Last updated on September 10, 2026
1. INTRODUCTION AND REGULATORY COMMITMENT
1.1. Corporate Philosophy and Core Commitment
HOLDEN TRANSFER INC., a company incorporated in the Province of Alberta, Canada (Corporate Access Number: 2028406771), maintains a strict policy against money laundering, terrorist financing, fraud, sanctions evasion, and all other forms of illicit financial activities. This commitment is integrated into the Company’s corporate governance framework and governs all over-the-counter (hereinafter – “OTC”) operations.
1.2. Nature of this Document
This document is provided for general informational purposes only and serves as a public summary of the Company’s Anti-Money Laundering (hereinafter – “AML”) and Anti-Terrorist Financing (hereinafter – “ATF”) approach. It is intended to provide Clients and business partners with a general understanding of the Company’s AML/ATF and financial-crime compliance approach.
To protect the integrity of the security systems and prevent bad actors from circumventing the compliance controls, specific operational requirements, escalation measures, and monitoring parameters are kept strictly confidential.
This Notice reflects the standards set out in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (hereinafter -“PCMLTFA“), and its associated Regulations, SOR/2002-184 (hereinafter – “PCMLTFR“).
2. THE RISK-BASED APPROACH
2.1. Foundation of the Risk-Based Approach
The Company applies a rigorous, dynamic Risk-Based Approach (hereinafter – “RBA”) to all aspects of its operations. This approach is consistent with the risk-assessment obligations applicable to reporting entities under the PCMLTFA and PCMLTFR, including the requirement to identify, assess and document money laundering and terrorist financing risks associated with Clients, products, services, delivery channels and geographic exposure. This mirrors the risk-assessment obligation set out in subsection 9.6(2) of the PCMLTFA and section 71 of the PCMLTFR, which requires reporting entities to assess and document the risks of money laundering and terrorist financing associated with their clients, products, delivery channels, and geography. This ensures that the most robust scrutiny and mitigation measures are applied to clients, products, and transactions that present the highest potential risk of money laundering or terrorist financing.
2.2. Comprehensive Risk Assessment Factors
During the establishment of business relations and throughout the lifecycle of the client relationship, the Company systematically evaluates risk across four primary categories:
Client Profile Risks: The nature and background of the client are analyzed. This includes differentiating between individual clients and complex corporate entities. Opaque ownership structures, the involvement of third-party intermediaries, and whether the client, their directors, or their Ultimate Beneficial Owners (hereinafter – “UBOs”) qualify as Politically Exposed Persons (hereinafter – “PEPs”) or close associates of PEPs are strictly scrutinized. The Company also identifies and assesses beneficial ownership and control in accordance with applicable Canadian AML/ATF requirements, including ownership thresholds and other forms of direct or indirect control.
Geographical and Jurisdictional Risks: The jurisdiction of origin, registration, and primary operation of the client and their counterparties are assessed. Elevated risk is assigned to clients connected with jurisdictions identified by the Financial Action Task Force as having strategic AML deficiencies, countries subject to Canadian and international sanctions, or regions known for high levels of corruption and illicit financial activity. “Canadian sanctions” in this context refers to measures imposed under the UNA, SEMA, and the Sergei Magnitsky Law.
Product, Service, and Transaction Risks: The Company assesses the nature, volume, frequency and patterns of requested virtual currency and fiat transactions. Transactions involving unusual volumes, complex cross-border routing, privacy-enhancing technologies or other elevated-risk features may be subject to enhanced review and additional controls.
Delivery Channel Risks: As a digital OTC service, the inherent risks associated with non-face-to-face onboarding and remote service delivery are taken into account. Advanced cryptographic and biometric verification (Liveness checks) are utilized to effectively mitigate these risks. Such measures may be used as part of the Company’s remote onboarding and identity-verification controls, together with the verification methods permitted under applicable Canadian AML/ATF requirements.
2.3. Risk Classification and Review
Based on the relevant risk factors, the Company assigns an appropriate risk classification to each Client or business relationship. Risk classifications may be reviewed and adjusted where the Client’s profile, transaction activity, geographic exposure or other relevant circumstances change.
2.4. Enhanced Due Diligence (hereinafter – “EDD”) and Mitigation Measures
When a Client or a specific transaction is classified as high-risk, standard Customer Due Diligence is deemed legally and operationally insufficient – consistent with the enhanced measures required for higher-risk business relationships under applicable Canadian AML/ATF requirements, the Company mandates Enhanced Due Diligence measures, which may include, but are not limited to:
- Requesting extensive and corroborated documentation regarding the Client’s Source of Wealth and Source of Funds.
- Conducting deeper adverse media screening and comprehensive background checks.
- Requiring mandatory review and explicit approval from senior management before establishing the business relationship or executing the transaction.
- Applying more frequent, intensive, and customized ongoing monitoring of the Client’s conversion patterns.
3. CUSTOMER DUE DILIGENCE: KYC & KYB
3.1. Strict Prohibition of Anonymity
The Company does not permit Clients to access regulated OTC Services without completing the identification and verification procedures required under applicable law and the Company’s internal compliance framework. The Company implements robust Know Your Customer (hereinafter – “KYC”) and Know Your Business (hereinafter – “KYB”) procedures to ensure the accurate identification, verification, and ongoing monitoring of its Clients. Full KYC/KYB procedures must be successfully completed, reviewed, and approved prior to the execution of any OTC transaction.
3.2. KYC Procedures for Individual Clients
To mitigate identity fraud and ensure regulatory compliance, individual Clients undergo a stringent onboarding process. The Company collects and verifies:
- Full legal name, date of birth, nationality, and a verified residential address.
- Valid, government-issued identity documents (e.g., passport or national ID card) checking for validity and authenticity.
- Mandatory liveness checks (biometric verification) to ensure the physical presence of the applicant and prevent deepfake or spoofing attacks.
- Information and, where required, supporting documentation concerning the Client’s Source of Funds.
- Explicit declarations regarding PEP status and the intended nature and purpose of the business relationship.
3.3. KYB Procedures for Corporate Clients
Corporate Clients inherently present a more complex risk profile. Therefore, the Company mandates a comprehensive review of the corporate structure to identify and understand the entity’s ownership and control structure, business activities and beneficial ownership. The KYB process includes:
Corporate Documentation: Obtaining and verifying official incorporation documents, including a recent Certificate of Incorporation, Certificate of Good Standing, a copy of the Memorandum and Articles of Association, and proof of the registered address.
Authorized Representatives & Directors: Verifying the identity of the natural persons authorized to act on behalf of the entity, including proof of authority. Identity verification, including government-issued identification, mandatory liveness checks, and proof of residential address, is required for all active directors, officers, and individuals authorized to execute transactions or bind the entity.
UBOs: The Company shall identify all natural persons who ultimately own or control the Client. This includes individuals directly or indirectly holding twenty-five percent (25%) or more of the shares, voting rights, or ownership interests, or those who exercise effective control over the management of the entity. This requires identity verification, including government-issued identification, liveness checks, and proof of residential address for each UBO.
Business Operations & Compliance Status: Reviewing the entity’s designated economic activity, its own AML/ATF policies, and requiring comprehensive, verifiable documentary evidence establishing the entity’s Source of Funds and overall Source of Wealth alongside the intended purpose of utilizing the Services.
3.4. Technological Integration and Third-Party Verification
To ensure the highest level of accuracy and operational efficiency, the Company utilizes specialized automated software solutions, seamlessly supported by manual compliance review. Appropriate third-party service providers may be engaged to support identity verification, document authentication, biometric verification and screening processes. Such tools supplement, but do not replace, the Company’s responsibility to ensure that identification and verification are conducted in accordance with applicable requirements.
3.5. Discretionary Rights and Manual Review
The Company reserves the right to conduct KYC and KYB procedures manually when additional checks are needed, particularly in complex, high-risk, or unusual cases where automated methods do not provide sufficient verification assurance. Furthermore, the Company retains the unilateral right to request additional information, suspend accounts, or decline any transaction at its sole discretion if a Client fails to satisfy the established due diligence requirements.
4. TRANSACTION MONITORING AND BLOCKCHAIN ANALYTICS
4.1. Continuous and Dynamic Monitoring
Our compliance obligations do not end once a Client successfully completes the onboarding phase. Ongoing monitoring is carried out in accordance with applicable Canadian AML/ATF requirements and is intended to identify activity that is inconsistent with the Client’s known profile, expected activity or the purpose of the business relationship. Transaction monitoring is conducted through a combination of automated systemic alerts and rigorous manual review by our specialized compliance personnel, ensuring that all Client activity remains consistent with their declared business profile.
4.2. Fiat Settlement and Anti-Third-Party Funding Controls
To mitigate the risks of traditional money laundering and wire fraud, all incoming and outgoing fiat settlements are reconciled against the verified Client’s registered banking details. The Company enforces a zero-tolerance policy against third-party funding. Any attempt to deposit funds from, or route withdrawals to, unauthorized intermediaries, undeclared corporate subsidiaries, or unverified personal accounts will not be processed. Such activity may result in rejection or delay of the transaction, additional compliance review, return of funds where legally and operationally permissible, restriction of access to the Services or termination of the business relationship.
4.3. Know Your Transaction (hereinafter – “KYT”) and Blockchain Forensics
The Company may use specialized blockchain analytics and Know Your Transaction (“KYT”) tools to assess wallet addresses, transaction histories and other blockchain-related risk indicators. These tools may assist the Company in identifying potential exposure to illicit, sanctioned or otherwise elevated-risk activity, including:
- Darknet markets and illegal gambling platforms;
- Mixing services designed to obfuscate transaction trails;
- Ransomware campaigns, hacks, and known exploit addresses;
- Entities subject to international sanctions.
4.4. Transactional Scrutiny and Source of Funds
Where a specific transaction deviates significantly from a Client’s established risk profile, exceeds expected transaction volumes, or otherwise gives rise to concern, it is immediately subject to further review and escalation. The Company reserves the right to request additional documentation confirming the Source of Funds based on actual transaction activity. Acceptable supporting documentation must correspond to the nature of the business and may include executed contracts, bank statements, invoices, or other corporate records clearly demonstrating the lawful origin of the capital.
4.5. Right to Restrict and Decline
Transactions or activity that cannot be adequately assessed, where required information is not provided, or that present an unacceptable level of risk may be delayed, suspended, restricted, declined or otherwise not processed. The Company exercises this right at its sole discretion to protect its operations and comply with regulatory mandates.
4.6. Compliance with the Travel Rule
Where applicable, the Company complies with Canadian Travel Rule requirements for electronic funds transfers and virtual currency transfers. For outgoing qualifying transfers, the Company ensures that the prescribed originator and beneficiary information accompanies the transfer. For incoming qualifying transfers, the Company takes reasonable measures to ensure that the required information has been included. Where required information is missing or incomplete, the Company applies risk-based procedures to determine whether the transfer should be allowed, suspended or rejected.
5. SANCTIONS AND PROHIBITED JURISDICTIONS
5.1. Sanctions Screening
The Company screens Clients, beneficial owners, counterparties and transactions against sanctions and restrictive measures applicable to it under Canadian law. As part of its internal risk-based compliance framework, the Company may also take into account sanctions and screening sources maintained by the United Nations, the United States, the European Union and other relevant authorities.
5.2. Jurisdictional and Territorial Restrictions
The Company may restrict or prohibit business relationships or transactions involving jurisdictions, territories or regions that are subject to applicable sanctions, Ministerial Directives, heightened AML/ATF risks or other restrictions under the Company’s internal risk-based framework. Geographic exposure is assessed based on the relevant facts and circumstances, including residence, place of establishment, business operations, beneficial ownership, source or destination of funds or virtual currency, and other material connections.
5.3. Dynamic Prohibited Jurisdictions List
Company maintains an internal, dynamically updated list of Prohibited Jurisdictions. The Company reserves the right to deny services to any individual or organization whose activities or associations with third parties raise reasonable concerns about potential breaches of AML regulations or sanctions exposure.
5.4. Anti-Circumvention and Zero Tolerance
The Company strictly enforces its geographic and sanctions-based restrictions. Any Client found to be attempting to circumvent these restrictions—whether through the use of VPNs, proxy servers, falsified documents, undeclared UBOs, or complex shell company structures—will face immediate consequences. In such circumstances, the Company will terminate the business relationship and restrict all associated transactions. Acting as a responsible regulated entity, the Company will withhold the provision of services and report the identified risks and evasion attempts to the Financial Transactions and Reports Analysis Centre of Canada and other relevant law enforcement authorities. Where such conduct gives rise to a reporting or disclosure obligation, the Company will make the applicable report or disclosure to FINTRAC or another competent authority in accordance with applicable law.
6. REPORTING OBLIGATIONS AND COOPERATION
6.1. Internal Investigation and Escalation
Where a transaction, pattern of activity, or Client behavior gives rise to concern, deviates from the established risk profile, or triggers systemic alerts, it is immediately subject to further review and escalation within the Company’s AML/ATF framework. Our dedicated compliance personnel conduct thorough, confidential internal investigations to determine the nature, legitimacy, and lawful intent of the flagged activity before taking external action.
6.2. Reporting to FINTRAC
Where the Company has reasonable grounds to suspect that a transaction or attempted transaction is related to the commission or attempted commission of a money laundering offence, a terrorist activity financing offence or sanctions evasion, the Company will submit a Suspicious Transaction Report to FINTRAC as soon as practicable, in accordance with applicable law.
The Company may also submit any other reports or disclosures required in connection with its regulated activities, including reports relating to large virtual currency transactions or other reportable events, where applicable.
6.3. Global Regulatory Cooperation
The Company cooperates with competent regulators, supervisory authorities, law-enforcement agencies and courts where required or permitted by applicable law. We fully, proactively, and transparently cooperate with national regulators, financial supervisory authorities, law enforcement agencies across jurisdictions, and relevant courts. The Company responds promptly and comprehensively to lawful subpoenas, production orders, and official requests for information to assist in the detection, investigation, and prosecution of illicit financial activities.
7. DATA RETENTION AND RECORDKEEPING
7.1. Recordkeeping Obligations and Scope
The Company maintains records required under applicable Canadian AML/ATF laws and regulations and such additional records as reasonably necessary for compliance, risk-management and audit purposes. Records are maintained in a manner that enables them to be produced to FINTRAC or other competent authorities where required by law. The recordkeeping framework is designed to satisfy applicable regulatory requirements, ensuring that all data is readily accessible for regulatory audits and law enforcement inquiries. The retained documentation includes, but is not limited to:
- Customer identification and verification documents
- Corporate due diligence materials, ownership structures, and UBO registries.
- Dynamic risk assessments, questionnaires, and background screening results.
- Complete transaction histories, fiat settlement records, and blockchain monitoring activity logs.
- Records relating to internal compliance reviews and copies of regulatory reports submitted where required by law.
7.2. Retention Periods
The Company retains records required under applicable Canadian AML/ATF legislation for the statutory retention period applicable to each category of record. Depending on the record type, such periods are generally at least five (5) years and are calculated from the date or event prescribed by applicable law. The applicable retention period may be extended where required by law, regulatory direction, legal hold, litigation or an ongoing investigation.
7.3. Confidentiality and Secure Destruction
Throughout the entire retention period, the Company maintains robust administrative and technological controls to preserve the strict confidentiality, integrity, and secure accessibility of such records. Once the statutory retention period has expired—and provided no further legal obligations require its preservation—the data is securely and permanently destroyed under direct management supervision.
8. CONTACT INFORMATION
If you have any questions, regulatory inquiries, or require further information regarding our compliance framework, please contact our team:
Holden Transfer Inc.
Registered Office: 700-602 12 AVENUE SW, Calgary, Alberta, T2R1J3, Canada
Company Registration Number: 2028406771
Email: holden.transfer@gmail.com