. For individuals, this includes government-issued identification documents. For entities, we verify legal existence and structure through official corporate records.
Beneficial Ownership: We identify the natural persons who ultimately own or control entity customers, ensuring transparency about who stands behind corporate structures.
Purpose and Nature of Business Relationship: We obtain information about the intended purpose of accounts and the expected nature of transactions to establish a baseline for monitoring.
Source of Funds and Wealth: For higher-risk relationships, we take additional measures to understand where a customer's funds originate.
Enhanced Due Diligence: When heightened risks are identified, we apply additional scrutiny, which may include obtaining additional documentation, conducting more frequent reviews, or requiring senior management approval.

Ongoing Monitoring

Establishing a customer relationship is not the end of our due diligence efforts—it's the beginning of an ongoing process. We continuously monitor customer transactions and activities throughout the duration of the business relationship to detect unusual or suspicious behavior.

Our monitoring program includes:

Automated transaction monitoring systems that flag unusual patterns or transactions for review
Regular reviews of customer accounts and business relationships
Periodic updates to customer information to ensure records remain current and accurate
Enhanced monitoring for customers assessed as higher risk
Analysis of transactions against expected activity based on the customer's profile
Investigation of alerts and escalation of potential suspicious activity

The frequency and intensity of monitoring varies based on the customer's risk rating, with higher-risk relationships subject to more frequent and detailed review.

Sanctions Screening

Canada, along with its international partners, maintains sanctions programs targeting individuals, entities, and countries involved in activities that threaten international peace and security, engage in terrorism, commit human rights abuses, or undermine democratic governance.

We screen all customers and beneficial owners against:

The Consolidated Canadian Autonomous Sanctions List
United Nations Security Council Sanctions Lists
Lists maintained under the Criminal Code of Canada
Other relevant domestic and international sanctions lists

Screening is conducted before onboarding new customers, periodically throughout the business relationship, and whenever sanctions lists are updated. If a match is identified, we take immediate action in accordance with applicable legal requirements, which may include rejecting the customer, freezing assets, or filing reports with appropriate authorities.

Politically Exposed Persons

Politically exposed persons (PEPs), heads of international organizations (HIOs), and their family members and close associates may present elevated risks due to their positions of influence and potential vulnerability to corruption. We have implemented specific procedures to identify these individuals and apply appropriate risk mitigation measures.

We determine whether customers, or beneficial owners of entity customers, are:

Foreign politically exposed persons
Domestic politically exposed persons
Heads of international organizations
Family members of any of the above
Close associates of any of the above

When such relationships are identified, we apply enhanced measures, which may include obtaining senior management approval, conducting enhanced due diligence to establish source of wealth, and implementing more intensive ongoing monitoring.

Reporting

As required by Canadian law, we file various reports with FINTRAC to support the detection, investigation, and prosecution of money laundering and terrorist financing offences. Our reporting obligations include:

Suspicious Transaction Reports: When we have reasonable grounds to suspect that a transaction or attempted transaction is related to the commission of a money laundering or terrorist financing offence, we report it to FINTRAC. There is no minimum threshold for suspicious transaction reporting—any amount may be reported if it meets the criteria.
Large Virtual Currency Transaction Reports: We report virtual currency transactions at or above prescribed thresholds.
Electronic Funds Transfer Reports: We report international electronic funds transfers at or above prescribed thresholds.
Terrorist Property Reports: If we identify property owned or controlled by terrorists or terrorist groups, we immediately report it to FINTRAC, the Royal Canadian Mounted Police, and the Canadian Security Intelligence Service, and take action to freeze the property.

All reports are filed within required timeframes and include detailed information to assist authorities in their investigations. We maintain strict confidentiality regarding the existence and content of these reports as required by law.

Record Keeping

Comprehensive record keeping is essential for demonstrating compliance with regulatory requirements and supporting investigations by law enforcement and regulatory authorities. We maintain detailed records of all customer identification procedures, transactions, and compliance activities.

Our records are:

Accurate, complete, and readily accessible
Maintained for the periods prescribed by law (generally five years)
Stored securely with appropriate safeguards against unauthorized access, loss, or destruction
Capable of being retrieved and provided to authorities promptly when requested

We maintain records of customer identification information, transaction details, business correspondence, account files, risk assessments, compliance reviews, training records, and all reports filed with FINTRAC.

Training and Awareness

An effective compliance program requires knowledgeable and vigilant staff. All employees, officers, and representatives of Invincible Pay receive comprehensive AML/ATF training appropriate to their roles and responsibilities.

Our training program includes:

Initial training for all new employees covering the fundamentals of money laundering, terrorist financing, and our compliance obligations
Role-specific training tailored to the particular compliance responsibilities of different positions
Annual refresher training to reinforce key concepts and communicate updates to laws, regulations, and policies
Ad-hoc training when significant changes occur in the regulatory environment or our operations
Training on identifying red flags and suspicious transaction indicators
Procedures for reporting concerns and escalating potential issues

We maintain records of all training provided, including attendance, completion, and assessment results.

Independent Review

To ensure the ongoing effectiveness of our compliance program, we conduct independent reviews at least every two years. These reviews are performed by qualified individuals who have expertise in AML/ATF compliance and are independent of the functions being reviewed.

The independent review assesses:

The design and implementation of policies and procedures
The adequacy of the risk assessment methodology and findings
The effectiveness of customer due diligence measures
The functioning of transaction monitoring systems and processes
Compliance with record keeping requirements
The adequacy and effectiveness of training programs
Compliance with reporting obligations
Remediation of previously identified deficiencies

The results of each review, including any findings and recommendations, are documented in a written report provided to senior management. We develop and implement action plans to address any identified deficiencies or opportunities for improvement.

Our Services

Invincible Pay provides payment processing and e-wallet services to customers in Canada and internationally. As an e-wallet provider and payment service provider, we facilitate the movement of funds for legitimate commercial purposes while maintaining robust safeguards against misuse.

Our services include:

E-wallet accounts for secure storage and management of funds
Payment processing for goods and services
Fund transfers between approved parties
Virtual currency services

While we strive to provide convenient and efficient services, we will not knowingly facilitate transactions that violate Canadian law or that we reasonably suspect may be related to money laundering, terrorist financing, or other illicit activities. We reserve the right to refuse service, decline transactions, or terminate business relationships when necessary to protect the integrity of our platform and comply with our legal obligations.

Customer Responsibilities

Effective AML/ATF compliance requires partnership between Invincible Pay and our customers. When you use our services, you agree to:

Provide Accurate Information: You must provide truthful, accurate, and complete information when opening an account and updating your information when it changes.
Cooperate with Verification Procedures: You must provide requested documentation and information to verify your identity and, if applicable, the identity of beneficial owners and authorized representatives.
Use Services Legitimately: You must use our services only for lawful purposes and in accordance with our Terms of Service.
Respond to Inquiries: You must respond promptly to our requests for additional information or clarification about your account or transactions.
Report Changes: You must notify us of material changes to your business, ownership structure, or other relevant information.
Comply with Applicable Laws: You are responsible for ensuring your use of our services complies with all laws and regulations applicable to you.

Failure to fulfill these responsibilities may result in delays in service provision, restrictions on account functionality, or termination of the business relationship. Providing false or misleading information is a serious matter that may be reported to appropriate authorities and could result in criminal prosecution.

Geographic and Jurisdictional Considerations

Money laundering and terrorist financing risks vary significantly across different countries and regions. Some jurisdictions have stronger regulatory frameworks and enforcement mechanisms, while others may have weak controls, high levels of corruption, or be associated with terrorism, organized crime, or sanctions evasion.

As part of our risk-based approach, we carefully assess the geographic risk associated with our customers and their transactions. We consider factors including:

The customer's country of residence or incorporation
The jurisdictions where funds originate and are sent
Countries identified by the Financial Action Task Force (FATF) or other reputable sources as having weak AML/ATF controls
Jurisdictions subject to Canadian or international sanctions
Countries with high levels of corruption, organized crime, or terrorist activity

We may decline to provide services to customers in certain high-risk jurisdictions or apply enhanced due diligence measures when geographic risk factors are present. These decisions are made in accordance with our risk assessment and risk tolerance levels.

Ministerial Directives

Under the PCMLTFA, the Minister of Finance may issue directives requiring reporting entities to apply special measures when there are concerns about money laundering or terrorist financing risks associated with specific foreign jurisdictions or entities.

We comply with all ministerial directives issued under the PCMLTFA. Current directives address transactions related to certain high-risk jurisdictions. When these directives apply, we implement the required countermeasures, which may include:

Treating all transactions as high-risk regardless of amount
Applying enhanced customer due diligence measures
Verifying source of funds and wealth
Keeping detailed records of all related transactions
Reporting transactions to FINTRAC
Declining to process certain transactions

As part of our commitment to Canadian security and international obligations, we do not process transactions involving certain high-risk jurisdictions as identified by Canadian authorities. This policy is reviewed and updated as new directives are issued or existing ones are modified.

Canadian Sanctions Compliance

Canada participates in various sanctions regimes established under the authority of the United Nations Act, Special Economic Measures Act, Justice for Victims of Corrupt Foreign Officials Act, and other legislation. These sanctions programs are essential tools for promoting international peace and security, protecting human rights, and combating corruption and terrorism.

Sanctions may prohibit or restrict:

Financial dealings with designated individuals, entities, or countries
Provision of financial services to sanctioned parties
Transactions involving certain sectors or types of goods
Any activity that might circumvent sanctions requirements

We maintain current sanctions screening capabilities and procedures to ensure full compliance with all applicable sanctions laws. When we identify property belonging to a sanctioned party, we immediately freeze the property and report it to the appropriate authorities as required by law.

Violating sanctions laws can result in severe criminal and civil penalties. We take our sanctions compliance obligations seriously and maintain zero tolerance for sanctions violations.

Technology and Innovation in Compliance

The rapidly evolving landscape of financial technology presents both opportunities and challenges for AML/ATF compliance. While new technologies can enhance the efficiency and effectiveness of compliance programs, they may also create new vulnerabilities that criminals can exploit.

Invincible Pay leverages technology to strengthen our compliance capabilities:

Automated Monitoring: We use advanced systems to monitor transactions and identify patterns that may indicate suspicious activity.
Data Analytics: We employ sophisticated analytical tools to assess risk and detect anomalies that might escape manual review.
Digital Identity Verification: We utilize secure digital methods to verify customer identities efficiently while maintaining high standards of accuracy.
Sanctions Screening Systems: We maintain automated screening capabilities that check against current sanctions lists in real-time.
Secure Record Keeping: We use robust data management systems to maintain comprehensive records that are secure, accessible, and searchable.

We continuously evaluate new technologies and methodologies to enhance our compliance program's effectiveness while remaining alert to the risks that technological innovation may introduce.

Privacy and Data Protection

Our AML/ATF compliance activities require us to collect, use, and retain significant amounts of personal and financial information about our customers. We recognize the importance of protecting this information and managing it responsibly.

We collect and use personal information only for legitimate compliance purposes, including:

Verifying customer identities
Assessing and managing money laundering and terrorist financing risks
Monitoring transactions for suspicious activity
Filing reports with FINTRAC and other authorities as required by law
Responding to lawful requests from law enforcement and regulatory agencies

We protect customer information through appropriate physical, technical, and administrative safeguards. Access to sensitive information is restricted to authorized personnel who require it to perform their duties. We maintain information security policies and procedures designed to prevent unauthorized access, use, disclosure, or loss of personal information.

While we are committed to protecting privacy, our compliance with AML/ATF laws takes precedence. This means we may share information with FINTRAC, law enforcement, and other authorities as required by law, and we cannot notify customers when we file suspicious transaction reports or provide information to authorities in connection with investigations.

Consequences of Non-Compliance

Money laundering and terrorist financing are serious crimes with severe consequences. Violations of AML/ATF laws can result in:

Significant criminal penalties, including imprisonment
Substantial administrative monetary penalties
Asset seizure and forfeiture
Business license revocation
Reputational damage
Civil liability

For individuals who knowingly participate in money laundering or terrorist financing, penalties can include imprisonment for up to 10 years or more, depending on the severity of the offense. Businesses that fail to comply with regulatory requirements may face administrative monetary penalties of up to $500,000 per violation for entities, with separate penalties for multiple violations.

Beyond legal consequences, non-compliance undermines the integrity of the financial system, facilitates crime, and harms innocent victims. It can enable drug trafficking, human trafficking, corruption, fraud, and terrorism—activities that have devastating impacts on individuals, communities, and nations.

International Cooperation

Money laundering and terrorist financing are global problems that require international cooperation. Canada works closely with international partners through organizations such as the Financial Action Task Force (FATF), the Egmont Group of Financial Intelligence Units, and various bilateral and multilateral agreements.

Invincible Pay supports these international efforts by:

Aligning our policies and procedures with international best practices
Considering international risk assessments and advisories in our risk management framework
Complying with international sanctions and restrictions
Cooperating with foreign authorities when appropriate and legally permissible
Staying informed about emerging global threats and trends

While our primary regulatory obligations are to Canadian authorities, we recognize that effective AML/ATF compliance requires awareness of and responsiveness to international developments.

Red Flags and Suspicious Activity Indicators

While we cannot disclose specific details of our transaction monitoring methodologies, we train our staff to recognize common indicators of potential money laundering or terrorist financing activity. These red flags may include, but are not limited to:

Transactions that are inconsistent with a customer's known business or personal activities
Complex or unusual transaction patterns without apparent economic or lawful purpose
Attempts to avoid reporting or record keeping requirements
Reluctance to provide information or documentation when requested
Provision of false, misleading, or suspicious identification or documentation
Frequent changes to account information or transaction patterns
Transactions involving high-risk jurisdictions or sanctioned parties
Rapid movement of funds through accounts or jurisdictions
Use of multiple accounts or entities without clear business purpose
Transactions involving known associates of criminal organizations or terrorist groups

The presence of one or more red flags does not necessarily indicate criminal activity. Many legitimate transactions may display characteristics that, in isolation, could appear suspicious. Our trained staff and sophisticated systems analyze the full context before reaching conclusions about whether a transaction should be reported to FINTRAC.

If you observe suspicious activity when using our platform or have information about potential money laundering or terrorist financing, we encourage you to report it to the appropriate authorities.

Employee Responsibilities and Culture of Compliance

Every employee, officer, director, contractor, and representative of Invincible Pay has a role to play in our AML/ATF compliance program. Compliance is not the sole responsibility of our Compliance Department—it is a shared obligation that requires vigilance and engagement from everyone in our organization.

General Responsibilities

All personnel are required to:

Understand and comply with this policy and all related procedures applicable to their role
Complete all required compliance training within specified timeframes
Remain alert for red flags and suspicious activity indicators
Report concerns or potential violations through appropriate channels
Cooperate fully with compliance investigations and audits
Maintain confidentiality regarding suspicious transaction reports and compliance investigations
Never tip off customers or third parties about compliance concerns or investigations
Treat customer information with appropriate care and protect it from unauthorized disclosure
Ask questions and seek guidance when uncertain about compliance requirements

Accountability

Non-compliance with AML/ATF policies and procedures is taken seriously and may result in disciplinary action up to and including termination of employment or engagement. Deliberate violations may also result in personal criminal or civil liability.

However, we also recognize that good faith compliance efforts should be protected and encouraged. Employees who report concerns in good faith, even if those concerns ultimately prove unfounded, will not face retaliation or adverse consequences for making such reports. Similarly, employees who file suspicious transaction reports in good faith are protected from civil liability under Canadian law.

Whistleblower Protection

We maintain confidential channels through which employees can report compliance concerns, violations, or unethical behavior without fear of retaliation. Reports can be made to the Compliance Officer, senior management, or through other designated reporting mechanisms.

We prohibit retaliation against any individual who, in good faith, reports compliance concerns or participates in compliance investigations. Retaliation itself is a violation of company policy and may result in disciplinary action.

Confidentiality and Legal Protection: Canadian law prohibits disclosing the existence or contents of suspicious transaction reports, terrorist property reports, or any information that could prejudice an investigation. This prohibition applies to all employees and representatives of Invincible Pay. Unauthorized disclosure can result in criminal prosecution with penalties of up to two years imprisonment. At the same time, Canadian law provides protection from civil liability for those who file reports in good faith or provide information to authorities as required by law. We take both the confidentiality requirements and the legal protections seriously and ensure all staff understand these important provisions.

Continuous Improvement and Policy Updates

The money laundering and terrorist financing threat environment is constantly evolving. Criminal organizations develop new techniques to evade detection, new technologies create new vulnerabilities, and regulatory requirements adapt to address emerging risks. To remain effective, our compliance program must evolve as well.

We are committed to continuous improvement of our AML/ATF program through:

Regular Policy Reviews: This policy and our related procedures are reviewed at least annually and updated as necessary to reflect changes in law, regulation, guidance, and our business operations.
Monitoring Regulatory Developments: We actively monitor developments in AML/ATF law, regulation, and guidance from FINTRAC, the Bank of Canada, and other relevant authorities.
Tracking Emerging Threats: We stay informed about new money laundering and terrorist financing typologies, methods, and trends through industry publications, law enforcement advisories, and professional networks.
Learning from Experience: We analyze suspicious transactions, customer feedback, audit findings, and operational experiences to identify opportunities for improvement.
Industry Engagement: We participate in industry associations and forums to share best practices and learn from peers.
Technology Assessment: We regularly evaluate new technologies and tools that could enhance our compliance capabilities.
Staff Feedback: We encourage employees at all levels to provide input on compliance policies, procedures, and systems.

When significant changes are made to this policy or our compliance program, we communicate those changes to affected personnel through training, written notices, or other appropriate means. All employees are expected to familiarize themselves with policy updates and comply with new or revised requirements.

This policy was last updated on November 1, 2025. The next scheduled review will occur no later than November 1, 2026, though updates may be made sooner if circumstances warrant.

Commitment to Transparency

While we must maintain confidentiality regarding specific compliance activities and investigations, we believe in being transparent about our general approach to AML/ATF compliance. This public policy statement demonstrates our commitment to operating with integrity and in full compliance with Canadian law.

We recognize that our customers, business partners, and stakeholders have a legitimate interest in understanding how we protect the integrity of our platform and the broader financial system. By clearly articulating our compliance commitments and practices, we aim to build trust and confidence.

At the same time, we must balance transparency with the need to protect sensitive information about our compliance methodologies that could be exploited by those seeking to evade detection. This policy provides comprehensive information about our compliance framework while appropriately protecting operational details.

Contact Information

For questions, concerns, or information regarding our AML/ATF compliance program, please contact us through the channels below. We are committed to responding to all compliance-related inquiries in a timely manner.

Compliance Inquiries:

Email: info@invinciblepay.com

Phone: 672-886-1422

Mailing Address:

Invincible Payment Systems Limited

Attention: Compliance Department

200-4909 50 Street, Red Deer, Alberta, T4N 1X8, Canada

Website: www.invinciblepay.com

Please note: For security and confidentiality reasons, we cannot discuss specific customer accounts, transactions, or compliance investigations via these general contact channels. Customers with account-specific inquiries should contact us through their secure account portal or authenticated channels.