Our commitment
Crestline Technologies Ltd., which provides its services under the Lyria brand, is committed to preventing its services from being used for money laundering, terrorist financing, sanctions evasion or other financial crime. We are registered with FINTRAC as a Money Services Business (registration number C10001565) for foreign exchange dealing and payment services and comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations, Canadian sanctions laws and the requirements of our banking and acquiring partners.
This statement summarises our program. Our detailed policies and procedures are internal and are available to regulators, auditors and partners under appropriate confidentiality.
Compliance program
Our compliance program includes each of the elements required by the PCMLTFA:
- a designated compliance officer with the authority, independence and resources to run the program, and direct access to senior management;
- written, up-to-date policies and procedures approved by senior management;
- a documented risk assessment covering our clients, products, services, delivery channels, geographies and new technologies;
- an ongoing written training program for employees and agents; and
- a two-year effectiveness review of the program, conducted by an internal or external reviewer.
Know your client and know your business
Before establishing a business relationship, we:
- verify the existence, legal form and registration of the business;
- identify and take reasonable measures to verify its directors and beneficial owners, including anyone who owns or controls 25% or more, directly or indirectly, and confirm its ownership and control structure;
- understand the purpose and intended nature of the relationship, the business model, expected volumes and markets;
- determine whether any related individual is a politically exposed person, a head of an international organisation, or a family member or close associate of one; and
- assign a risk rating that determines the level of ongoing scrutiny.
Higher-risk relationships are subject to enhanced due diligence, which may include source of funds and source of wealth verification, senior management approval and more frequent review.
Ongoing monitoring
We monitor business relationships and transactions on an ongoing basis, proportionate to risk, to detect activity that is unusual or inconsistent with what we know about a client. Client information is refreshed periodically and whenever a trigger event occurs.
Sanctions and listed persons
We screen clients, beneficial owners, counterparties and payout recipients against Canadian sanctions under the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act and the United Nations Act, against listed terrorist entities under the Criminal Code, and against other lists required by our partners. Screening takes place at onboarding, on an ongoing basis and before funds are released. Where we identify property of a listed person, we freeze it and report as the law requires.
Reporting to FINTRAC
We file the reports required of Money Services Businesses, which may include suspicious transaction reports, terrorist property reports, large cash transaction reports, large virtual currency transaction reports and electronic funds transfer reports. By law, we cannot tell anyone whether a report has been made.
Travel Rule
For electronic funds transfers that meet the regulatory thresholds, we include and retain the required originator and beneficiary information, and take reasonable measures where it is missing.
Ministerial directives and high-risk jurisdictions
We comply with ministerial directives issued under the PCMLTFA and apply enhanced measures, or decline business, involving jurisdictions identified as high risk.
Record keeping
We keep client identification records, transaction records, reports and supporting documents for at least five years, in a form that can be provided to FINTRAC within 30 days of a request.
What we expect from clients
- Accurate, complete and current information during onboarding and throughout the relationship.
- Prompt notice of changes in ownership, control, business model, markets or licences.
- Cooperation with reasonable requests for information or documents.
- Compliance with our acceptable use policy and with the laws that apply to your own business.
We may refuse, suspend or end a relationship, or decline or delay a transaction, where we cannot complete due diligence or where we suspect financial crime.
Contact
Compliance enquiries, including from regulators, auditors, partners and law enforcement: [email protected].