AML/KYC Policy

Last updated: March 2026

1. Purpose and Scope

This Anti-Money Laundering and Know Your Customer Policy ("AML/KYC Policy") outlines the measures taken by Trustmepay Global Corp. ("Trustpay," "we," "us," or "our") to prevent the use of the Platform for money laundering, terrorist financing, and other financial crimes. Trustpay is registered as a Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and complies with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations.

This policy applies to all users of the Trustpay platform located at trust-pay.ca, including all supported digital assets: BTC, ETH, SOL, and USDC.

2. Customer Identification Program (CIP)

Before enabling trading, deposits, or withdrawals, Trustpay requires all users to complete identity verification. Our Customer Identification Program includes the following tiers:

Tier 1 — Basic Verification

Full legal name as it appears on government-issued identification
Date of birth
Residential address
Email address
Phone number
Government-issued photo ID (passport, driver's licence, or national ID card)
Selfie for facial comparison

Tier 2 — Enhanced Verification

Required for higher transaction limits or when triggered by risk-based assessment:

Proof of address (utility bill, bank statement, or government correspondence dated within the last three months)
Source of funds declaration
Additional documentation as required (e.g., proof of employment, business registration documents)

3. Customer Due Diligence (CDD)

Trustpay conducts Customer Due Diligence on all users at account opening and on an ongoing basis. CDD includes verifying the identity of the user, understanding the nature and purpose of the business relationship, and assessing the risk profile of the user. We assign each user a risk rating (low, medium, or high) based on factors including:

Country of residence and nationality
Transaction volume and patterns
Source of funds and wealth
Whether the user is a Politically Exposed Person (PEP)
Adverse media screening results

4. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to high-risk users and situations, including:

Politically Exposed Persons (PEPs) and their associates
Users from or transacting with higher-risk jurisdictions
Users with unusual or complex transaction patterns
Large or frequent transactions that exceed expected activity

EDD measures may include more frequent reviews, additional documentation requests, senior management approval for the business relationship, and ongoing enhanced monitoring.

5. Transaction Monitoring

Trustpay employs automated and manual transaction monitoring systems to detect suspicious activity. Our monitoring covers both fiat and digital asset transactions, including on-chain activity. We utilize blockchain analytics tools to screen for interactions with known high-risk addresses, mixing services, darknet markets, and sanctioned entities.

Transactions flagged for review are escalated to our Compliance Team for further investigation. Users may be contacted to provide additional information regarding flagged transactions.

6. Suspicious Transaction Reporting

Where Trustpay has reasonable grounds to suspect that a transaction is related to the commission or attempted commission of a money laundering or terrorist financing offence, we will file a Suspicious Transaction Report (STR) with FINTRAC. We are prohibited from disclosing to the user or any third party that an STR has been or is being filed (tipping off).

Trustpay also reports to FINTRAC: (a) large cash transactions of $10,000 CAD or more; (b) electronic funds transfers of $10,000 CAD or more; and (c) terrorist property reports, as required by the PCMLTFA.

7. Sanctions Screening

All users and transactions are screened against applicable sanctions lists, including but not limited to:

United Nations Security Council Consolidated List
Canadian Consolidated Autonomous Sanctions List (CASL)
U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List
EU Consolidated List of Sanctions

Users identified as sanctioned individuals or entities will be immediately blocked from the Platform, and their accounts and funds will be frozen in accordance with applicable law.

8. Record Keeping

Trustpay maintains records of all customer identification documents, transaction records, and compliance reports for a minimum period of five (5) years from the date the record was created, or five (5) years after the business relationship has ended, whichever is later. Records are stored securely and are accessible to authorized compliance personnel and regulatory authorities upon request.

9. Employee Training

All Trustpay employees and contractors receive AML/KYC training upon onboarding and at least annually thereafter. Training covers the identification of suspicious activity, reporting obligations, sanctions compliance, and updates to relevant legislation and regulations.

10. Compliance Officer

Trustpay has appointed a Chief Compliance Officer responsible for overseeing the implementation and effectiveness of this AML/KYC Policy. The Compliance Officer reports directly to senior management and is responsible for filing reports with FINTRAC, conducting internal audits, and ensuring ongoing compliance.

11. Non-Compliance and Account Restrictions

Failure to provide requested identification or documentation may result in the restriction or closure of your account. Trustpay reserves the right to refuse to process transactions, freeze accounts, or terminate the business relationship if it determines, in its sole discretion, that a user has failed to comply with this policy or poses an unacceptable risk.

12. Contact

For questions about this AML/KYC Policy, please contact:

Chief Compliance Officer
Trustmepay Global Corp.
970 Burrard St. Vancouver, BC Unit 112, V6Z 1V3, Canada
Email: compliance@trust-pay.ca