The Compliance Regime
Manixe Money Transfer is Money Service Business registered and incorporated under the laws of Canada and regulated in compliance under Financial Transaction and Reports Analysis Centre of Canada (“FINTRAC”) for international money transfers.
Compliance Operations Officer (“COO”) is appointed as a risk-based approach. Charles Tichafanana Mauppa who has trained in financial intelligence brings in 20 years and has the full knowledge and expertise of the business functions and structures in the finance industry, regarding compliance of trade-based money laundering (“TBML”) and Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“PCMLTFA”).
The personal information in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) we collect on our website from our users and consumers as required by the regulatory authority for online Money Service Business (“MSB”) of transferring money, (“FINTRAC”) FINTRAC # M14281805.
Customers privacy is the heart of our business therefore, protecting, securing and safeguarding it is of utmost importance from would be fraudsters and hackers. The information customers provide is freely given and under no undue influence or misrepresentation of facts and only used for the sole purpose of using our products and services during our relationship. As a law compliance we take online countermeasures, every precaution and due diligence when scrutinizing the customers to avoid and protect both the client and us as a barrier from criminal activity of (“TBML’) Anti Money Laundering. We will report, after identifying suspicious transactions, any unusual pattern of transferring funds, or any amounts above the stipulated FINTRAC regulation. If we identify and have gathered enough evidence of any suspicious transfer (“PCMLTFA”) we report it to FINTRAC. This may include responding to legal requests from jurisdictions outside of Canada where we have a good faith belief that the personal information is required by law in that jurisdiction.
When a user or customer visits our website platform and provides us with their personal information after reading and accepting our terms and agreement freely entering submitting the required information, the information is captured and stored in our secure online cloud severs. We review and analyze in real time automation screening the information and if the data provided is verified to be accurate and correct, we contact the customer to provide us with more information as required by FINTRAC. We complete a Know Your Customer (“KYC”) first and being extra cautious, laser focused and being vigilant when assessing customer profiles. Once the KYC is verified and approved for biometric authentication of the customer, the user will receive an email to validate the email address and can log in and start processing their transactions.We start with small transactions less than US$500 while we get to know and familiarize with the customers behaviour, patterns of transacting and activities. As an added security measure, we will have knowledge of where the money is coming from, as we will match the sender’s credentials with proof of payment from sender’s bank, if there is an inconsistent on risk assessment, any would be violations involving financial transactions will be denied services and reported to the regulatory authorities for investigation. Ongoing enhanced monitoring and risk assessment of accounts as a compliance policy will be carried out more often, every 3 months on customers determined to be of high-risk category. Receiving and keeping up with news updates of all current legislative requirements is vital for our operations to help prevent financial crimes AML risk evaluation and enhanced monitoring. If any irregularities or deficiencies are identified, planned corrective measures are applied and implemented. A review of the policy and procedure will be conducted by external auditors for compliance of policies and procedures, risk assessment, record keeping and training effectiveness.
We have developed borderless crime prevention strategies, and risk evaluation to quickly identify illicit financial transactions and deter, reduce financial risk for the protection and the integrity of financial systems. We receive updates of operational alert notices from FINTRAC of money laundering involving online child exploitation, sextortion, corruption and human trafficking related to strategies technicalities and vulnerability.
What we collect
· First/Last Name, Email Address, Mobile/Phone Number, Occupation, Home Address, Date of Birth, Receiver First/Last Name, Receivers Mobile/phone Number, Receivers City, Receivers Country. Bank details of the receivers if sender opts that the destination of funds be deposited into the bank account or credit card. We use third party for artificial intelligence machine learning software technology from a reliable source to authenticate the government issued photo identification document.
· Individual's name
· Matching photo
· Unique identifying number
· Date of verification
· Date of issue
· Type of document front and back
· Document number
· Province that issued the document
· Expiry date
· Biometric or Verified notarized copies as proof of valid 2 pieces of government issued photo identification for user/sender and beneficiary/receiver will be required at the time the user first signs in and agrees to our terms and agreement, and the destination of the funds when receiver of the funds collects the funds.
· Matching selfie photo or live video chat from user's mobile phone while holding an authentic valid photo Government of Canada issued ID with unique identifying number, such as Canadian Passport, Drivers Licence, Permanent Residence card, or Citizenship card. A health card cannot be used for identification purposes.
· We use Optical Character Recognition (“OCR”) to prove the integrity of mobile number, current address, from notarized utility bill for gas, electricity, water, phone in customers name for verification and authentication purposes.
· Proof of a verified notarized current loan account, credit card or bank statement to verify legitimacy where the funds are coming from. You are not acting and processing a transaction on behalf of a third party and you are in your somber and normal senses above the age of 18. You know and have a good relationship with the receiver of the funds. You know and have full capacity, have not been forced or coerced or intimidated by anyone and you have full knowledge and reason and purpose why you are sending the funds.
We collect system operating software and types of devices, used to access our site location accessed from (GPS), time and date this information is used for upgrading our operating systems and tracking activity. We encrypt our source of transmitting data using secure remote online cloud servers, advanced firewalls, secure locks, to protect from unauthorized users of criminal activity.
We take the following enhanced measures to mitigate once a customer has been identified as a high risk
· Reports on frequency of high-risk transactions
· Red flagging unusual suspicious activities
· Remittances of transfers of a certain dollar amount
· Obtaining the source and ownership of funds
· The reason why the transaction is being processed
· Relationship with the receiver of the funds
· Maintaining a threshold to limit our exposure
· Stringent internal controls of high-risk customers
Training of agents
For revenue and operational efficiency and accountability, we provide proper training using state-of-the-art technology to simplify positive ID verification, compliance regarding audit trail, internal record keeping, how to KYC analyze and determine unusual suspicious transfers online. We use government departments for these trainings, such as receiving updated information, online videos, workbooks, attending conferences and webinars. Keeping records of training manuals and dates of training, who provided training and attendance. A compliance review analysis will be carried out after every year to identify any loopholes and weaknesses in our compliance program to ensure that the business is in line with the FINTRAC requirements
· Training how to recognize opportunity versus risk as low, medium, high risk customers for purposes of compliance, reporting and monitoring proceeds of crime and how to combat TBML and PCMLTFA.
· Training on how to identify and verify email address, mobile number, Identity document for real world credentials and address verification using onboarding artificial intelligence machine learning software.
· Training and awareness of crime prevention strategies, disruption, risk evaluation to quickly identify illicit financial transactions and reduce financial risk.
· Training how soon to reach the conclusion of a suspicious transfer, as a reporting Entity (“RE”) how to compile and submit credible and transparent Suspicious Transaction Report (“SARs") and corrective measures to lessen or reduce risk or frequency of large electronic funds transfers.
· Training for online internal record keeping and written standard operating procedures to follow, using all mechanisms and regulatory tools at our disposal as to who has access to our financial database, and analytics that we use to identify, mitigate and disable fraud.
· Training how to recognize and screen users who have been red flagged for sanctions, on the watchlist to protect our business and healthy of the economy and money movement from corruptions.
· Training how to identify review and analyze, placement, integration, structuring and layering, attempts to disguise the trail of money from illicit activity by high risk politically exposed person (“PEP"), head of international organization, or a family member and organized crime gangs.
· Training how to identify and review and analyze and dismantle if the funds are meant for human trafficking and child exploitation.
· Training on identifying and disruption of organized gang related virtual financial crimes.
· Training on how to thoroughly monitor clients for potential risk of fraud, money laundering, increasing the frequency of monitoring of higher risk transfers.
· Training on how to apply transfer limits and obtain additional information on KYC
· Training what type of questions to ask in order to complete a Canadian credit check for suspicious transactions and how to prepare and submit audits such as:
· Match Individual's name
· Date you consulted/searched the credit file
· Name of the credit bureau
· Individual's credit file number
· In existence for 3 + years
· Training how to combat and identify illegitimate financial transactions who to report to and why it is critical to our business operations and the economic stability.
· Training on the level of risk tolerance to determine how to deal with each level of financial risk, regulatory, reputational and legal risk and what mitigatory reduction measures and controls to apply for each risk.
· Training in control systems to identify the source of funds of payment we receive and how we collect money via trusted third parties Moneris and Interac e-transfer service, wire transfer, and bank deposit. No other form of payment is acceptable.
· Training how to use intuition, listen to your instinct, if in doubt raise a red flag escalate and report to compliance officer of suspicious transfers.
· Training how to identify and disrupt criminal gangs who try to navigate the movement of money using the decentralized platforms into the traditionally monetary system.
· Training in identifying criminal networks who use sophisticated technologies to exploit and take risk advantages when there is a global crisis.
· Training on how to review and analyze live updates from regulatory body and government departments
Retain all database for 5 years from the date of the transfer.
Disclosure report of a small RE of Mobile Money Operator is not as complex and complicated as of large RE of brick-and-mortar operations https://www.fintrac-canafe.gc.ca http://www.fatf-gafi.org / https://jmlsg.org.uk/ http://www.fatf-gafi.org https://www.fincen.gov http://www.fatf-gafi.org/publications/methodsandtrends/?hf=10&b=0&s=desc(fatf_releasedate)