Policies & Procedures – Sharp Route Financial Services Ltd.
Sharp Route Financial Services Ltd. is committed to preventing its services from being used for money laundering or terrorist financing activities. We comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and all related FINTRAC regulatory requirements.
This policy applies to all directors, officers, employees, contractors, and advisors of Sharp Route Financial Services Ltd.
Money Laundering: The process of concealing the origins of illegally obtained money.
Terrorist Financing: Providing or collecting funds intended to support terrorist activities.
Politically Exposed Person (PEP): An individual who holds or has held prominent public functions, including their family members and close associates.
Beneficial Ownership: Natural persons who ultimately own or control a client, directly or indirectly.
Sharp Route Financial Services Ltd. evaluates risks related to clients, services, products, delivery channels, and geographic regions. High-risk clients such as Politically Exposed Persons (PEPs) or clients located in high-risk jurisdictions require enhanced due diligence procedures.
Before establishing a business relationship, we must:
Sharp Route Financial Services Ltd. maintains records of:
All records must be retained for a minimum of five (5) years.
The following reports must be submitted to FINTRAC:
Ongoing monitoring of all client relationships and transactions is conducted to detect unusual or suspicious activities that may indicate money laundering or terrorist financing.
All employees and advisors must complete AML/ATF compliance training upon hiring and annually thereafter. Training includes identifying suspicious activities, reporting procedures, and regulatory compliance requirements.
The AML/ATF compliance program must be reviewed by an independent party at least once every two years to ensure effectiveness and regulatory compliance.
Failure to comply with this policy may result in disciplinary action including termination of employment and may expose individuals and the organization to criminal, civil, or regulatory penalties.
This policy will be reviewed annually and updated as necessary to ensure compliance with legislative changes or regulatory guidance.
