3.1  Our Commitment

UVA Global is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. As a FINTRAC-registered Money Services Business operating under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), we maintain a comprehensive, risk-based compliance programme that applies to every client relationship, every transaction, and every corridor we operate.

Compliance is not a function we maintain in parallel to our business. It is embedded into the core of how we operate.

3.2  Regulatory Framework

Our AML and compliance programme is built to satisfy the requirements of the following regulatory frameworks:

• Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) — Canada
• FINTRAC Guidance and Regulations — Canada
• Financial Action Task Force (FATF) Recommendations — International Standard
• Applicable sanctions regimes including OFAC, United Nations, European Union, and the Government of Canada
• [INSERT any additional applicable frameworks]

3.3  Know Your Business (KYB) and Customer Due Diligence

UVA Global conducts thorough due diligence on every client before providing access to our Services. Our KYB process includes:

• Verification of legal entity name, registration, and jurisdiction
• Identification and verification of directors and ultimate beneficial owners
• Assessment of business purpose, expected transaction volumes, and source of funds
• Screening of all individuals and entities against international sanctions and PEP (Politically Exposed Person) lists
• Risk classification and ongoing monitoring appropriate to the client’s risk profile

Enhanced due diligence is applied to clients classified as higher risk, including politically exposed persons, clients operating in higher-risk jurisdictions, and clients with complex ownership structures.

3.4  Transaction Monitoring

All transactions processed through UVA Global’s platform are subject to real-time monitoring for unusual or suspicious activity. Our transaction monitoring controls include:

• Real-time screening against OFAC, UN, EU, and Canadian sanctions lists
• Detection of unusual transaction patterns, volumes, or frequencies
• Monitoring for structuring and other typologies associated with money laundering
• Automated alerts and manual review processes for flagged transactions

3.5  Reporting Obligations

In accordance with our obligations under the PCMLTFA, UVA Global reports the following to FINTRAC:

• Suspicious Transaction Reports (STRs) — filed where there are reasonable grounds to suspect that a transaction is related to money laundering or terrorist financing
• Large Cash Transaction Reports (LCTRs) — filed for cash transactions of CAD $10,000 or above
• Electronic Funds Transfer Reports (EFTRs) — filed for international electronic transfers of CAD $10,000 or above
• Terrorist Property Reports — filed where we have knowledge or reasonable grounds to believe that property is owned or controlled by a terrorist or terrorist group

3.6  Record Keeping

UVA Global maintains all client identification records, transaction records, and compliance documentation for a minimum of five (5) years, in accordance with FINTRAC’s record-keeping requirements under the PCMLTFA.

3.7  Training and Governance

All personnel involved in the provision of our Services receive regular AML and compliance training appropriate to their role and responsibilities. Our compliance programme is overseen by a designated Compliance Officer who is responsible for ensuring the programme remains current, effective, and responsive to regulatory developments.

3.8  Sanctions Compliance

UVA Global maintains a zero-tolerance policy toward sanctions violations. We screen all clients, beneficial owners, counterparties, and transactions against applicable sanctions lists prior to onboarding and on an ongoing basis. We will not process any transaction that involves a sanctioned individual, entity, or jurisdiction.

3.9  Contact

Email: [email protected]