TeemoPay is fully committed to upholding the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. As a regulated Money Services Business (MSB) registered under the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) with MSB Registration No. M23802826, TeemoPay enforces a globally aligned AML/CTF compliance framework, designed in accordance with the Financial Action Task Force (FATF) recommendations, the PCMLTFA, and international best practices.
This policy applies globally and governs how TeemoPay prevents, detects, investigates, and reports any activities related to money laundering, terrorism financing, sanctions evasion, and financial crime.

• Ensure compliance with national and international AML/CTF laws and regulations
• Detect and prevent the use of TeemoPay services for money laundering, terrorism financing, or other illicit purposes
• Implement a risk-based approach to customer onboarding, monitoring, and transaction processing
• Promote a culture of compliance, transparency, and accountability throughout the organization
• Cooperate proactively with law enforcement and regulatory authorities

This policy applies to:

• All TeemoPay employees, contractors, agents, and subsidiaries
• All TeemoPay clients, including direct merchants and platform integrators
• All business activities, including onboarding, transaction processing, settlement, and reporting
• All jurisdictions where TeemoPay operates or offers services

TeemoPay has appointed a dedicated Compliance Officer with the authority and independence to:

• Oversee and continuously improve the AML/CTF program
• Report directly to senior management and the Board of Directors
• Approve high-risk clients and jurisdictions
• Act as the primary point of contact with FINTRAC and other regulators

TeemoPay also maintains a Compliance Committee responsible for policy oversight, risk review, and strategic compliance direction.

TeemoPay applies a dynamic and comprehensive risk-based approach that includes:

• Risk categorization of clients by industry, region, transaction type, and delivery channel
• Enhanced Due Diligence (EDD) for high-risk industries (e.g., Forex, iGaming, lending) and jurisdictions
• Continuous risk re-assessment during the client lifecycle
• Proactive de-risking of clients with elevated exposure or non-cooperative behavior

TeemoPay enforces robust Know Your Business (KYB) and Customer Due Diligence (CDD) controls:

• Verification of legal entity identity, registration documents, and business license
• Identification and verification of Ultimate Beneficial Owners (UBOs) holding 25%+ interest
• Screening against global sanctions lists, PEP databases, adverse media
• Geolocation/IP intelligence, device fingerprinting, and access behavior profiling
• Ongoing due diligence and periodic information refreshes

EDD measures may include:

• Source of funds and source of wealth verification
• Additional documentation for ownership/control structures
• Independent verification of licensing and regulatory standing

TeemoPay maintains automated and manual transaction monitoring protocols:

• Real-time and post-settlement analysis of transaction velocity, frequency, and anomaly patterns
• Rules-based and machine-learning models for behavioral scoring
• Continuous screening of clients and transactions against global watchlists
• Monitoring thresholds dynamically adjusted based on evolving risk levels
• Triggers for Suspicious Activity Reports (SAR/STR), internal alerts, and escalations

TeemoPay fulfills its regulatory reporting obligations through:

• Filing of Suspicious Transaction Reports (STRs), Large Virtual Currency Transactions (LVCTs), and Large Cash Transaction Reports (LCTRs) with FINTRAC
• Timely response to subpoenas, production orders, and regulatory examinations
• Maintenance of an internal case management system to document all investigationsmer credit issuance

TeemoPay enforces real-time screening of clients, transactions, and counterparties against:

• United Nations Sanctions Lists
• Office of Foreign Assets Control (OFAC) SDN & Non-SDN lists
• European Union Consolidated Sanctions List
• UK HMT Sanctions List
• Domestic or regional sanctions lists relevant to operational jurisdictions

Sanction matches trigger automated blocking, manual review, and regulatory escalation procedures.

TeemoPay retains AML-related records for a minimum of five (5) years from the date of transaction or end of business relationship, including:

• KYB files and identity verification documentation
• UBO declarations and ownership charts
• All payment transactions and system logs
• Risk assessments, STRs, EDD files, and compliance communications

All records are encrypted and securely stored in compliance with data protection standards.

TeemoPay ensures AML/CTF training across all staff levels:

• Mandatory AML onboarding training for all new hires
• Annual refresher courses with jurisdiction-specific modules
• Specialized training for compliance, operations, tech, and BD teams
• Periodic assessments to evaluate training effectiveness

Employees are required to report any suspicious activity to the Compliance Officer via internal whistleblower mechanisms.

All third-party providers, agents, and integration partners must undergo due diligence review, including:

• Contractual AML obligations and information-sharing clauses
• Periodic re-certification and audit cooperation
• Immediate notification of material breaches or regulatory inquiries

TeemoPay does not work with anonymous, shell, or non-transparent intermediaries.

TeemoPay’s AML program undergoes:

• Internal audit by an independent function at least annually
• Third-party external review when required by jurisdictional regulators
• Remediation of identified gaps within fixed timelines
• Board-level oversight of audit findings and action plans

This AML/CTF policy is reviewed annually or in response to:

• Regulatory changes (local or international)
• New product or service launches
• Expansion into new geographies
• Internal or external audit feedback

All changes are approved by the Compliance Committee and documented in the policy revision log.

For compliance inquiries, document submission, or escalation requests, please contact our Compliance Department at: 📩 legal@teemopay.com