TAP 2 SEND
ANTI-MONEY LAUNDERING, KNOW YOUR CUSTOMER & KNOW YOUR BUSINESS POLICY
1. Introduction
Tap 2 Send, operated by Tap 2 Send Ltd, is committed to preventing the misuse of its financial services for money laundering, terrorist financing, sanctions evasion, fraud and other financial crimes. As a Canadian business providing or facilitating eligible financial services, including international money transfers, foreign exchange and digital asset conversions, Tap 2 Send recognizes the importance of effective customer due diligence and compliance with applicable financial crime prevention requirements. This public policy describes the general principles and compliance standards applicable to our business activities. It does not reproduce confidential internal procedures, transaction-monitoring methodologies, risk scoring models or regulatory reporting controls.
2. Applicable Legal Framework
Where applicable, Tap 2 Send is subject to the PCMLTFA, its regulations, applicable FINTRAC guidance and reporting requirements, the Criminal Code of Canada, the United Nations Act, the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law), and other applicable sanctions, anti-fraud and financial-services requirements. Requirements vary by activity, transaction, customer, service and jurisdiction.
3. Compliance Program
Where required, Tap 2 Send maintains a documented anti-money laundering and anti-terrorist financing compliance program including a designated compliance officer, written policies and procedures, a documented risk assessment, ongoing training and training plan, and an effectiveness review at least every two years. The detailed internal program is confidential.
4. Risk-Based Compliance Approach
Tap 2 Send uses a risk-based approach considering customer type, business activity, ownership and control, geography, transaction amount and frequency, relationship characteristics, products and services, sources and destinations of funds, digital-asset activity, counterparties, delivery channels and other indicators. Additional due diligence may apply to higher-risk relationships.
5. Know Your Customer (KYC)
We may verify connected individuals using full legal name, date of birth, residential address, government identification, authorized verification methods and supporting information. Verification may be performed directly or through authorized providers. Additional verification may be required when information is incomplete or inconsistent.
6. Know Your Business (KYB)
Before a relevant business relationship, we may collect and verify legal entity name, incorporation or registration details, addresses, business nature, directors and officers, authorized representatives, ownership and control, beneficial ownership, expected activity and commercial documentation. Requirements depend on law and assessed risk.
7. Beneficial Ownership
Tap 2 Send seeks to identify individuals who ultimately own or control relevant business customers. This may involve ownership records, direct and indirect ownership, complex structures, supporting documents and reasonable confirmation measures. Where information cannot be established, additional measures or restrictions may apply.
8. Authorized Representatives
Businesses must identify authorized representatives. We may request evidence of authority and may decline instructions from persons whose authority cannot be verified.
9. Politically Exposed Persons
Where required, Tap 2 Send may identify politically exposed persons, heads of international organizations and relevant family members or close associates. Enhanced due diligence may apply. PEP status does not mean wrongdoing.
10. Sanctions Compliance
Tap 2 Send complies with applicable Canadian sanctions requirements. We may screen parties and transactions. Transactions may be declined, blocked, frozen, reported or otherwise handled where legally required or permitted. We will not knowingly facilitate prohibited transactions.
11. Source of Funds and Source of Wealth
We may request information about the origin of funds or assets, including revenue, contracts, invoices, financial statements, bank information, asset sales and supporting records. Source-of-wealth enquiries may be required. Unsatisfactory information may prevent a transaction or relationship.
12. Transaction Purpose
Customers may need to provide the commercial purpose of proposed transactions, including supplier payments, commercial obligations, currency conversion, digital-asset conversion and supporting invoices or contracts. Additional information may be requested.
13. Transaction Monitoring
Where required, Tap 2 Send reviews activities and relationships for consistency with customer information, expected behaviour, legal obligations and risk indicators. Reviews may include monitoring, enquiries, updated verification and compliance assessment. Specific methodologies are confidential.
14. Digital Asset Risk Assessment
Digital-asset activity may involve heightened risks. For applicable services, Tap 2 Send may review blockchain wallet addresses, public transaction history, asset types, networks, counterparties, sources and destinations, blockchain risk indicators and commercial information. We may use blockchain analytics or authorized verification resources. Certain assets, addresses, networks, counterparties or jurisdictions may be restricted.
15. Virtual Currency Transfers and Travel Rule
Where relevant, Tap 2 Send complies with Canadian requirements for virtual-currency transfers, including record keeping and prescribed originator or beneficiary information. Required information may be obtained, retained, transmitted or processed under applicable law. Transactions may be delayed or declined when information cannot be obtained or verified.
16. Ongoing Business Relationship Monitoring
Due diligence may continue after onboarding. We may periodically review business activity, ownership, representatives, transaction patterns, geography, risk classification and other information, and request updated verification.
17. Enhanced Due Diligence
Higher-risk circumstances may require additional identification, ownership analysis, source-of-funds or wealth enquiries, commercial documents, management approval and increased monitoring. Measures depend on requirements and risk.
18. Suspicious Transaction Reporting
Tap 2 Send complies with applicable suspicious-transaction reporting obligations. Where legally required, reports may be submitted to FINTRAC or other competent authorities. The Company will not disclose confidential reporting information where prohibited.
19. Other Regulatory Reporting
Reporting may include prescribed electronic-funds-transfer reports, large cash transaction reports, large virtual-currency transaction reports or other required reports. We do not publicly disclose confidential internal reporting or monitoring procedures.
20. Record Keeping
Tap 2 Send maintains applicable business-relationship, identification, transaction and compliance records under Canadian law, including customer identification, business verification, beneficial ownership, transaction details, payment instructions, digital-asset records, compliance assessments, supporting commercial information and other prescribed records. Retention depends on record type and statutory requirements.
21. Compliance Training
Where required, relevant personnel and authorized representatives receive training appropriate to their duties. Training may address financial-crime risks, verification, sanctions, suspicious activity, records, reporting, digital-asset risks and escalation procedures. Content and frequency follow applicable requirements and Tap 2 Send Ltd’s compliance program.
22. Independent Effectiveness Review
Where required, Tap 2 Send conducts an effectiveness review at least every two years. The review considers policies, risk assessments and training. Findings and corrective actions are documented and reported to management as required.
23. Prohibited Activities
Tap 2 Send does not knowingly facilitate money laundering, terrorist financing, sanctions evasion, fraud, transactions involving prohibited parties, unlawfully obtained funds, false or misleading identification or other unlawful financial activity. Additional restricted categories may be established by agreements and internal policies.
24. Refusal or Restriction of Services
Tap 2 Send may refuse, suspend, delay or restrict services or transactions where legally required or permitted. Reasons may include incomplete verification, unacceptable compliance risk, prohibited parties or jurisdictions, missing information, suspected unlawful activity, failure to meet service requirements or inability to meet regulatory obligations. Explanations may be restricted by law.
25. Confidentiality and Information Protection
Information obtained through verification and compliance activities is handled under applicable privacy, financial-crime and confidentiality requirements. It may be disclosed to competent authorities or authorized service providers as required or permitted.
26. Regulatory Cooperation
Tap 2 Send cooperates with competent regulatory and law-enforcement authorities by responding to lawful requests, maintaining prescribed records and submitting required reports.
27. Customer Responsibilities
Customers must provide accurate information; disclose ownership and control; provide requested verification documents; use services lawfully; provide accurate payment instructions; inform Tap 2 Send of relevant business changes; cooperate with required verification and transaction reviews; and comply with applicable service agreements.
28. Policy Review
This public statement may be revised to reflect changes in legislation, regulatory requirements, Tap 2 Send Ltd’s services and relevant business practices.
29. Compliance Contact
Tap 2 Send — Compliance Department
Legal Entity: Tap 2 Send Ltd
Email: [COMPLIANCE EMAIL]
Address: 300 - 15300 CROYDON DRIVE,SURREY,BRITISH COLUMBIA,CANADA,V3Z 0Z5
Â