Risk appetite and restricted activities.

BREADX PAY (BC) Limited’s onboarding and transactional risk appetite defines the level of risk it is willing to assume concerning its clients and the transactions it processes. The company uses a risk-based approach for client relationships and transactional activity.

Systems and controls are maintained to deter, detect and disrupt financial crime. Treating clients fairly and enforcing the risk framework — including policies on politically exposed persons (PEPs), illegal activity, sanctioned counterparties, criminals and individuals associated with terrorism — are required of the company and expected of stakeholders.

BREADX PAY (BC) Limited onboards small, medium or large corporations only. It does not onboard sole traders, micro-enterprises or small charities.

The company is committed to applicable laws and regulations, including those related to anti-money laundering, counter-terrorism financing, sanctions and export control. Banking partners uphold their own limits on industries, activities and countries. Failure to comply can result in delayed or declined payments. Repeated breaches can lead to account closure. Speak with the relationship manager for a live programme.

Prohibited locations

BREADX PAY (BC) Limited prohibits onboarding companies with any subsidiaries, ultimate beneficial owners (UBOs), directors or operations resident in, or websites targeting, the following sanctioned countries: Iran, North Korea, Syria, Myanmar, Cuba, Venezuela, Russia.

The fuller unsupported-jurisdiction list is published separately.

Prohibited businesses

• Businesses operating or running Hawala (informal banking system)
• Companies engaged in or providing illegal drugs and/or unlicensed drug-related activity
• Unregulated pharmaceuticals/food supplement companies (nutraceuticals)
• Activities related to defense and munitions, including dual-use items
• Binary options or unregulated investments
• Companies formed of bearer shares
• Company structures comprising only nominee directors (there must always be individual directors)
• Companies dealing in counterfeit goods
• Companies dealing with cultural artifacts, ivory, or other items related to protected species, or with items of archaeological, historical, religious, or rare scientific value
• Companies involved in piracy or illegal streaming
• Political or religious organizations engaged in hate speech
• Pyramid schemes or multi-level marketing (MLM) schemes
• Companies dealing in non-electronic funds
• Unregulated institutions that should be regulated
• Shell banks
• Shell companies (a company having no physical presence, no employees, or no commercial activity in its registered jurisdiction)
• “Get rich quick” schemes (proposals to pay high rates of return over a short period in return for a small investment)
• Unregulated charities
• Banks not located/domiciled onshore

Additional requirements for specific industries

Clients in certain industries must meet an initial set of criteria, and further industry-specific criteria, before they can be onboarded.

Initial risk-assessment criteria include:

• No unresolved AML/CTF failings or fines
• Adherence to BREADX PAY (BC) Limited’s industry-specific policies and control frameworks
• Compliance with regulatory limitations applicable to the jurisdiction

For a comprehensive list of restricted jurisdictions, see Unsupported jurisdictions.

BREADX PAY (BC) Limited is Registreraed by The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) to operate as a Money Service Business. Services offered include: Payment Service Provider, Money Transferring, and Dealing in Foreign Exchange and Virtual Currency. FINTRAC MSB Registration No. M24963656.

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