Anti-Money-Laundering & Counter-Terrorist-Financing Policy

We apply a risk-based approach to identify, assess, mitigate and monitor the money-laundering, terrorist-financing and sanctions risks associated with our business, clients, products, delivery channels and geographies. Risk assessments are documented and reviewed periodically.

Before entering into a business relationship or conducting a reportable transaction, we identify and verify the identity of each client and, where applicable, any beneficial owners, directors, senior officers, trustees and settlors, using reliable, independent source documents, data or information. See our KYC Policy for further detail.

We screen clients, beneficial owners and relevant related parties against applicable sanctions lists (including OSFI-consolidated Canadian lists), terrorist-financing lists, and politically-exposed-persons and head-of-international-organisation lists. Positive or potential matches are escalated and investigated before any relationship is opened or transaction processed.

We take reasonable measures to establish the source of funds (and, for higher-risk relationships, the source of wealth) used in any subscription or transaction, and may request supporting documentation.

Client relationships and transactions are subject to ongoing monitoring for unusual or suspicious activity and to ensure the information we hold remains current. Enhanced due diligence is applied to higher-risk relationships, including those involving politically-exposed persons or higher-risk jurisdictions.

Where required by law, we submit reports to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and to other competent authorities, including suspicious-transaction reports, terrorist-property reports, large-cash and large-virtual-currency reports and electronic-funds-transfer reports, as applicable.

We maintain records of identification, verification, risk assessments, transactions and reports for the minimum periods required by law (generally at least five years, and in some cases longer).

We have appointed a Chief AML Compliance Officer who is responsible for the AML/CTF programme. Personnel receive training appropriate to their roles, and the programme is subject to a documented independent effectiveness review at least every two years, or more frequently where risk warrants.

We do not knowingly do business with individuals or entities that are subject to applicable sanctions, that we suspect of money laundering or terrorist financing, that refuse to provide required identification, or whose source of funds or wealth we cannot satisfactorily verify. We reserve the right to decline, delay or terminate any relationship or transaction, or to freeze or refuse assets, where required or permitted by law.

Concerns about possible money laundering, terrorist financing or sanctions breaches can be reported confidentially to info@caldouncapital.ca.