Sanctions policy

MMFintech Ltd. does not conduct business with persons, entities or in respect of activity that is prohibited under the sanctions regimes applicable to it. This policy applies to every employee, officer, contractor and agent of the company, and to every client relationship and transaction.

Scope of regimes applied

MMFintech Ltd. is bound by Canadian sanctions law. It also applies the regimes below because its programmes are delivered on the infrastructure of providers subject to them, and because transactions may be routed through correspondent institutions and currencies within their reach.

• Canada — Special Economic Measures Act, Justice for Victims of Corrupt Foreign Officials Act, United Nations Act regulations, the Criminal Code listings, and the Consolidated Canadian Autonomous Sanctions List.
• United States — OFAC Specially Designated Nationals and Blocked Persons List and consolidated non-SDN lists.
• European Union — consolidated list of persons, groups and entities subject to financial sanctions.
• United Kingdom — OFSI consolidated list of financial sanctions targets.
• United Nations — Security Council Consolidated List.

Ownership and control

The prohibition extends to entities owned or controlled by a designated person, whether or not the entity itself is named on a list. Ownership and control are assessed on the applicable thresholds of each regime and on the substance of the arrangement, not on its form alone.

How screening is applied

• Clients and, where relevant, their beneficial owners, directors and authorised signatories are screened before onboarding is completed.
• The client portfolio is screened on an ongoing basis and re-screened whenever an applicable list is updated.
• Counterparties, originators and beneficiaries are screened at transaction level, together with the countries and institutions involved.
• Virtual currency addresses are screened against known designated addresses and assessed for indirect exposure.
• Screening parameters, including matching tolerance, are documented, tested and reviewed.

Handling a match

• A potential match suspends the transaction. It is not released until the case is resolved.
• Cases are reviewed within defined timeframes by trained personnel, and the basis for discounting or confirming a match is recorded.
• A confirmed match is actioned in accordance with the applicable regime, which may include blocking property and freezing the relationship.
• Reports are made to the relevant authority where required, within the applicable deadlines. In Canada this includes disclosure obligations to the Royal Canadian Mounted Police and to the Canadian Security Intelligence Service, and monthly reporting to the applicable supervisory authority where prescribed.
• The client is not informed of the reasons for a block where doing so would be unlawful.

Country risk

MMFintech Ltd. takes into account the lists of jurisdictions published by the Financial Action Task Force, including those subject to a call for action and those under increased monitoring. Inclusion of a country on the increased monitoring list is treated as a country risk factor within the client risk assessment and corridor monitoring, applied through the risk-based approach rather than as an automatic prohibition. Jurisdictions subject to comprehensive sanctions are excluded. Markets are opened only in accordance with the published programme phases.

Change of regime

Sanctions measures change without notice and may be reimposed after a period of relief. Responsibility for monitoring changes to applicable regimes, including general licences and their expiry, is assigned within the compliance function, and changes are communicated to the affected operational areas. Client relationships are re-assessed against the measures in force at the time.