Compliance,
visible and held.

Registration

Xchange House is registered as a Money Services Business with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Our registration is maintained in good standing and can be verified through the FINTRAC MSB Registry.

FINTRAC MSB Registration Number: C100001017
Legal Entity: Kool Telecom Ltd.
Principal Jurisdiction: Ontario, Canada

Regulatory framework

Our operations are governed primarily by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA") and the Regulations made under that Act. We apply FINTRAC\'s published guidance in our day-to-day compliance work.

We also observe obligations arising under:

• Canadian sanctions regimes, including those administered under the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act, the United Nations Act, and the Criminal Code;
• The Personal Information Protection and Electronic Documents Act ("PIPEDA") in respect of personal information;
• Provincial consumer-protection and business-practices legislation applicable in the jurisdictions in which we operate;
• Applicable foreign sanctions and payment-screening requirements, where an engagement involves foreign counterparties or currencies.

Our compliance programme

We maintain a written compliance programme that addresses each of the elements required under the PCMLTFA Regulations. The programme is reviewed periodically and updated in response to regulatory change, business change, and the findings of independent review.

Designated compliance officer

A Compliance Officer is appointed by the firm and holds the authority and resources required to implement the programme. The Compliance Officer reports to senior management.

Policies and procedures

Written policies and procedures cover onboarding, client identification, beneficial ownership, ongoing monitoring, transaction review, reporting, recordkeeping, sanctions screening, and escalation. These documents are maintained current and are available for regulatory review.

Risk assessment

We conduct and document a risk assessment covering our products and services, clients, geographic exposure, delivery channels, and other relevant factors. The assessment informs the controls applied to individual engagements, including the level of due diligence at onboarding.

Training

Relevant personnel receive training on the firm\'s compliance obligations and procedures at onboarding and on a recurring basis. Training records are maintained.

Independent review

The compliance programme is subject to independent review on the timeline required by the Regulations. Findings are documented, remediated, and reported to senior management.

Client due diligence

We apply proportionate know-your-client ("KYC") and know-your-business ("KYB") procedures at onboarding. Depending on client type and transaction profile, this may include verification of identity, verification of existence and structure of corporate entities, determination of beneficial ownership, source of funds review, source of wealth review, and sanctions and PEP screening.

Ongoing monitoring is applied throughout the client relationship. Enhanced due diligence is applied where the client risk profile warrants it.

Reporting

We file reports to FINTRAC in accordance with our reporting obligations under the PCMLTFA, including (as applicable) suspicious transaction reports, large cash transaction reports, large virtual currency transaction reports, electronic funds transfer reports, and terrorist property reports.

Reporting obligations are not negotiable with clients and are not disclosed to the subject of a report.

Recordkeeping

We retain records for the minimum periods required under the Regulations, and longer where the engagement or prudent practice warrants it. Records are maintained in a manner that permits retrieval within the timeframes required by regulatory request.

Sanctions and restricted parties

All clients and counterparties are screened against applicable Canadian sanctions lists and, where relevant to the transaction, other applicable sanctions regimes. We do not execute transactions involving sanctioned parties or sanctioned jurisdictions except where specifically authorized under a lawful exemption.

Complaints and concerns

Clients who wish to raise a concern about the firm\'s conduct or compliance with applicable regulation may do so through our complaints process. See our Complaints Process for details.

Verification

Our FINTRAC MSB registration can be verified at any time by searching the FINTRAC MSB Registry using our registration number or legal entity name.

Onboarding documents

Our standard client onboarding documentation is available for review below. Every client completes these forms as part of our compliance onboarding process — we make them visible here so prospective clients know what to expect before an initial conversation.