KYC Policy

Orion Transact Inc.

ONBOARDING POLICY

Purpose of policy

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) regulates Orion Transact Inc. as a registered Money Services Business (MSB). This onboarding policy's goal is to make sure that the company complies with all relevant Canadian laws and regulations, particularly the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its related regulations. The policy also complies with accepted international norms and pertinent FINTRAC recommendations.

Orion Transact Inc. has put in place a thorough verification and monitoring system to reduce the risks associated with fraud, money laundering, terrorist financing, and sanctions. This includes continuous transaction monitoring, continual client risk assessments, and strict identification verification using authorized techniques that adhere to Canadian legislation.

Orion Transact Inc. regularly screens its customers against Canadian and international sanctions lists (including those under the Special Economic Measures Act and United Nations Act), adverse media monitoring, and politically exposed person (PEP) checks. All customers must submit valid corporate registration and operation documents, as well as comprehensive information about the source of funds. KYB procedures follow the prescribed verification methods outlined by Canadian law.

By implementing this policy, Orion Transact Inc. aims to preserve the integrity of the Canadian financial system, stop illegal use of its services, and maintain the confidence of its stakeholders, clients, and regulators. In accordance with its responsibilities under Canadian law, it also guarantees that the business recognizes, evaluates, and controls the risks connected to financial transactions.

Definitions

Know Your Customer (KYC) - The process of identifying and verifying the identity of individuals to comply with Canadian regulations, particularly the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). KYC includes collecting personal details such as full name, date of birth, and residential address, obtaining valid government-issued identification, verifying the authenticity of documents, and conducting identity verification through approved methods under Canadian law. Customers are also screened against sanctions lists, politically exposed person (PEP) registries, and adverse media sources.

Know Your Business (KYB) - The process of identifying and verifying corporate clients, including their legal existence, ownership structure, business activities, and beneficial ownership information. KYB procedures ensure compliance with Canadian regulations by assessing corporate documents, confirming the identity of directors and shareholders, identifying ultimate beneficial owners (UBOs), and monitoring business relationships involving higher-risk sectors.

Customer Due Diligence (CDD) - The process of collecting, verifying, and assessing information related to customers to evaluate the risk they may pose, in accordance with PCMLTFA requirements. CDD includes verifying the identity and address of individuals or entities, understanding the nature of the business relationship, and conducting ongoing monitoring for suspicious activities.

Enhanced Due Diligence (EDD) - Additional scrutiny applied to customers assessed as posing a higher risk of money laundering, terrorist financing, or sanctions evasion. EDD measures include verifying the source of funds and wealth, obtaining additional identification information, conducting more frequent transaction monitoring, and enhanced screening for PEPs and individuals from high-risk jurisdictions.

Anti-Money Laundering (AML) - A framework of laws, regulations, and procedures designed to detect, deter, and report the movement of illicit funds. Under Canadian law, AML obligations include suspicious transaction reporting, large virtual currency transaction reporting, implementation of risk-based controls, and compliance with sanctions imposed under the Special Economic Measures Act (SEMA) and United Nations Act.

Politically Exposed Person (PEP) - An individual who holds or has held a prominent public position, domestically or internationally, such as a head of state, senior government official, military officer, judge, or executive of a state-owned enterprise. The definition extends to close family members and associates. Canadian MSBs are obligated to identify PEPs and heads of international organizations (HIOs) and apply enhanced measures when dealing with such persons, as outlined under PCMLTFA.

Adverse Media - Information sourced from credible public media outlets, legal records, or regulatory findings indicating that an individual or entity may present reputational, legal, or financial risk, including but not limited to allegations of fraud, corruption, organized crime involvement, or regulatory breaches.

Sanctions - Legal measures imposed by the Canadian government or international bodies to restrict or prohibit economic or financial activities with designated individuals, entities, or countries. Sanctions include asset freezes, prohibitions on transactions, and restrictions on services, and are mandated under Canadian laws such as the Special Economic Measures Act (SEMA), United Nations Act, and Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law).

Risk Scoring - A structured evaluation process assigning risk ratings to customers based on multiple criteria, including geographic location, nature of business, transaction patterns, sources of funds, and customer behavior. Risk scoring is critical for applying appropriate levels of due diligence and for ongoing monitoring requirements under Canadian AML/ATF regulations.

KYC process in Orion Transact

Orion Transact Inc. is governed by Canadian law and corresponds with all applicable regulations for Money Services Businesses (MSBs), such as the Financial Transactions and Reports Analysis Centre of Canada's (FINTRAC) guidance, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), and the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR). These specifications align with Canada's commitments under global norms, including the Financial Action Task Force (FATF) Recommendations.

Comprehensive Know Your Customer (KYC) and Know Your Business (KYB) protocols are used at Orion Transact Inc. to confirm the identity of our clients and business associates, stop illegal activities such money laundering and terrorist financing, and reduce the risk of other financial crimes. We monitor transactions, report suspicious transactions (STRs) and large virtual currency transactions (LVCTRs) to FINTRAC when required, and strictly implement Canadian and international penalties as part of our compliance policy.

For Orion Transact Inc., Know Your Customer (KYC) practices are essential to compliance, particularly in perspective of the higher risks connected to financial services utilizing digital assets. Transactions involving digital assets are inherently anonymous, which raises issues including possible fraud, money laundering, financing of terrorism, and evasion of sanctions. We contribute to the establishment of consumer validity, foster trust among regulators, users, and stakeholders, and guarantee adherence to Canadian legal standards by gathering and validating customer information, such as government-issued picture identity and evidence of residential address.

Strong KYC procedures enable Orion Transact Inc. to identify, evaluate, and reduce risks early on, promoting transparency and supporting larger national and international initiatives to combat financial crime. Obtaining official documentation, confirming identities by techniques authorized by Canadian law (such as the dual-process method, credit file method, or affiliate identification methods), and evaluating risk profiles using structured risk scoring mechanisms are all part of our onboarding process.

We understand that money laundering, fraud, evading sanctions, and the anonymity of financial transactions involving virtual assets present unique compliance challenges. Orion Transact Inc. is dedicated to maintaining the highest security and compliance standards, guaranteeing a secure and reliable environment for all users.

Orion Transact Inc. and its clients are at severe risk when KYC requirements are not met. Customers may have their accounts suspended or deleted if they submit fake documents during the onboarding process or neglect to provide the necessary identifying information. In order to prevent abuse of its services, Orion Transact Inc. will take legal action where necessary in accordance with Canadian law in response to incidents of attempted fraud, the provision of forged papers, or other suspicious activity.

Objectives of Onboarding Policy in Orion Transact

Know Your Customer (KYC) is a cornerstone of Orion Transact Inc.'s compliance framework, which was created to handle the particular transparency issues related to financial services incorporating digital assets. In order to guarantee adherence to Canadian regulatory requirements and to preserve the platform's security and integrity, KYC procedures are applied at critical points in the customer interaction.

KYC verification is necessary from the time of first account registration in order to verify each customer's identity and eligibility to conduct financial activities. In addition to obtaining a valid government-issued photo identification (such as a passport, driver's license, or other approved ID) and proof of address documents (such as bank statements or utility bills issued within the last three months), the process entails gathering important personal information, such as full legal name, date of birth, nationality, and residential address.

To make sure that money comes from reliable sources, KYC verification is required for deposits, withdrawals, and any transactions above predetermined internal thresholds in the financial sector. Additional verification processes, such as source-of-funds and source-of-wealth inquiries, as well as enhanced due diligence (EDD) procedures when appropriate, are triggered by transactions that meet or surpass specific risk-based thresholds.

Ongoing customer profile monitoring and periodic reviews are carried out to guarantee ongoing adherence to regulatory requirements. Customers classified as higher-risk, such as those who reside in or transact with high-risk jurisdictions, are given extra consideration based on internal risk assessments conducted by Orion Transact Inc. and Canadian regulatory guidance.

Our larger Customer Due Diligence (CDD) process, which focuses on recognizing, assessing, and reducing the risks posed by our clients, includes KYC as a fundamental element. Orion Transact Inc. employs sophisticated screening tools to identify possible red flags, including exposure to sanctions, the presence of heads of international organizations (HIOs) and politically exposed persons (PEPs), and unfavorable media indicators.

In order to maintain continuous compliance with Canadian anti-money laundering (AML) and counter-terrorist financing (CTF) regulations, customers may be asked to submit updated information or additional supporting documentation if suspicious or unusual activity is discovered during onboarding or at any point during the business relationship.

Risk mitigation by Onboarding Policy in Orion Transact

The onboarding procedure at Orion Transact Inc. is especially made to recognize and lessen the risks that come with financial services that use digital assets. Advanced verification methods, specified documentation requirements, and structured measures are used to address each risk type. In order to maintain the integrity of our operations and guarantee compliance with Canadian law, the onboarding process is a crucial control point. The main risk categories we oversee and the matching mitigation strategies we employ are listed below:

- Identity Fraud: Requiring proof of address, government-issued photo identification, and real-time identity verification (such as live selfie checks) reduces the possibility that people will provide stolen or fraudulent identities. To authenticate documents and confirm identities, Orion Transact Inc. uses document verification solutions that adhere to Canadian standards. The likelihood of fraudulent account creation is greatly decreased by accurate personal data validation.

- Third-Party Deposits: Comprehensive Source of Funds (SOF) and Source of Wealth (SOW) documentation is necessary for major transactions in order to reduce the risks related to unapproved third-party deposits. The funding source and the customer's identity must be explicitly linked in bank statements, payment confirmations, or other supporting documentation. Transactions that seem to involve funding from a third party are scrutinized more closely and may be forwarded for additional examination.

- Corporate Structure Risks: We mitigate the risks associated with intricate or opaque structures for corporate clients by requiring thorough Know Your Business (KYB) documentation. This comprises director information, shareholder registries, business registration documents, certificates of status, and articles of incorporation. To find discrepancies, unidentified beneficial owners, or indications of fraud, these documents are cross-checked against official public registries.

- High-Volume Transactions: Large transactions require more thorough due diligence because they carry a higher risk of money laundering. Additional verification procedures, such as reviews of SOFs and SOWs, examination of investment records, corporate financial statements, and confirmations of beneficial ownership, are triggered by transactions that surpass the thresholds set in Orion Transact Inc.'s risk-based framework.

- High-Risk Jurisdictions: Enhanced Due Diligence (EDD) applies to customers who are from or connected to high-risk jurisdictions, as determined by FINTRAC guidance, FATF listings, or Canadian regulatory advisories. This includes in-depth analyses of the exposure to sanctions, negative media reports, political ties, and supplementary materials like comprehensive UBO profiles and financial background data.

- Counterfeit Documents: There is a serious risk associated with submitting documents that are forged or altered. Orion Transact Inc. detects and marks fake documents using cutting-edge document authentication technologies. According to Canadian reporting regulations, suspected cases of document fraud may be reported to FINTRAC and escalated for internal review.

- Cryptocurrency Anonymity Risks: Ongoing transaction monitoring programs that identify odd trends, like frequent wallet switching, mixer use, or transactions that don't fit the customer profile, help to protect the anonymity of cryptocurrency transactions. Consumers involved in transactions that have been flagged must submit SOF documentation and valid justifications for their actions.

- Fraudulent Business Operations: Companies in high-risk sectors must adhere to stringent KYB and EDD procedures. To evaluate the stability and legitimacy of such companies, Orion Transact Inc. gathers and examines financial statements, corporate governance records, business licenses, and unfavorable press coverage. Sectors deemed high-risk by Canadian regulations are subject to additional scrutiny.

Companies in high-risk sectors must adhere to stringent KYB and EDD procedures. To evaluate the stability and legitimacy of such companies, Orion Transact Inc. gathers and examines financial statements, corporate governance records, business licenses, and unfavorable press coverage. Sectors deemed high-risk by Canadian regulations are subject to additional scrutiny.

Identity verification is the main goal of the KYC process for individual clients, who usually make investments or conduct personal transactions. Government-issued photo identification, such as a passport or driver's license, and recent evidence of a residential address, such as a utility bill or bank statement from the previous three months, are required documents. Geographic risk assessment, PEP/HIO assessment, and sanctions screening are essential steps in the procedure.

The KYB procedure is more thorough for business clients and entails confirming the organization's operational and legal legitimacy. This entails gathering corporate structure charts, certificates of corporate registration, proof of business address, and the names of all senior officers and beneficial owners. Verification of the source of funds and wealth is done in accordance with the business's risk classification and the legal jurisdictions in which it conducts business.

Due to higher transaction volumes, cross-border operations, and possible exposure to high-risk industries, business customers typically carry higher risks. As a result, more thorough due diligence procedures are used, such as continuous monitoring, thorough confirmation of corporate ownership, and financial history.

Orion Transact Inc. makes sure that the onboarding process serves as the first line of defense against financial crimes like money laundering, terrorist financing, fraud, and sanctions evasion by putting in place strong KYC and KYB procedures that are suited to the customer's risk level. This all-encompassing risk-based strategy bolsters our dedication to security, compliance, and safeguarding the Canadian financial system.

KYC/KYB Levels and Limits

A tiered Know Your Business (KYB) framework tailored for corporate clients is used by Orion Transact Inc. It is organized based on the type of business relationship and the evaluated level of risk. By using this strategy, the business can effectively distribute compliance resources, keep regulatory alignment, and guarantee that all of its clients receive the same level of verification and monitoring. According to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and any applicable FINTRAC guidelines for money services businesses doing business in Canada, all KYB procedures are carried out.

The submission of foundational incorporation records, such as articles of incorporation or certificates, confirmations of business registration, and proof of business address, is the first step in the corporate verification process. Additional levels of scrutiny are applied in ascending order based on the business's risk classification.

At the most basic level, Orion Transact Inc. needs proof of legal existence, organizational structure, and operational status for corporate clients that pose little risk. In addition to identifying the directors and providing an overview of the ownership structure, this entails gathering corporate documents attesting to the entity's current registration in its jurisdiction of incorporation. The data is checked against government databases and open corporate registries.

Orion Transact Inc. requires a complete and up-to-date Register of Directors and Shareholders, as well as the identification of all Ultimate Beneficial Owners (UBOs), at the intermediate verification level, which is intended for medium-risk clients or companies operating in moderately regulated sectors. An ownership chart that clearly displays the corporate structure is required, as is the disclosure and validation of any nominee arrangements. Depending on the type of activities being carried out, requests for business licenses or sector-specific operating permits may also be made.

Enhanced Due Diligence (EDD) is used for high-risk clients, such as companies involved in cross-border transactions, companies based in high-risk jurisdictions, or companies with intricate or multi-layered ownership structures. In addition to the usual KYB requirements, these clients must submit copious amounts of documentation. This includes declarations of Source of Funds (SOF) and Source of Wealth (SOW) backed up by pertinent records like audited reports, tax returns, or financial statements. When appropriate, comprehensive UBO background profiles or resumes are needed. To find hidden risks or reputational issues, the compliance team uses sanctions screening, open-source research, and adverse media analysis.

EDD requirements include:

- Document Collection is one of the requirements for EDD. Additional documents, such as Source of Funds (SOF) statements, Source of Wealth (SOW) evidence, UBO CVs, recent bank statements, asset ownership certificates, or audited financial statements for businesses, must be submitted by customers who have been flagged for EDD.

- Verification of documents. Open-source intelligence (OSINT) and sophisticated verification procedures are used to confirm ownership structures, authenticate submitted documents, and find any connections to sanctioned organizations, high-risk industries, or negative media.

- Risk analysis and data collection. Customers with higher risk profiles are monitored more frequently, and verified EDD data is grouped by risk level. Tools for risk scoring and ongoing transaction monitoring are used to identify odd trends or questionable activity.

- Safe Storage & Compliance Surveillance. Every document pertaining to EDD is encrypted and kept safe for at least five years. To guarantee data accuracy and to reevaluate customer risk profiles as needed, audits are carried out on a regular basis.

Corporate account transaction limits are determined by the client's verified activity type and risk assessment. While high-risk clients are subject to stringent monitoring thresholds, transaction-specific justifications, and more frequent internal reviews, lower-risk corporate clients may be granted standard operating limits subject to periodic reviews. Every corporate account is onboarded and kept up to date with careful consideration of its financial behavior, operational scale, regulatory history, and jurisdictional exposure.

Orion Transact Inc. guarantees that it can evaluate, validate, and keep an eye on corporate clients in a way that conforms with Canadian regulatory standards, reduces exposure to financial crime, and fosters enduring and open client relationships by implementing this risk-based KYB framework.

Restricted Countries

Jurisdictional risk at Orion Transact Inc. is evaluated according to a legal entity's country of incorporation, the location of its registered business address, and the citizenship and place of residence of its directors and ultimate beneficial owners (UBOs). Orion Transact Inc. conducts business in accordance with all applicable Canadian laws and regulations, including the United Nations Act, the Special Economic Measures Act (SEMA), and the Financial Transactions and Reports Analysis Centre of Canada's (FINTRAC) guidelines.

As a registered Money Services Business (MSB) in Canada, Orion Transact Inc. does not provide services to individuals, entities, or businesses located in, incorporated in, or otherwise associated with restricted jurisdictions. These jurisdictions include, but are not limited to: North Korea, Iran, Syria, Sudan, Cuba, Afghanistan, Belarus, Myanmar (Burma), Venezuela, Yemen, Russia, South Sudan, Syria, Venezuela, Yemen, Ukrainian territories currently under Russian occupation (Crimea, Donetsk, Luhansk, Zaporizhzhia, and Kherson).

This list is reviewed and updated regularly to reflect changes in Canadian sanctions legislation, United Nations Security Council Resolutions, and other international regulatory developments.

During the onboarding process, Orion Transact Inc. performs jurisdictional and sanctions risk pre-checks on every customer. Customer data is compared to sanction lists published by the United Nations (UN), the U.S. Office of Foreign Assets Control (OFAC), the Government of Canada (GAC, or Global Affairs Canada), and other reputable authorities using advanced screening platforms and public sanctions databases. An instant review and possible escalation to compliance leadership are triggered by any possible match, and the application may be rejected.

In addition to prohibited jurisdictions, Orion Transact Inc. identifies high-risk jurisdictions based on public advisories, including those issued by the Financial Action Task Force (FATF). Customers from jurisdictions recognized as having strategic AML/CTF deficiencies are subject to Enhanced Due Diligence (EDD) requirements. High-risk jurisdictions include, but are not limited to: Algeria, Burkina Faso, Cameroon, Democratic Republic of the Congo, Haiti, Kenya, Lebanon, Mali, Mozambique, Nigeria, Philippines, South Africa, Tanzania, Vietnam, Uganda. Customers associated with high-risk jurisdictions are subjected to stringent EDD measures, including thorough Source of Funds (SOF) and Source of Wealth (SOW) verifications, comprehensive background checks, and enhanced transaction monitoring. Each case is reviewed individually to ensure regulatory compliance while maintaining the integrity and security of Orion Transact Inc.’s operations.

Depending on the jurisdictional risk rating of the customer, different levels of due diligence are applied. While customers from high-risk jurisdictions are subject to more frequent monitoring, more stringent transaction thresholds, additional document verification, and continuous enhanced reviews, customers from lower-risk jurisdictions go through standard Customer Due Diligence (CDD) procedures.

Every piece of customer documentation that is submitted is thoroughly examined for completeness, consistency, and authenticity during the onboarding process. Any anomalies, missing documents, or discrepancies are noted and resolved right away. Orion Transact Inc. ensures transparency, regulatory compliance, and strong customer risk management by managing document validation through secure systems and workflows.

In addition to reducing the risks involved in serving clients from sanctioned or high-risk jurisdictions, this policy of limited access and increased monitoring aids Orion Transact Inc. in adhering to Canadian anti-money laundering (AML) and counter-terrorist financing (CTF) regulations.

AML Screening in Orion Transact

Orion Transact Inc. has put in place a thorough AML screening framework tailored to its operations as a federally registered Money Services Business (MSB) in order to ensure complete compliance with Canadian anti-money laundering (AML) and counter-terrorist financing (CTF) laws. The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), its implementing regulations, and the Financial Transactions and Reports Analysis Centre of Canada's (FINTRAC) official guidelines are all taken into consideration when developing these procedures.

An essential component of Orion Transact Inc.'s onboarding and continuing monitoring processes is AML screening. The business conducts negative media searches, sanctions screening, transaction behavior evaluations, and the identification of politically exposed persons (PEPs) and heads of international organizations (HIOs). The United Nations Security Council resolutions, the Canadian sanctions lists kept up to date by Global Affairs Canada (GAC), the U.S. Office of Foreign Assets Control (OFAC) sanctions lists, and advisories issued by the Financial Action Task Force (FATF) concerning high-risk jurisdictions are among the reliable sources used in these checks. Internal risk intelligence tools and open-source research are used to augment the screening.

Finding people and organizations that might pose higher risks of financial crime, such as those with ties to organized crime, corruption, financing of terrorism, or international sanctions regimes, is the main goal of these screening procedures. The case is forwarded to the compliance team for further review and risk assessment after a customer match is found during screening. Orion Transact Inc. may reject the customer's application, ask for more details, submit a suspicious transaction report (STR) to FINTRAC, or end the current relationship, depending on the risk's nature and severity.

Given the cross-border nature of many financial operations conducted by Orion Transact Inc., including domestic and international funds transfers, business-to-business settlements, and account-based services, enhanced screening is especially important in the context of correspondent banking relationships, payment corridors involving sanctioned or high-risk jurisdictions, and transactions involving layered or intermediary entities. In particular, the company actively monitors settlement activity for signs of structuring, round-tripping, unusually high volumes, third-party funding, or patterns inconsistent with the stated purpose of the business relationship.

There are internal systems in place to facilitate periodic reevaluations of transaction flows and real-time monitoring. Compliance officers have the authority to freeze accounts or escalate cases in line with the risk management protocol, and alerts are generated based on departures from expected behavior. Transaction monitoring rules are continuously improved to guarantee responsiveness to new threats, regulatory changes, and typologies found by FINTRAC and international standard-setters.

Orion Transact Inc. regularly reviews and enhances its AML and CTF controls to remain aligned with evolving Canadian legal standards and global best practices. By maintaining a robust screening and escalation process, Orion Transact Inc. strengthens its capacity to detect and prevent financial crime, mitigates institutional risk, and reinforces the trust of its partners, regulators, and clients in Canada and internationally.

Counterfeited Documents Reporting obligation in Orion Transact

Managing fake documents is essential to upholding compliance and safeguarding Orion Transact Inc.'s business operations. According to Canadian regulatory requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated FINTRAC guidance, prompt and decisive action is taken when potentially fraudulent or counterfeit documents are discovered during the onboarding process or during follow-up account reviews.

All identified cases involving suspected counterfeit documents are subject to internal escalation, full documentation, and, where appropriate, mandatory reporting to FINTRAC through the filing of suspicious transaction reports (STRs). Counterfeited documents may include manipulated government-issued identification documents, such as altered names, dates of birth, or photographs, falsified proofs of address such as fabricated utility bills, or forged corporate records, including fraudulent Certificates of Incorporation or shareholder registries.

Verifying the legitimacy of customer submissions is the first step in detecting counterfeit documents. Government-issued identification documents and proofs of address are among the uploaded files that are verified using both manual checks and verification tools. A thorough examination is carried out by comparing the information in documents that have been flagged as suspicious with credible open-source intelligence platforms, public corporate databases, and official government registries. When discrepancies or indications of document manipulation are verified, the matter is promptly forwarded to the compliance team for additional examination and determination.

The customer's identity, the fraudulent documents submitted, the outcomes of verification checks, and the circumstances surrounding the fraudulent activity are all meticulously recorded in confirmed cases of counterfeited documentation. As part of Orion Transact Inc.'s legal duty to report suspicious activity in accordance with Canadian AML/CTF laws, such cases are reported to FINTRAC. The reporting procedure guarantees that attempted abuses involving corporate misrepresentation or fraudulent identification are communicated to the Canadian financial intelligence system.

Fake utility bills that make up residential addresses; government-issued identification cards with altered fonts, photos, or security features; and corporate certificates that display ownership or directorship details that don't match public records are all examples of counterfeit documents. Before being confirmed, every suspected document is closely examined against official templates and real registry samples.

By maintaining a robust framework for detecting, analyzing, and reporting counterfeit documentation, Orion Transact Inc. reinforces its commitment to compliance, contributes to safeguarding the Canadian financial system, and demonstrates to stakeholders and regulators its dedication to upholding the highest standards of operational integrity and transparency.

Risk-Scoring as part of the onboarding policy in Orion Transact

Customer risk scoring is a crucial part of Orion Transact Inc.'s compliance framework. Geographical location, transaction behaviors, business sector involvement, and customer background characteristics are just a few of the structured risk factors that Orion Transact Inc. considers when evaluating each customer profile. According to Canadian regulatory standards under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and guidelines issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), Orion Transact Inc. is able to apply proportionate levels of due diligence and monitoring and prioritize resources appropriately by assigning a risk rating to each customer using a numerical or categorical model.

Risk scoring is fundamental in addressing the challenges posed by the global nature of financial services involving digital assets. Orion Transact Inc. applies a risk-based approach to mitigate jurisdictional risks and regulatory inconsistencies by assessing the geographic location of customers and imposing stricter onboarding and monitoring requirements on accounts associated with high-risk jurisdictions. In addition, Orion Transact Inc. evaluates the declared purpose of the account, anticipated transaction activity, and ongoing transaction patterns to detect irregularities that may indicate heightened risks. Customers assessed as high-risk undergo additional verification measures, including detailed Source of Funds (SOF) and Source of Wealth (SOW) validation, and are subject to enhanced and more frequent monitoring of their account activities.

Throughout the customer lifecycle, Orion Transact Inc. also performs recurring risk reassessments and periodic reviews. Risk ratings are dynamic and are updated frequently in response to shifts in consumer behavior, exposure to different regions, and other pertinent variables. Low-risk customers are reviewed at least once every three years, medium-risk customers are reviewed once a year, and high-risk customers are reviewed semi-annually in compliance with Canadian compliance standards and best practices. These review intervals guarantee that each customer's risk profile is kept up to date and suitably classified in accordance with changing risks and legal requirements.

Given the diverse composition of the customer base, which includes both individuals and businesses, Orion Transact Inc. maintains differentiated approaches based on customer risk profiles. Low-risk customers are subject to standard Customer Due Diligence (CDD) measures, including basic verification of identification documents and monitoring of transactional consistency. Medium-risk customers are subjected to enhanced scrutiny, which includes additional document verification, periodic reassessment of the customer's activities, and closer monitoring of transaction patterns. High-risk customers, particularly those engaging in high-value transactions, operating in or transacting with high-risk jurisdictions, or displaying complex corporate structures, are subjected to Enhanced Due Diligence (EDD) procedures. These procedures involve detailed investigations into SOF and SOW, comprehensive background checks, adverse media reviews, and continuous transaction monitoring.

Orion Transact Inc. guarantees complete adherence to Canadian anti-money laundering and counter-terrorist financing regulations by utilizing a tiered risk-scoring and monitoring model. By using this strategy, Orion Transact Inc. can preserve the integrity of its services and safeguard the Canadian financial system while successfully reducing the various risks connected to various client profiles.

Re-verification and Updating Documents process in Orion Transact

Orion Transact Inc. places a strong emphasis on maintaining the accuracy and currency of customer information and documentation to ensure ongoing compliance and effective risk management. Through periodic reviews and ongoing monitoring, the compliance team identifies outdated or incomplete customer records and proactively requests updated documentation as part of the company's continuous due diligence obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC regulatory expectations.

The expiration of government-issued identification documents, substantial changes in a customer's risk profile, notable shifts in transaction behavior, or corporate changes like beneficial ownership, shareholding structures, or directorship changes can all cause a customer's information to need to be re-verified. Passports and driver's licenses that have expired, out-of-date proofs of residential address, and updated corporate records like updated Certificates or Articles of Incorporation, Registers of Directors, and Registers of Shareholders are common examples of documents that need to be updated on a regular basis.

For corporate customers, the re-verification process ensures that Orion Transact Inc. maintains a clear and current understanding of the business’s structure, operational activities, and ultimate beneficial ownership. Updated corporate documentation is collected where applicable, and cross-referenced against authoritative public registries and sources. The compliance team applies enhanced scrutiny to ensure that any corporate changes are legitimate and that the customer remains compliant with Canadian AML/CTF requirements.

Using a risk-based approach, the frequency of re-verification corresponds to the customer's assigned risk level. Low-risk customers must update their documentation at least once every three years, medium-risk customers must do so annually, and high-risk customers must review and update their documentation semi-annually. Through these review cycles, Orion Transact Inc. is able to adhere to regulatory requirements for record maintenance and continuous due diligence while maintaining an accurate and risk-appropriate customer database.

The re-verification process is initiated by notifying customers through secure communication channels with clear and detailed instructions for submitting updated documents. Upon receipt, the new documents are subjected to thorough authenticity validation using approved verification technologies and manual cross-checks. For corporate clients, additional verification measures include reviewing public records to confirm any changes in directors, shareholders, or business activities, and conducting updated sanctions screening to detect potential new risk exposures.

For instance, Orion Transact Inc. requests a new government-issued ID and a current photo for real-time identity verification if a customer's government-issued identification document expires. When a corporate client's board of directors changes, updated corporate registries are gathered and cross-referenced with official documents to ensure the changes are accurate. Updated documents are always safely kept and added to the customer's risk profile files.

By maintaining a rigorous and structured re-verification process, Orion Transact Inc. ensures the integrity and reliability of its customer information, reduces operational and regulatory risks, and reinforces its ongoing commitment to upholding the highest standards of compliance and transparency within the Canadian financial services environment.

KYC record keeping in Orion Transact

Orion Transact Inc. complies fully with Canadian regulatory requirements and securely maintains all Know Your Customer (KYC) records. All identification documents, customer transaction records, risk assessments, due diligence documentation, communications, and any reports pertaining to suspicious activities are kept for a minimum of five years after the customer's account is closed or the last transaction involving the account is completed, in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and related regulations.

The purpose of this retention policy is to ensure that Orion Transact Inc. can meet its obligations under Canadian law, assist regulatory authorities in any investigations or audits, and maintain a verifiable record of compliance activities over the required statutory period. This practice is critical in supporting effective anti-money laundering (AML) and counter-terrorist financing (CTF) oversight, as well as facilitating potential law enforcement inquiries.

The Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy laws govern the collection, processing, storage, and destruction of all customer data, including financial records and personally identifiable information. Orion Transact Inc. places a high priority on safeguarding client information by putting strong data security measures in place, such as access control, encryption, and safe digital and physical storage systems. Sensitive customer data is only accessible by authorized personnel, and strict internal policies are in place to guard against misuse, disclosure, and unauthorized access.

Transparency, purpose limitation, and data minimization principles govern the collection and use of personal information. Orion Transact Inc. ensures that only information necessary for compliance and operational purposes is retained. Regular audits and compliance reviews are conducted to verify adherence to record-keeping obligations and to ensure that customer data remains accurate, relevant, and secure throughout its lifecycle.

Orion Transact Inc. reaffirms its dedication to protecting consumer data, guaranteeing legal compliance, and preserving the integrity of the Canadian financial system by upholding these standards.

KYC Third-party sharing

At Orion Transact Inc., customer privacy is a fundamental priority, carefully balanced with the need to comply with legal and regulatory obligations. Personal information, including KYC and KYB documents, is shared with third parties strictly under limited and clearly defined circumstances, in full compliance with Canadian legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and obligations arising under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

When filing suspicious transaction reports (STRs), terrorist property reports (TPRs), or large virtual currency transaction reports (LVCTRs), Canadian regulatory bodies like the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) may receive customer information. When disclosure is mandated by law, regulation, subpoena, court order, or official investigation requests, information may also be shared with authorized financial institutions or Canadian law enforcement agencies. Proof of identity, transaction records, corporate registration documents, and proof of the validity of funds or ownership structures are a few examples of shared information.

In every instance of data sharing, Orion Transact Inc. ensures that only the minimum information necessary to fulfill the specific legal or regulatory requirement is disclosed. No KYC, KYB, or customer information is shared with any third party outside of these lawful obligations unless the explicit consent of the customer has been obtained in advance. Orion Transact Inc. maintains strict internal protocols to review and validate any disclosure requests before acting upon them, ensuring that customer privacy rights are preserved at all times.

Only authorized recipients have access to all shared information, which is sent over secure, encrypted channels. The compliance team at Orion Transact Inc. has received substantial training on how to properly respond to requests for third-party disclosure, confirm the validity of such requests, and guarantee that private client data is shielded from abuse or illegal access.

By adhering to these principles, Orion Transact Inc. upholds its commitment to protecting customer privacy while meeting its legal and regulatory obligations under Canadian law.

Internal training in Orion Transact

The fast-evolving nature of financial services involving digital assets demands continuous adaptation and education. Orion Transact Inc. is committed to enhancing the expertise of its employees in Know Your Customer (KYC) and Know Your Business (KYB) verification standards as a critical part of both the customer onboarding process and ongoing monitoring obligations. This commitment is particularly important given the complexity and emerging risks associated with the use of virtual currencies, including the heightened possibility of encountering fraudulent documentation and high-risk customer profiles.

To guarantee that all compliance and customer-facing staff members stay current on the newest legal changes, verification methods, and industry best practices in anti-money laundering (AML) and counter-terrorist financing (CTF) compliance, Orion Transact Inc. has put in place extensive training programs. All current compliance staff members participate in quarterly training sessions, and new hires are onboarded right away. Key topics covered in these sessions include the application of international and Canadian standards for customer due diligence, the validation of identification documents, the identification of red flags in customer onboarding and transaction activities, and the detection of fraudulent behaviors.

Workers are given hands-on training on how to properly evaluate customer risk profiles, apply Enhanced Due Diligence (EDD) measures, comprehend risk indicators, and validate customer-provided documentation. Throughout the course of the customer relationship, special attention is paid to compliance with Canadian privacy laws, such as the Personal Information Protection and Electronic Documents Act (PIPEDA), which guarantees that customer data is gathered, processed, and stored safely and legally.

The preparation and filing of Suspicious Transaction Reports (STRs), Terrorist Property Reports (TPRs), and Large Virtual Currency Transaction Reports (LVCTRs) are among the mandatory reporting obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) that Orion Transact Inc. makes sure compliance staff are trained on.

Records of all training sessions are maintained to evidence compliance with regulatory expectations and to facilitate internal audits, regulatory inspections, and external compliance reviews. These training records detail attendance, materials covered, and individual employee completion status.

In order to guarantee that its operations meet the highest standards of regulatory compliance, risk management, and customer protection, Orion Transact Inc. consistently invests in employee education and upholds a strong compliance culture. This strengthens the integrity of its services within the Canadian financial system.

Policy Review and Updates

Orion Transact Inc. reviews this onboarding KYC policy at least once a year to make sure it's still applicable, efficient, and in line with industry, legal, and regulatory standards. Every time there are major changes to applicable Canadian laws or regulatory frameworks, such as revisions to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), FINTRAC guidance, or related obligations affecting Money Services Businesses (MSBs) in Canada, the policy is reviewed and updated in addition to the planned annual reviews.

Orion Transact Inc. makes sure that users and stakeholders are promptly and openly informed of any significant changes to the policy. Updates to the policy are communicated through the proper channels, giving users concise explanations of the changes and, if necessary, asking for their acknowledgement or consent before they go into effect.

Through this structured review and communication process, Orion Transact Inc. maintains its commitment to operational transparency, regulatory compliance, and the ongoing protection of its customers and the Canadian financial system.

Got questions?

Reach out to our Compliance Team at [email protected].