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AML Policy

1. Purpose and Scope

This policy establishes the Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) measures applicable exclusively to the Sasono prepaid product offered by Sason Finance Ltd., Canada. 

The policy ensures compliance with relevant Canadian regulations, specifically the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), as well as guidelines from the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

This policy is a summarized, web-friendly version of the more compehensive Sason Finance Ltd. Anti-Money Laundering & Anti-Terrorist Financing Policy.

2. Product Overview

Sasono is an open-loop prepaid card voucher that allows individuals and entities to make secure online payments without using traditional credit or debit cards. Users can purchase Sasono vouchers in predetermined denominations through approved merchants. Sason Finance ensures that all merchants and resellers comply with relevant AML regulations to maintain the integrity of the product.

3. Relevant Legislation and Guidelines

The following laws and guidelines govern the Sasono prepaid product:

  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA): Establishes the foundation for AML and ATF measures in Canada.
  • FINTRAC Guidelines: Provides specific reporting and compliance requirements for money service businesses.
  • United Nations Act and Special Economic Measures Act: Enforces international sanctions compliance.

4. Key Compliance Obligations

As a Money Service Business (MSB), Sason Finance Ltd. must:

  • Identify clients following MSB guidelines.
  • Report eligible transactions.
  • Conduct AML staff training.
  • Maintain a risk-based compliance program.
  • Undergo independent reviews every two years.

5. Customer Due Diligence (CDD)

  • Reseller Verification: All resellers offering the Sasono prepaid product must be verified before acceptance into the program. Verification includes collecting the following information:
    • Business registration documents (e.g., Certificate of Incorporation, Articles of Association).
    • Names and identification of directors and beneficial owners.
    • Confirmation of compliance with applicable AML regulations.
    • Review of previous compliance history and operational risk profile.
  • End-User Verification:
    • End users must provide a valid email address to use the Sasono prepaid product. The email serves as a unique identifier for transaction monitoring.
    • End users are permitted to purchase Sasono vouchers in denominations of up to $990 CAD (or equivalent) within a single 24-hour period without additional verification.
    • Purchases exceeding $990 CAD (or equivalent) within a 24-hour period require verification of the individual’s identity, including:
      • Full name
      • Date of birth
      • Address
      • Government-issued photo ID
    • Any anomalies during verification must be flagged for further review.

6. Enhanced Due Diligence (EDD)

Enhanced Due Diligence measures apply to high-risk resellers and transactions:

  • High-Risk Resellers: Resellers operating in jurisdictions flagged for money laundering risks or those associated with politically exposed persons (PEPs) are subject to additional scrutiny.
  • High-Value Transactions: Transactions exceeding $10,000 CAD in a 24-hour period undergo in-depth reviews, including verification of the source of funds and transaction purpose.
  • Monitoring Unusual Activity: Patterns inconsistent with user profiles trigger immediate compliance reviews.

7. Transaction Monitoring

Sason Finance employs a risk-based approach to monitor transactions related to the Sasono prepaid product. The following measures are implemented:

  • Transaction Thresholds: Transactions over $10,000 CAD (or equivalent) in a 24-hour period are reviewed and reported to FINTRAC.
  • Unusual Activity Monitoring: Transactions inconsistent with typical user behavior or business profiles are flagged for further review.
  • Suspicious Activity Reporting: Transactions identified as suspicious are reported to FINTRAC as required under Canadian regulations.
  • Continuous Monitoring Tools: Automated systems flag irregular patterns for manual investigation by compliance officers.

8. Record-Keeping

Sason Finance retains records for all transactions and customer interactions for a minimum of five years. Records include:

  • Customer identification information.
  • Transaction details, including amounts and associated merchant data.
  • Documentation of suspicious transaction investigations and reports.
  • Records of compliance audits and internal monitoring reviews.

9. Training

All employees involved in Sasono operations must complete AML training annually. Training topics include:

  • Identification of money laundering risks.
  • Reporting obligations.
  • Monitoring and handling of suspicious activities.
  • Updates on regulatory changes and emerging risks.

10. Compliance Oversight

The Chief Compliance Officer (CCO) oversees the implementation and enforcement of this policy. Responsibilities include:

  • Conducting annual reviews of the AML program.
  • Ensuring compliance with regulatory updates.
  • Coordinating independent audits every two years to assess program effectiveness.
  • Overseeing the resolution of identified deficiencies through remediation plans.

11. Reporting Requirements

  • Large Transactions: All transactions exceeding $10,000 CAD in a 24-hour period are reported to FINTRAC.
  • Suspicious Transactions: Reports are filed with FINTRAC when there are reasonable grounds to suspect money laundering or terrorist financing activities.
  • Attempted Transactions: Any suspicious activities, even if not completed, are documented and reported.

Red flags include:

  • Transactions inconsistent with client profiles.
  • Structuring transactions to avoid reporting thresholds.
  • Rapid transfers without economic purpose.

Investigations are conducted to determine whether transactions warrant reporting to FINTRAC.

12. Penalties for Non-Compliance

Failure to adhere to this policy or applicable regulations may result in penalties, including:

  • Fines and sanctions as determined by FINTRAC.
  • Termination of business relationships with non-compliant resellers or merchants.
  • Legal proceedings and reputational damage.

13. Policy Updates

This policy will be reviewed annually or as required by regulatory changes. Updates are approved by the Chief Compliance Officer and communicated to relevant stakeholders. Enhanced review procedures ensure the policy remains effective and compliant with evolving regulations.

14. Whistleblower Protection

Sason Finance encourages employees and stakeholders to report any suspected non-compliance or unethical practices. Whistleblowers are protected under Canadian law and internal company policies, ensuring confidentiality and safeguarding against retaliation.