Anti-Money Laundering Policy

Ntradex Solutions Inc. ("Ntradex," "we," "our," or "us") is a registered Money Service Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), registration number C10001380. We are also registered with the Bank of Canada under the Retail Payments Activities Act (RPAA) as a payment service provider.

This AML Policy has been prepared in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations. It applies to all Ntradex products, services, and platforms, and to all individuals and businesses that use our services, regardless of where they are located.

Ntradex has zero tolerance for money laundering, terrorist financing, and any other form of financial crime. We are committed to protecting the integrity of the global financial system and cooperating fully with law enforcement and regulatory authorities.

Money laundering is the process by which the proceeds of criminal activity are made to appear legitimate. It typically involves three stages: placement (introducing illicit funds into the financial system), layering (obscuring the trail through complex transactions), and integration (reintroducing the funds into the economy in a form that appears legitimate).

Terrorist financing refers to the provision of funds — whether from legitimate or illegitimate sources — to individuals or groups for the purpose of carrying out terrorist acts, or to support terrorist organisations. Unlike money laundering, the funds involved in terrorist financing may originate from entirely legal sources.

Both offences are serious crimes under Canadian law, including under the PCMLTFA, the Criminal Code of Canada, and the Terrorism Act. Individuals and organisations found guilty of either offence face severe criminal penalties, including imprisonment and asset forfeiture.

Ntradex's AML compliance programme is anchored in Canadian federal law and guided by international standards. Our primary obligations arise under:

Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) — Canada's principal AML/ATF statute. As a FINTRAC-registered MSB, Ntradex is a "reporting entity" under the PCMLTFA and is required to maintain a compliance programme, conduct customer due diligence, keep records, and report certain transactions to FINTRAC.

FINTRAC Guidelines — The Financial Transactions and Reports Analysis Centre of Canada publishes operational guidance that informs our policies, procedures, and risk assessments.

Retail Payments Activities Act (RPAA) — Ntradex is registered with the Bank of Canada under the RPAA. Our operational risk management and safeguarding obligations under the RPAA complement our AML/ATF compliance framework.

Financial Action Task Force (FATF) — As an international standard-setter for AML/CFT, FATF recommendations and country-risk assessments inform how we assess the risk profiles of transactions, corridors, and counterparties. Ntradex treats jurisdictions on the FATF grey list or black list as high-risk by default, applying enhanced due diligence to transactions involving those countries.

Customer identity verification is the cornerstone of our AML programme. We are required by law to verify the identity of every customer before providing services, and to maintain records of that verification. Our KYC procedures are designed to ensure that we know who our customers are, understand the nature of their business, and can assess the risk they represent.

4.1 Identity Verification

All personal account holders must provide government-issued photo identification before transacting. Business account holders must provide corporate documentation including certificates of incorporation, beneficial ownership registers, and identity verification for all individuals who own 25% or more of the business.

We use a combination of document verification, biometric checks, and third-party identity verification services to confirm that the information provided matches the individual presenting it. We reserve the right to request additional documentation at any time.

4.2 Beneficial Ownership

For business accounts, Ntradex identifies and verifies the beneficial owners of the entity — those individuals who ultimately own or control the business. We are required under the PCMLTFA to collect and maintain beneficial ownership information and to update it when it changes.

4.3 Politically Exposed Persons (PEPs) and Heads of International Organisations (HIOs)

Ntradex screens all customers against PEP and HIO lists as part of onboarding and on an ongoing basis. A Politically Exposed Person is an individual who holds or has held a prominent public function domestically or internationally, or is a close associate or family member of such a person. Given the elevated risk of corruption associated with PEPs, we apply enhanced due diligence measures to all PEP relationships, including senior management approval, additional source-of-funds verification, and more frequent transaction monitoring.

4.4 Customer Risk Assessment

Each customer is assigned a risk rating — low, medium, or high — based on a combination of factors including the nature of their business, the countries and corridors they transact in, their transaction volumes and patterns, and the results of screening against sanctions lists and adverse media. Higher-risk customers are subject to more intensive monitoring and periodic review.

Examples of customer types that may attract elevated risk include: businesses that deal primarily in cash or cash equivalents; companies operating in sectors with historically high exposure to illicit finance (such as armaments, unregulated charities, and high-value goods dealers); and customers whose transactions are inconsistent with their stated business purpose.

4.5 Sanctions Screening

Ntradex screens all customers and transactions against applicable sanctions lists, including those maintained by the Government of Canada (the Special Economic Measures Act and United Nations Act lists), the U.S. Office of Foreign Assets Control (OFAC), the UK Office of Financial Sanctions Implementation (OFSI), and the European Union. Any customer or transaction that matches a sanctions designation will be blocked, and Ntradex may be required to report such a match to the relevant authority.

Ntradex employs automated and manual transaction monitoring systems to detect activity that may be indicative of money laundering, terrorist financing, or other financial crime. Our monitoring systems apply risk-based rules and behavioural analytics to flag transactions that are unusual, inconsistent with a customer's profile, or consistent with known patterns of illicit activity.

Indicators of suspicious activity include, but are not limited to: transactions with no apparent economic purpose; structuring transactions to avoid reporting thresholds; use of multiple accounts or third-party payers to obscure the origin or destination of funds; sudden significant changes in transaction volume; and requests to send funds to or receive funds from high-risk jurisdictions without a clear business rationale.

Ntradex also monitors for indicators of fraud, sanctions evasion, and proliferation financing as part of its broader financial crime risk management framework.

As a FINTRAC-registered reporting entity, Ntradex is legally required to file certain reports with FINTRAC. These reports are not discretionary — they are obligations under the PCMLTFA, and failure to file them is a criminal offence. Our primary reporting obligations are as follows:

6.1 Suspicious Transaction Reports (STRs)

Ntradex must submit a Suspicious Transaction Report to FINTRAC when there are reasonable grounds to suspect that a transaction or attempted transaction is related to money laundering or terrorist financing. The obligation to file an STR arises from reasonable suspicion — it does not require certainty, nor does it require that the transaction be completed. STRs must be filed within 30 days of a transaction being identified as suspicious.

6.2 Large Cash Transaction Reports (LCTRs)

Ntradex must report to FINTRAC any cash transaction of $10,000 CAD or more (or its equivalent in another currency) received in a single transaction, or in two or more transactions that total $10,000 or more within 24 hours where Ntradex knows or suspects they were conducted by the same person or entity. LCTRs must be filed within 15 days of the transaction.

6.3 Electronic Funds Transfer Reports (EFTRs)

Ntradex must report international electronic funds transfers of $10,000 CAD or more — both incoming and outgoing — to FINTRAC. These reports are filed within 5 business days of the transfer date.

6.4 Terrorist Property Reports (TPRs)

If Ntradex knows or believes that it is in possession or control of property that belongs to a terrorist group or that has been used or will be used to facilitate a terrorist activity, it must immediately report this to FINTRAC and to the Royal Canadian Mounted Police (RCMP) or the Canadian Security Intelligence Service (CSIS).

The PCMLTFA requires Ntradex to keep records of all transactions, customer identification documents, beneficial ownership information, and related correspondence for a minimum of five (5) years from the date the record was created. Records must be kept in a form that can be produced to FINTRAC upon request, and must be accessible and legible throughout the retention period.

Ntradex maintains its records in secure, encrypted storage systems with access controls appropriate to the sensitivity of the information. Records subject to a FINTRAC production order or law enforcement request will be produced in the required format and within the required timeframe.

Customers who close their accounts should note that Ntradex retains their identity, transaction, and account records for the full five-year retention period required by law, notwithstanding the closure of the account. This obligation takes precedence over any request for earlier deletion of personal data.

Ntradex reserves the absolute right to refuse to process any transaction, to suspend or terminate any account, or to decline to onboard any customer where:

We are unable to verify the identity of a customer or beneficial owner to our satisfaction; a customer provides false, misleading, or incomplete information; a transaction appears to be designed to circumvent legal reporting requirements; a customer or counterparty is the subject of a sanctions designation or a court order; or we have reasonable grounds to suspect that a transaction is connected to money laundering, terrorist financing, fraud, or any other financial crime.

Where Ntradex terminates a relationship or refuses a transaction on AML/ATF grounds, we may be required by law to file an STR with FINTRAC. In such cases, and consistent with the tipping-off prohibition described in Section 6.4, Ntradex will not disclose the reason for the refusal or termination to the customer.

Any customer who provides false identification documents or knowingly makes false representations to Ntradex for the purpose of evading AML controls will be reported to law enforcement authorities and may be subject to criminal prosecution.

Not all jurisdictions present the same level of AML/ATF risk. Ntradex maintains a country risk matrix that is updated regularly to reflect current FATF guidance, Government of Canada advisories, and our own analysis of the corridors in which we operate.

Jurisdictions on the FATF grey list (subject to increased monitoring) or black list (high risk, subject to a call for action) are treated as high-risk by Ntradex. Transactions to or from these jurisdictions, or involving counterparty financial institutions based there, are subject to enhanced due diligence, including senior management approval for new relationships and more frequent review of existing ones.

Our primary operating corridors — including Nigeria, Ghana, Kenya, South Africa, Canada, Australia, the United Kingdom, and the United States — each carry their own risk profile, and our controls are calibrated accordingly. We continuously refine our corridor-specific monitoring rules to reflect the most current intelligence about financial crime patterns in those markets.

Ntradex's AML compliance programme is overseen by a designated Compliance Officer who is responsible for implementing and maintaining the programme, reporting to senior management on compliance matters, and serving as the primary point of contact with FINTRAC and other regulatory authorities.

The programme includes: written policies and procedures that reflect current regulatory requirements; ongoing employee training on AML/ATF obligations, red flags, and internal escalation procedures; an independent audit function that periodically tests the effectiveness of controls; and a risk assessment process that evaluates Ntradex's exposure to money laundering and terrorist financing and informs the calibration of controls.

All Ntradex employees, contractors, and agents who interact with customers or process transactions are required to complete AML/ATF training appropriate to their role, and to report any suspicious activity they observe through Ntradex's internal escalation process without delay. Retaliation against any employee who makes a good-faith report of suspected financial crime is strictly prohibited.

By using Ntradex's services, you agree that you will not use the platform for any purpose connected to money laundering, terrorist financing, fraud, sanctions evasion, or any other illegal activity. You agree to provide accurate and complete information during onboarding and throughout your relationship with Ntradex, and to promptly notify us of any material changes to your circumstances, business purpose, or ownership structure.

You acknowledge that Ntradex is required by law to collect, verify, and retain your identity information and transaction records, and that Ntradex may be required to report certain transactions and information about you to FINTRAC and other government authorities without notifying you.

You also acknowledge that Ntradex may decline to process transactions or terminate your account without explanation in circumstances where doing so is required by law or is necessary to comply with our AML/ATF obligations, and that no liability attaches to Ntradex for such actions where they are taken in good faith.

Your acceptance of Ntradex's Terms and Conditions at the time of account creation constitutes your acknowledgement that you have read and understood this AML Policy and agree to be bound by its requirements.

Ntradex reviews and updates this AML Policy at least annually, or more frequently when required by changes in law, regulation, or the risk environment. Material changes will be published on our website and communicated to existing customers by email at least fourteen (14) days before they take effect.

The current version of this policy is always available at ntradex.ca/aml-policy. Your continued use of our services following the effective date of any update constitutes acceptance of the revised policy.