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AML/ATF Notice

Introduction and Scope

SINVERON Inc. is a legal entity formed pursuant to the Canada Business Corporations Act (R.S.C., 1985, c. C-44), with its registered office at 700-602 12 Avenue SW, Calgary, Alberta, T2R 1J3, Canada (“We“, “Our“, “SINVERON Inc.” or the “Company“) has established and maintains an Anti-Money Laundering and Anti-Terrorist Financing (“AML/ATF”) compliance program designed to support compliance with applicable Canadian AML/ATF requirements and to prevent the misuse of Our services for money laundering (“ML”), terrorist activity financing (“TF”), sanctions evasion, fraud, or other unlawful activities.

This Notice applies to current and Prospective Clients and, where applicable, individuals associated with a Client or Prospective Client, including directors, officers, authorized representatives, and beneficial owners, where AML/ATF requirements apply.

Applicable AML/ATF Laws

The Company manages AML/ATF risks in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“PCMLTFA”), its associated regulations, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (“PCMLTFR”), applicable Canadian sanctions and terrorist-property legislation, and applicable Ministerial Directives issued pursuant to the PCMLTFA. In implementing its compliance framework, the Company also has regard to applicable FINTRAC guidance, interpretations and regulatory publications, as well as relevant international AML/ATF standards and risk-based practices, where appropriate to its business activities. 

Key Terms

  • “Anti-Money Laundering/Anti-Terrorist Financing” (“AML/ATF”) means the framework of legal, regulatory and internal compliance measures designed to prevent, detect and deter money laundering and terrorist activity financing.
  • “Client” means any person or legal entity accepted by the Company for the provision of its services.
  • “Prospective Client” means a person or legal entity whose request to receive the Company’s services is under review and who has not yet been accepted as a Client.
  • “Enhanced Measures” means additional risk-mitigation measures applied where a Client, business relationship, transaction, activity, jurisdiction, or other exposure presents a higher level of ML/TF or sanctions-evasion risk. Such measures may include obtaining additional information, information on source of funds or source of wealth, information on the reasons for transactions, additional verification, and more frequent or enhanced monitoring, as appropriate.
  • Know Your Customer (“KYC”) means a process used to identify and verify the identity of customers and assess relevant risks before and during the business relationship.
  • Know Your Business (“KYB”) means a process used to identify and verify a business customer, its ownership and control structure, and the nature and purpose of the business relationship.
  • “Politically Exposed Person” (“PEP”) means a politically exposed foreign person or a politically exposed domestic person, as defined under applicable PCMLTFA and PCMLTFR requirements.
  • “Head of an International Organization” (“HIO”) means a person who currently holds or has held within the previous five years the office or position of head of an international organization, an institution established by such an organization, or an international sports organization, within the meaning of applicable Canadian AML/ATF requirements. 

Compliance Officer

The Company will appoint a Compliance Officer overseeing the implementation and ongoing maintenance of the Company’s AML/ATF compliance program in accordance with applicable legal and regulatory requirements. The Compliance Officer oversees the Company’s AML/ATF controls and acts as an appropriate point of contact for AML/ATF compliance matters.

Measures We Use to Support Effective AML/ATF Compliance

  • Client Identification and Verification: We perform KYC, KYB and other identification and verification measures required by applicable law, including, where relevant, beneficial ownership verification, third-party determinations, and PEP/HIO determinations. 
  • Risk-Based Approach: We apply a risk-based approach to Our AML/ATF compliance measures. Under this approach, the Company assesses the AML/ATF risks associated with each Client based on relevant risk factors, including transaction activity, geographic exposure, the nature and purpose of the business relationship, and other applicable circumstances. Clients identified as presenting a higher level of risk may be subject to enhanced measures, including additional information gathering or verification, source of funds or source of wealth checks, and more frequent monitoring.

Where the Company determines that the level of risk associated with a Client, proposed Transaction or activity is unacceptable or cannot be adequately mitigated, the Company may decline, restrict or suspend the relevant activity or business relationship, or take such other action as is permitted or required under Applicable Law and the applicable transaction terms. 

  • Ongoing Monitoring: We conduct ongoing monitoring of Client transactions and activities, where required, to identify activity that may be unusual or inconsistent with a Client’s established profile, expected behaviour, or the known nature and purpose of the business relationship. The Company also considers relevant risk factors, including high-risk jurisdictions, PEPs, HIOs, sanctioned persons or entities, and other exposures subject to applicable regulatory restrictions or enhanced scrutiny. Potentially unusual activity is assessed in accordance with the Company’s internal AML/ATF procedures and may be reported to FINTRAC or other competent authorities where required by law.
  • Record Keeping: We maintain transaction, client identification, business relationship, and reporting records as required by applicable AML/ATF laws and regulations. Such records are retained securely and made available to FINTRAC or other competent authorities where required by law or pursuant to a lawful request.
  • Training and Awareness: We maintain an ongoing AML/ATF training program for relevant employees and other authorized persons so that they understand their compliance responsibilities, including the identification and escalation of unusual or potentially suspicious activity. Training is updated as appropriate to reflect relevant regulatory developments, emerging risks, and new or evolving threats.
  • Reporting: Where required by applicable law, the Company submits reports to FINTRAC or other competent authorities, including Suspicious Transaction Reports (“STRs”) where the applicable legal criteria for reporting are met. The Company also cooperates with law enforcement and regulatory authorities in accordance with applicable legal requirements.
  • Travel Rule: Where applicable to a Virtual Currency transfer, the Company obtains, records and transmits prescribed originator and beneficiary information in accordance with Canadian Travel Rule requirements. Where required information is missing or incomplete, the Company takes reasonable measures to obtain it and applies its risk-based procedures to determine whether the transfer may proceed, should be suspended or should be rejected. 

What You Should Know About Third-Party Providers

The Company may engage third-party service providers to support certain aspects of its AML/ATF compliance program, including, where applicable, identity and business verification, sanctions and other screening, transaction monitoring, blockchain analytics, and record keeping. The Company conducts appropriate due diligence and oversight of such providers and remains responsible for meeting its applicable AML/ATF obligations and for the appropriate implementation of its compliance framework.

Clients and Activities We Do Not Serve

  • We do not establish or maintain business relationships with Clients who have a material connection to jurisdictions, territories or regions designated as prohibited under the Company’s internal risk-based framework, including jurisdictions subject to applicable sanctions, legal prohibitions or an unacceptable level of ML/TF, sanctions or other financial-crime risk. 
  • We do not serve Clients involved in unlawful or unlicensed activities, or where the lawful business purpose, ownership, control, or source of funds or revenue cannot be reasonably established. This includes opaque, fictitious, nominee, or front-company structures where the true ownership, control, or business purpose cannot be reasonably established. We also do not serve persons or entities subject to applicable Canadian sanctions, terrorist-property restrictions, or other legal prohibitions. PEPs, HIOs, their family members and close associates may be subject to enhanced measures, restrictions or prohibition in accordance with the Company’s internal risk appetite and applicable law.
  • We do not establish or maintain relationships involving unlawful or prohibited activities, unlicensed regulated activities, fraud or other financial crime, illicit or anonymity-enhancing virtual-asset services designed primarily to conceal the source or destination of funds or virtual assets, terrorist financing, sanctions evasion, or other activities outside the Company’s risk appetite.

Effective Date and Updates to This Notice

The Company may update this Notice from time to time to reflect changes in applicable law, regulatory requirements, the Company’s services, or its AML/ATF practices. The updated version will be posted on the Company’s Website with a revised “Last Updated” date.

Contact

If You have questions regarding this Notice or the Company’s AML/ATF compliance requirements, please contact:

Email: sinveron.official@gmail.com 

Effective Date: 2026-09-14

Last Updated: 2026-09-14