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AML / CTF Policy

Last updated: September 27, 2026

CryptoPAYR Limited maintains an Anti-Money Laundering ("AML") and Counter-Terrorist Financing ("CTF") programme designed to comply with the Canadian Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA"), applicable Cayman Islands law and FATF standards. The Services are provided through a Money Services Business registered with and regulated by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under MSB registration number M/2264-958/5, and the programme is operated to that standard.

Risk-based approach

CryptoPayr is a crypto-only service and does not offer direct fiat conversion or fiat settlement. We apply a risk-based programme built around transaction monitoring, blockchain analytics and sanctions screening rather than the collection of identity documents, and we manage risk through on-chain controls and the limits described below.

No required KYC or KYB

We do not require Know Your Customer ("KYC") identity verification or Know Your Business ("KYB") verification to open or operate a merchant account, or to use our no-account crypto swap. We do not require merchants or users to verify their identity or beneficial ownership, to provide identity documents, or to demonstrate source of funds or wealth. Merchants may choose to verify their identity through our verification partner; this is voluntary and is never a condition of opening or using an account. Our no-account crypto swap settles a maximum of $10,000 per transaction; this is a per-transaction settlement limit set for operational and risk reasons and is not tied to any identity check.

Transaction monitoring

We monitor activity for indicators of money laundering, fraud and sanctions exposure, including blockchain analytics and screening of wallet addresses against risk databases.

Sanctions screening

We screen wallet addresses and counterparties against applicable sanctions lists and prohibit use from restricted jurisdictions (see Geographic Restrictions). Every outbound crypto send is screened before any funds move.

Reporting & record-keeping

We file suspicious transaction reports with the FINTRAC and any other relevant authority where required and retain transaction records for the period mandated by law. We will not "tip off" a customer about a report.

Cooperation

We may freeze funds, suspend accounts, and disclose information to regulators or law enforcement as required by law.

Contact

Questions about this policy? Contact us at [email protected] or by post at CryptoPAYR Limited, Cayman Corporate Centre, Office 2852, George Town, Grand Cayman, Cayman Islands.