AML & Compliance Policy

THE METRO LINKS INC. O/A CANADIAN UNION (“CANADIANUNION.CA”) IS A REGISTERED MONEY SERVICE BUSINESS WITH THE FINANCIAL TRANSACTIONS & REPORTS ANALYSIS CENTRE OF CANADA (FINTRAC).

THIS IS OUR POLICY TO COMPLY WITH ALL GOVERNMENT REGULATIONS AT ALL TIMES.

AS A MONEY SERVICE BUSINESS, WE ARE SUBJECT TO THE FOLLOWING FINTRAC REGULATIONS:

REPORTING

We are required to report the following types of transactions to FINTRAC:

• Suspicious Transactions
• Terrorist Property
• Large Cash Transactions
• Electronic Funds Transfers

RECORD KEEPING

We are required to keep all client, transaction and corporate records for a minimum of 5 years.

ASCERTAINING IDENTITY

We are required to collect and verify your identification for remittances of $1,000 and more.

POLITICALLY EXPOSED FOREIGN PERSON (PEFP)

For remittances over $100,000 or more, we are required to make PEFP determination.

THIRD PARTY DETERMINATION

If you are conducting a transaction on someone else’s behalf, we are required to obtain information on the both parties: you and the person on whose behalf you are conducting the transaction.

COMPLIANCE REGIME

We are required to maintain a compliance program containing adequate policies and procedures in accordance with the FINTRAC regulations. For more information, refer to FINTRAC website: http://fintrac-canafe.gc.ca/msb-esm/intro-eng.asp. KD

ADDITIONAL MEASURES WE TAKE TO PREVENT MONEY LAUNDERING AND TERRORIST FINANCING

WE TAKE THE FOLLOWING ADDITIONAL MEASURES TO PREVENT MONEY LAUNDERING AND TERRORIST FINANCING:

SCANNING AGAINST THE OSFI & OFAC WATCH LIST

It is our policy to check each transaction against the OSFI and OFAC watch lists. Any matched names are subject to further review by the compliance officer.

TRANSACTION MONITORING

We have adequate controls pertaining to the transaction activity at several instances of the life cycle of a transaction. These controls include:

• Client Profiling
• Risk Assessment
• Client Identification Controls & Validations
• Transaction Aggregation Thresholds
• Government Reporting Controls & Validations
• Possible Structuring Reporting
• Enhanced Due Diligence Reporting