Statement of commitment
Xchange House is committed to the prevention of money laundering and terrorist financing. We take our obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada) ("PCMLTFA") and its regulations seriously, and we view compliance as a core operating discipline of the firm — not an overhead to be minimized.
Registration
The firm is registered as a Money Services Business with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Registration details are set out on our Compliance page.
Compliance Officer
The firm has appointed a Compliance Officer who is responsible for the implementation of the firm\'s compliance programme. The Compliance Officer holds the authority, independence, and resources required to discharge that responsibility.
Compliance programme
Our compliance programme is documented in writing and addresses each of the elements required under the PCMLTFA Regulations, including:
- Policies and procedures covering client identification, beneficial ownership determination, ongoing monitoring, reporting, and recordkeeping;
- Risk assessment of the firm\'s products, clients, geographic exposure, and delivery channels;
- Training for all personnel on compliance obligations and procedures;
- Independent review of the programme on a scheduled basis as required by regulation.
Client due diligence
We conduct proportionate know-your-client and know-your-business procedures at onboarding. Depending on risk profile, due diligence may include:
- Verification of identity for individuals, using government-issued identification and such other means as the Regulations permit;
- Verification of existence and structure for corporate and trust clients;
- Determination of beneficial ownership;
- Source of funds review;
- Source of wealth review where risk profile warrants;
- Sanctions and politically exposed person screening;
- Enhanced due diligence in higher-risk cases.
Ongoing monitoring
Client relationships are monitored throughout their life, with transaction-level and relationship-level review. Unusual activity is escalated for further enquiry and, where warranted, reporting.
Reporting
We meet our reporting obligations to FINTRAC, including — as applicable — the filing of Suspicious Transaction Reports, Large Cash Transaction Reports, Large Virtual Currency Transaction Reports, Electronic Funds Transfer Reports, and Terrorist Property Reports.
Reporting obligations are not disclosed to the subject of a report and are not subject to client consent.
Sanctions compliance
The firm screens clients and counterparties against applicable sanctions regimes, including those administered under the Special Economic Measures Act, the United Nations Act, the Justice for Victims of Corrupt Foreign Officials Act, and the Criminal Code. The firm does not execute transactions involving sanctioned parties or sanctioned jurisdictions except where a lawful exemption applies.
Recordkeeping
Records are retained for at least the periods required by the Regulations and are maintained in a form that permits regulatory retrieval.
Client cooperation
Clients are expected to cooperate with the firm\'s compliance procedures. Failure to provide required information or documentation may result in the firm declining to accept, or terminating, the engagement.
Contact
General enquiries about the firm\'s compliance programme may be directed to compliance@xchangehouse.ca.