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Anti-money laundering and anti-terrorist financing notice

Last updated on August 28, 2026

INTRODUCTION

This Anti-Money Laundering and Anti-Terrorist Financing Notice (hereinafter – “Notice”) of BLACKVERGE FINANCIAL Inc., a company incorporated under the laws of Canada, under company number 2028407001, having its registered and business address at 700-602 12 AVE SW, Calgary, Alberta, T2R1J3, Canada (hereinafter – “Company”, “We”, or “Us”), provides a general overview of the principles and measures applied by the Company to prevent the use of its over-the-counter virtual currency exchange services (hereinafter “OTC Services”) for money laundering, terrorist financing , sanctions evasion, fraud or other illicit financial activities. 

The Company is in the process of applying for registration with the Financial Transactions and Reports Analysis Centre of Canada (hereinafter –“FINTRAC”) as a Money Services Business (hereinafter –“MSB” under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (hereinafter –“PCMLTFA”).

In preparation for its intended MSB activities, the Company maintains an AML/ATF compliance framework designed to meet the applicable anti-money laundering and anti-terrorist financing (hereinafter –“AML/ATF”) and sanctions requirements that will apply to its activities upon commencement of regulated operations.

This Notice is published on the Company’s Website for general informational purposes only and provides a description of the Company’s approach to AML/ATF compliance. The Company maintains separate internal AML/ATF policies and procedures that govern its operations and are applied in the course of providing the Services, including in relation to client due diligence, risk assessment, transaction monitoring, regulatory reporting and other compliance measures. Detailed operational requirements, internal controls, risk assessment methodologies, monitoring criteria and escalation procedures are maintained within the Company’s internal compliance framework and are not intended for public disclosure.

* NOW, access to the Website does not entitle any User to receive OTC Services. The availability of OTC Services is subject to the completion of the Company’s registration with FINTRAC and any other applicable legal or regulatory requirements.

Any references in this Notice to the Company’s AML/ATF measures in connection with the provision of OTC Services describe the compliance framework intended to apply upon commencement of such services. *

1. AML/ATF COMPLIANCE FRAMEWORK

The Company maintains an AML/ATF compliance framework designed to prevent, detect and mitigate the risk of the OTC Services being used for money laundering, terrorist financing, sanctions evasion, fraud or other illicit financial activities.

The Company applies a risk-based approach to AML/ATF compliance and implements measures appropriate to the nature of its OTC Services and the risks associated with its Clients and transactions.

The Company’s AML/ATF framework includes, as applicable:

  1. Client identification and verification, including Know Your Client (hereinafter – “KYC”) and Know Your Business  (hereinafter –“KYB”) measures;
  2. Client and transaction risk assessment;
  3. enhanced due diligence  (hereinafter –“EDD”)  where warranted by the level of risk;
  4. sanctions, politically exposed person (hereinafter – “PEP”), head of an international organization (hereinafter –“HIO”) and other relevant compliance screening; 
  5. ongoing monitoring of business relationships and transactions;
  6. monitoring and assessment of virtual currency transactions ;
  7. regulatory reporting and cooperation with competent authorities; and
  8. maintenance and retention of records in accordance with applicable legal and regulatory requirements.

The Company may use appropriate technological solutions and third-party service providers to support certain elements of its AML/ATF compliance framework, including identity and business verification, screening, transaction monitoring and blockchain analytics. The use of such service providers does not relieve the Company of its applicable AML/ATF obligations.

2. CLIENT IDENTIFICATION AND DUE DILIGENCE 

The Company applies Client identification and due diligence measures before establishing a business relationship or providing OTC Services. The scope of such measures is determined in accordance with applicable Canadian AML/ATF requirements and the Company’s internal AML/ATF policies and procedures.

As part of the Client due diligence process, the Company may obtain and verify information relating to:

  • the identity of individual Clients;
  • the legal existence and business activities of corporate Clients;
  • directors, authorized representatives and other persons acting on behalf of a Client;
  • ownership and control structure and beneficial owners, where applicable;
  • the purpose and intended nature of the business relationship or proposed OTC transaction;
  • expected transaction activity and relevant geographic exposure; and
  • source of funds and, where appropriate, source of wealth.

The Company may request additional information or supporting documentation where necessary to complete Client verification, understand the nature or purpose of a proposed transaction, establish the source of funds or virtual currency, or address identified AML/ATF, sanctions or other financial crime risks.

Clients are required to provide accurate, complete and current information and to reasonably cooperate with the Company’s due diligence requirements. The Company may require previously provided information or documentation to be updated or re-verified where appropriate.

3. RISK-BASED APPROACH AND ENHANCED DUE DILIGENCE

The Company applies a risk-based approach to its AML/ATF activities in order to identify, assess and mitigate money laundering, terrorist financing, sanctions evasion and other relevant financial crime risks associated with its Clients and OTC Services. The nature and extent of the AML/ATF measures applied may vary depending on the circumstances and the level of risk identified.

In assessing AML/ATF risks, the Company may take into account relevant factors including:

  • the Client’s identity, background, occupation or business activities;
  • the Client’s ownership and control structure and beneficial owners, where applicable;
  • the purpose and intended nature of the business relationship;
  • the nature, size, frequency and expected pattern of OTC transactions;
  • the source and destination of funds or virtual currency;
  • countries and jurisdictions connected with the Client or transaction;
  • the use of third parties, intermediaries, bank accounts or virtual currency wallets;
  • sanctions, PEP/HIO, adverse information and other relevant compliance considerations; and
  • any other circumstances or risk indicators considered relevant under applicable law or the Company’s internal AML/ATF framework.

Where a Client, business relationship or transaction presents a higher level of risk, the Company may apply EDD and other enhanced measures. Such measures may include obtaining additional information or supporting documentation, conducting screening, obtaining further information concerning the purpose of a transaction, obtaining additional management or compliance approval where appropriate, and applying enhanced monitoring or other measures appropriate to the identified risk.

The Company determines the appropriate level of due diligence and risk-mitigation measures on a case-by-case basis in accordance with applicable legal and regulatory requirements and its internal AML/ATF framework. The Company’s internal risk classifications, assessment methodologies, criteria and thresholds are not disclosed in this Notice.

4. SANCTIONS SCREENING AND GEOGRAPHIC RESTRICTIONS

The Company conducts sanctions and other relevant compliance screening as part of its AML/ATF framework. Such screening may apply to Clients, beneficial owners, directors, authorized representatives, counterparties and other persons connected with a business relationship or OTC transaction, where appropriate.

The Company screens against sanctions and other restrictive measures applicable to it under Canadian law, including applicable Canadian sanctions and terrorist property restrictions. The Company may also take into account United Nations sanctions and other sanctions or screening sources incorporated into its internal compliance framework.

The Company will not establish or continue a business relationship or process an OTC transaction where doing so would be prohibited under applicable Canadian sanctions laws, regulations, Ministerial Directives or other binding legal or regulatory requirements.

In addition to restrictions required by law, the Company applies geographic restrictions under its internal risk-based framework. These restrictions may be more stringent than the minimum requirements imposed by applicable law where the Company determines that the relevant money laundering, terrorist financing, sanctions evasion or other financial crime risks fall outside its risk appetite.

4.1 Prohibited Jurisdictions, Territories and Regions

As part of its risk-based AML/ATF framework, the Company does not provide OTC Services where a Client, business relationship or transaction has a material direct or indirect connection with any of the jurisdictions, territories or regions listed below. These geographic restrictions reflect the Company’s internal risk appetite and may be broader than restrictions expressly required under applicable Canadian law.

For the purposes of this Notice, a material connection includes, in particular:

  • the Client being established, incorporated, resident or operating in a listed jurisdiction;
  • a beneficial owner or person exercising control being resident or established in a listed jurisdiction;
  • the source or destination of funds or virtual currency being connected with a listed jurisdiction; or
  • a financial institution, virtual asset service provider, payment intermediary or other material participant in the relevant transaction or business relationship being established in a listed jurisdiction.

Prohibited jurisdictions, territories and regions include: 

Abkhazia; Afghanistan; Belarus; Central African Republic; Crimea; Cuba; Democratic Republic of the Congo; occupied parts of the Donetsk region of Ukraine; Democratic People’s Republic of Korea (DPRK); Eritrea; Guinea; Guinea-Bissau; Haiti; Iran; Iraq; occupied parts of the Kherson region of Ukraine; Lebanon; Libya; occupied parts of the Luhansk region of Ukraine; Myanmar; Nicaragua; Russia; Somalia; South Ossetia; South Sudan; Sudan; Syria; Transnistria; Venezuela; Yemen; occupied parts of the Zaporizhzhia region of Ukraine; and Zimbabwe.

Nationality, place of birth, previous residence or another historical or incidental connection with a listed jurisdiction does not, by itself, constitute a prohibited geographic exposure. Such connections may nevertheless be considered as part of the Company’s overall risk assessment.

The list of prohibited jurisdictions, territories and regions may be amended from time to time to reflect changes in applicable law, sanctions measures, Ministerial Directives, regulatory developments and the Company’s internal risk assessment. The Company may also restrict or decline Clients, business relationships or transactions involving other jurisdictions where the associated risks cannot be adequately understood, mitigated or managed within the Company’s risk appetite.

5. TRANSACTION MONITORING AND TRAVEL RULE

The Company monitors Client activity and transactions in order to identify unusual, suspicious or elevated-risk activity and to assess whether transactions are consistent with the Client’s known profile, expected activity and purpose of the business relationship.

As part of transaction monitoring, the Company may consider, where relevant:

  • the nature, amount, frequency and pattern of transactions;
  • the source and destination of funds or virtual currency;
  • the parties, counterparties and jurisdictions involved;
  • the purpose and circumstances of the transaction;
  • blockchain transaction history and associated wallet addresses;
  • exposure to sanctioned, illicit or otherwise elevated-risk addresses, services or activities; and
  • other relevant AML/ATF, sanctions or financial crime risk indicators.

Where a transaction or activity raises compliance concerns, the Company may:

  • conduct additional review or verification;
  • request information or supporting documentation regarding the transaction, source of funds or virtual currency;
  • apply enhanced monitoring or other risk-mitigation measures; and
  • delay, suspend, restrict or decline a transaction where required or permitted by applicable law or the Company’s internal AML/ATF framework.

Travel Rule. Where applicable, the Company complies with Canadian Travel Rule requirements for virtual currency transfers, including by ensuring that prescribed originator and beneficiary information accompanies outgoing transfers and taking reasonable measures to obtain required information in relation to incoming transfers. Where required information is missing or incomplete, the Company applies risk-based procedures to determine whether the transfer should be allowed, suspended or rejected.

6. REGULATORY REPORTING

The Company assesses transactions and activities for applicable reporting obligations and submits reports or disclosures to FINTRAC or other competent authorities where required by Applicable Law.

Such reporting may include:

  • Suspicious Transaction Reports  (hereinafter – “STRs”);
  • Large Virtual Currency Transaction Reports (hereinafter – “LVCTRs”);
  • Listed Person or Entity Property Reports (hereinafter – “LPEPRs”); and
  • other reports or disclosures applicable to the Company’s activities.

The Company determines whether a reporting obligation arises based on the circumstances of the relevant transaction or activity and the requirements of Applicable Law. The fact that a transaction is delayed, declined or otherwise subject to compliance review does not, by itself, mean that a regulatory report will be filed.

7. RESTRICTED AND PROHIBITED USE

The Company does not provide OTC Services to Clients, or in connection with activities or transactions, that are prohibited by applicable law or fall outside the Company’s established risk appetite.

The Company may refuse to onboard or provide OTC Services to Clients who:

  • are subject to applicable sanctions or other legally binding restrictions;
  • cannot be satisfactorily identified or verified;
  • fail or refuse to provide information or documentation reasonably required for AML/ATF compliance;
  • provide information or documentation that the Company reasonably believes to be false, misleading, incomplete or materially inconsistent;
  • conceal or fail to disclose beneficial ownership, control, representation or the involvement of a third party;
  • are reasonably suspected of using or intending to use the OTC Services for unlawful purposes; or
  • otherwise present AML/ATF, sanctions or financial crime risks that the Company cannot adequately understand, mitigate or manage within its risk appetite.

The OTC Services must not be used in connection with:

  • money laundering, terrorist financing, sanctions evasion, fraud or other criminal activity;
  • transactions involving proceeds of crime or virtual currency reasonably suspected to derive from unlawful activity;
  • concealment of the origin, ownership, destination or beneficial ownership of funds or virtual currency;
  • circumvention of AML/ATF, sanctions, reporting or other regulatory requirements;
  • transactions conducted for or on behalf of an undisclosed third party;
  • any other activity prohibited by applicable law or outside the Company’s risk appetite.

Where a prohibited or unacceptable risk is identified, the Company may, as appropriate:

  • refuse or discontinue onboarding;
  • request additional information or documentation;
  • refuse, delay, restrict or suspend an OTC transaction;
  • restrict access to the OTC Services;
  • terminate an existing business relationship; or
  • take any other action required or permitted by applicable law.

The application of any restriction, refusal, suspension or termination does not by itself determine whether regulatory reporting is required. Any reporting obligation is assessed separately in accordance with applicable Canadian AML/ATF requirements and the Company’s internal compliance framework.

8. RECORD KEEPING

The Company maintains records and documentation required under applicable Canadian AML/ATF laws and regulations. Such records may include, where applicable:

  • Client identification and verification information;
  • beneficial ownership and authorized representative information;
  • due diligence and risk assessment records;
  • records relating to OTC transactions and virtual currency transfers;
  • transaction monitoring and screening records; and
  • other records required for AML/ATF compliance purposes.

Records are retained for the periods required by applicable Canadian law and the Company’s internal record-keeping procedures.

Personal information collected and retained for AML/ATF purposes is handled in accordance with applicable privacy requirements and the Company’s Privacy Policy.

9. CONFIDENTIALITY

Information relating to the Company’s AML/ATF reviews, investigations, monitoring activities and regulatory reporting is treated as confidential and is disclosed only where required or permitted by applicable law.

The Company may be prohibited or restricted from informing a Client whether:

  • a suspicious transaction or other regulatory report has been submitted or is being considered;
  • a transaction or Client is subject to an internal compliance review or investigation; or
  • information has been provided to FINTRAC or another competent authority.

The Company does not disclose its confidential internal AML/ATF controls, including internal risk assessment methodologies, monitoring criteria, risk indicators, thresholds, escalation procedures or reporting methodologies.

10. CHANGES TO THIS NOTICE

The Company may review and update this Notice from time to time to reflect changes in applicable laws and regulations, regulatory requirements or guidance, the Company’s OTC Services, business operations, risk profile or internal AML/ATF compliance framework.

Any updated version of this Notice will be published on the Company’s Website and will become effective from the date indicated as the “Last Updated” date, unless otherwise stated.

Clients are encouraged to review the current version of this Notice periodically to remain informed of the Company’s general AML/ATF approach and any changes that may affect the provision of OTC Services.

11. CONTACT INFORMATION

Questions regarding this Notice or the Company’s general AML/ATF requirements may be submitted using the contact details below:

Company name: Blackverge Financial Inc.

Registered address: 700-602 12 AVE SW, Calgary, Alberta, T2R1J3, Canada.
Email: blackverge.financial@gmail.com