Anti-Money Laundering (AML) Policy

1. Purpose

This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy outlines the procedures and controls that Polarbit Solutions Limited implements to detect, prevent, and report money laundering, terrorist financing, and other financial crimes.

2. Regulatory Framework

Our AML/CTF program is designed in compliance with:

• Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
• FINTRAC regulations and guidance
• FATF (Financial Action Task Force) Recommendations
• Canadian sanctions regulations
• Applicable provincial regulations

3. Know Your Customer (KYC)

All users must complete identity verification before accessing our services. Our KYC procedures include:

• Identity Verification: Government-issued photo ID (passport, national ID, or driver's license)
• Address Verification: Proof of residential address (utility bill, bank statement, or government letter)
• Enhanced Due Diligence: Additional verification for high-risk customers, including source of funds documentation
• Ongoing Monitoring: Continuous monitoring of customer transactions and activities

4. Customer Due Diligence (CDD)

We perform CDD at the following stages:

• During account registration
• When a transaction exceeds CAD 1,000
• When there is suspicion of money laundering or terrorist financing
• When there are doubts about previously obtained identification data
• On an ongoing basis throughout the business relationship

5. Transaction Monitoring

We employ automated and manual transaction monitoring to identify suspicious activities, including:

• Unusual transaction patterns or volumes
• Transactions inconsistent with customer profile
• Rapid movement of funds (layering)
• Transactions involving high-risk jurisdictions
• Structuring of transactions to avoid reporting thresholds

6. Sanctions Screening

All customers are screened against relevant sanctions lists, including Canadian, UN, OFAC, and other applicable sanctions lists. Screening is performed at onboarding and on an ongoing basis.

7. Politically Exposed Persons (PEPs)

We identify and apply enhanced due diligence to Politically Exposed Persons, their family members, and known close associates, in accordance with applicable regulations.

8. Suspicious Activity Reporting

We report suspicious transactions to FINTRAC (Financial Transactions and Reports Analysis Centre of Canada). All employees are trained to identify and escalate suspicious activities. We do not inform customers that a report has been or is being made.

9. Record Keeping

We maintain records of all customer identification documents, transaction records, and compliance documentation for a minimum of 5 years after the end of the business relationship, or as otherwise required by law.

10. Employee Training

All employees receive regular AML/CTF training, including identification of suspicious activities, regulatory updates, and internal procedures. Training records are maintained and reviewed annually.

11. Contact

For questions regarding this AML Policy, contact our Compliance Department:

Email: support@toloexchange.biz
Address: 700-838 W Hastings Street, Vancouver, BC V6C 0A6, Canada