AML/CTF & Sanctions Statement

Our Approach

Fineus Ltd. is committed to developing a responsible and risk-based approach to preventing money laundering, terrorist financing, sanctions evasion and other financial crime risks.

Our compliance framework is being designed with reference to applicable Canadian legal requirements and relevant international regulatory standards, taking into account the nature of our B2B financial services activities and the jurisdictions in which we intend to operate.

Customer & Counterparty Due Diligence

Our compliance framework is intended to incorporate risk-based customer and counterparty due diligence, including:

• Identification and verification of corporate customers and beneficial owners.
• Assessment of ownership structures, business activities and geographic exposure.
• Politically Exposed Person (PEP) and sanctions screening.
• Source of funds and source of wealth enquiries where appropriate.
• Enhanced due diligence for higher-risk relationships and activities.

The scope and application of these measures will reflect applicable legal obligations and the risks associated with the relevant services.

Sanctions Compliance

Fineus recognises the importance of compliance with applicable economic and financial sanctions.

Our sanctions compliance approach is being developed with reference to relevant restrictions and designated-party lists, including:

• Canada: Sanctions administered under the United Nations Act, Special Economic Measures Act and Justice for Victims of Corrupt Foreign Officials Act.
• United Nations: Applicable UN Security Council sanctions, including those implemented through Canadian law.
• United States: Sanctions administered by the Office of Foreign Assets Control (OFAC), where relevant.
• European Union: Applicable EU restrictive measures and financial sanctions.
• United Kingdom: Applicable UK financial sanctions and designations under the UK Sanctions List.

The relevance and application of these regimes will be assessed according to applicable law, transaction characteristics, jurisdictions and counterparties.

Fineus does not intend to facilitate transactions or relationships prohibited by applicable sanctions laws.

Transaction Monitoring & Reporting

Our compliance framework is intended to address transaction monitoring, risk escalation, record keeping and reporting obligations, including the identification and assessment of unusual or potentially suspicious activities.

Relevant controls and procedures will be developed and implemented in accordance with applicable requirements before the commencement of regulated operations.

Regulatory Status

Fineus Ltd. is an Ontario-incorporated company preparing for registration with FINTRAC as a Money Services Business (MSB). Regulated financial services are not currently being offered.

This statement summarises Fineus's intended approach to financial crime compliance. It does not replace the company's internal policies, procedures or applicable regulatory obligations.

For compliance-related enquiries, please contact support@fineus.io.