An overview of Brisk Pay’s Anti-Money Laundering and Financial Crime Prevention approach.
Anti-Money Laundering & Financial Crime Prevention
An overview of Brisk Pay’s approach to Anti-Money Laundering, customer due diligence, transaction monitoring and financial crime prevention.
Brisk Pay is committed to maintaining a secure and compliant payments environment and to preventing its services from being used for money laundering, terrorist financing, sanctions evasion, fraud or other unlawful financial activity.
Brisk Pay Ltd. is registered in British Columbia, Canada under Company No. BC1516153 and is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business under registration number C100000711.
Our compliance programme is designed to meet applicable requirements under Canadian anti-money laundering and anti-terrorist financing laws and regulations, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated regulations.
1. Our AML Commitment
Preventing financial crime is a core part of how Brisk Pay operates.
We maintain a risk-based compliance framework designed to identify, assess and manage money laundering, terrorist financing, sanctions, fraud and related financial crime risks associated with our customers, products, services, transactions and geographic exposure.
Our controls may evolve over time in response to changes in legislation, regulatory guidance, emerging financial crime risks, technology and the services offered through Brisk Pay.
Compliance requirements may also differ depending on the customer, transaction, jurisdiction, product or level of risk involved.
2. Compliance Governance
Brisk Pay maintains compliance oversight and procedures appropriate to its obligations as a Canadian Money Services Business.
Our AML compliance framework includes policies and procedures, risk assessment, customer due diligence, ongoing monitoring, employee training and compliance oversight.
The programme is periodically reviewed to assess its effectiveness and to identify areas requiring improvement or additional controls.
Brisk Pay maintains effectiveness reviews in accordance with applicable FINTRAC requirements, including the requirement for a review of the compliance programme at least every two years.
3. Know Your Customer and Know Your Business
Understanding who uses Brisk Pay is fundamental to preventing financial crime.
Before providing certain services, and where otherwise required by law, Brisk Pay carries out Know Your Customer (KYC) and Know Your Business (KYB) procedures to verify the identity of customers and understand the nature and purpose of their activity.
Depending on the customer and services requested, we may obtain or verify information including:
Full legal name
Date of birth
Residential or business address
Government-issued identification
Business registration or incorporation information
Nature of business activities
Directors and authorized representatives
Ownership and control information
Expected account or transaction activity
Other information reasonably required for verification or compliance purposes
The information and documentation required may vary according to regulatory requirements and the risk associated with the relationship.
Brisk Pay may use appropriately authorized third-party service providers to assist with identity verification, screening and other compliance processes.
4. Beneficial Ownership
Where a customer is a corporation, partnership or other legal entity, Brisk Pay may be required to identify and obtain information regarding the individuals who ultimately own or control the entity.
These individuals are commonly referred to as Ultimate Beneficial Owners (UBOs).
We may therefore request information concerning:
Ownership percentages
Shareholders
Directors
Individuals exercising direct or indirect control
Corporate ownership structures
Parent or related entities
Where an ownership or control structure is complex, additional information or documentation may be required before onboarding can be completed or services provided.
Customers are expected to provide complete and accurate beneficial ownership information and to inform Brisk Pay of material changes where required.
5. Customer Risk Assessment
Brisk Pay applies a risk-based approach to customer due diligence.
This means that customers and business relationships may be assessed using a range of relevant risk factors, which may include:
Nature of the customer or business
Products and services being used
Expected transaction activity
Geographic exposure
Ownership structure
Transaction patterns
Delivery channels
Counterparties
Other financial crime or regulatory risk indicators
The level of due diligence and monitoring applied may vary according to the risk identified.
Customers assessed as presenting a higher level of risk may be subject to additional due diligence, more frequent review or enhanced monitoring measures.
6. Enhanced Due Diligence
In certain circumstances, Brisk Pay may conduct Enhanced Due Diligence (EDD).
This may include requesting additional information or documentation relating to:
Source of funds
Source of wealth, where appropriate
Purpose and expected nature of a transaction
Relationship between the sender and beneficiary
Commercial rationale for a payment
Supporting invoices or contracts
Business activities
Ownership and control
Geographic or counterparty exposure
Other information required to assess a particular risk
Requests for additional information form part of normal compliance procedures and do not necessarily indicate that Brisk Pay considers a customer or transaction suspicious.
7. Politically Exposed Persons and Higher-Risk Relationships
As part of its customer due diligence procedures, Brisk Pay applies measures relating to Politically Exposed Persons (PEPs) and Heads of International Organizations (HIOs) where required under applicable Canadian law.
Relevant requirements may also extend to certain family members and close associates.
Where a person or relationship falls within an applicable PEP, HIO or other higher-risk category, Brisk Pay may carry out additional due diligence, obtain further information and apply enhanced ongoing monitoring in accordance with regulatory requirements and its risk-based procedures.
8. Sanctions Controls
Brisk Pay maintains controls designed to manage risks arising from applicable economic sanctions and related restrictions.
As part of its compliance processes, Brisk Pay may screen customers, beneficial owners, counterparties and other relevant parties against applicable sanctions information and may conduct additional reviews where a potential match or sanctions-related risk is identified.
Brisk Pay may decline, delay, restrict or prevent a transaction or customer relationship where necessary to comply with applicable sanctions laws, regulatory requirements or internal risk controls.
Where required by law, Brisk Pay may also make reports relating to suspected sanctions evasion or sanctioned property to the relevant authorities.
9. Ongoing Monitoring
Customer verification does not end when an account is opened.
Brisk Pay conducts ongoing monitoring on a risk-sensitive basis to help understand customer activity and identify activity that may require further review.
Monitoring may take into consideration factors such as:
Transaction amounts
Frequency and patterns of activity
Origin and destination of funds
Geographic exposure
Beneficiaries and counterparties
Changes in expected account behaviour
Customer risk profile
Information obtained during onboarding or subsequent reviews
Other indicators relevant to financial crime prevention
The nature and frequency of monitoring may vary according to the level of risk associated with the customer or business relationship.
Higher-risk relationships may be subject to enhanced ongoing monitoring.
10. Transaction Reviews
Certain transactions may require additional compliance review before they can be processed.
Brisk Pay may request further information or documentation where, for example:
The purpose of a transaction requires clarification
Activity differs from the customer’s expected profile
Verification information is incomplete or requires updating
Source of funds requires additional verification
A transaction involves a higher-risk jurisdiction or counterparty
A potential sanctions or compliance concern is identified
Additional regulatory review is required
A transaction may be delayed, rejected, restricted or otherwise prevented where Brisk Pay is unable to complete required due diligence or where processing the transaction would conflict with applicable law, regulatory requirements, our Terms and Conditions or our risk controls.
11. Suspicious Activity
Brisk Pay maintains procedures designed to identify and assess activity that may be unusual or potentially suspicious.
Where the applicable legal threshold is met, Brisk Pay will make reports to FINTRAC or other competent authorities as required by Canadian law.
This may include completed or attempted transactions suspected of being related to:
Money laundering
Terrorist activity financing
Sanctions evasion
Other activity subject to mandatory regulatory reporting
Brisk Pay will not provide customers with information where disclosure would be prohibited by law or could compromise a regulatory review, investigation or financial crime prevention measure.
12. Record Keeping
Brisk Pay maintains records required under applicable Canadian financial crime and regulatory requirements.
Depending on the nature of the relationship or transaction, these may include:
Customer identification information
Business verification information
Beneficial ownership information
Transaction records
Supporting documentation
Compliance-related records
Records required for regulatory reporting
Records are retained for the periods required under applicable law and regulatory requirements and are handled in accordance with relevant privacy and data protection obligations.
13. Keeping Customer Information Up to Date
Brisk Pay may periodically request customers to confirm or update information previously provided.
This may include changes relating to:
Address or contact information
Business activities
Directors
Ownership or beneficial owners
Expected transaction activity
Source of funds
Other information relevant to the customer relationship
Customers must provide accurate and current information and notify Brisk Pay of material changes where required.
Failure to provide information or documentation reasonably required for compliance purposes may result in restrictions being placed on an account or service.
14. Compliance Training
Brisk Pay’s compliance framework includes training appropriate to the responsibilities of personnel involved in relevant areas of the business.
Training is intended to support awareness of applicable AML and financial crime obligations, relevant risks, internal policies and procedures, and the identification and escalation of potentially unusual or suspicious activity.
Training requirements may be updated as regulations, business activities and financial crime risks evolve.
15. Use of Technology and Third-Party Providers
Brisk Pay may use technology and specialist third-party service providers to support elements of its compliance programme.
These services may assist with activities such as:
Identity verification
Business verification
Screening
Transaction monitoring
Fraud prevention
Risk assessment
Regulatory compliance processes
The use of third-party technology or service providers does not remove Brisk Pay’s responsibility to comply with applicable legal and regulatory obligations.
Customer information is handled and shared in accordance with applicable privacy requirements, contractual safeguards and Brisk Pay’s Privacy Policy.
16. Your Responsibilities
Protecting the Brisk Pay platform and the financial system is a shared responsibility.
Customers are expected to:
Provide complete, accurate and truthful information
Provide genuine and valid documentation
Keep customer and business information current
Use Brisk Pay only for lawful purposes
Provide information reasonably requested as part of compliance reviews
Respond promptly to verification requests
Ensure transactions have a legitimate purpose
Protect account credentials and access devices
Notify Brisk Pay promptly of suspected unauthorized access or fraudulent activity
Customers must not use Brisk Pay to conceal the origin, ownership, destination or purpose of funds or to circumvent applicable laws, sanctions, regulatory controls or financial crime prevention measures.
17. Our Right to Take Compliance Action
Brisk Pay may take reasonable action where required to protect the platform, comply with applicable law or manage financial crime risk.
Depending on the circumstances, this may include:
Requesting additional information
Conducting further due diligence
Delaying a transaction while a review is completed
Rejecting a transaction
Restricting particular services
Suspending access to an account
Terminating a customer relationship
Making regulatory or legal reports where required
Where permitted by law, Brisk Pay will communicate with customers regarding information or action required from them.
However, there may be circumstances in which Brisk Pay is legally restricted from providing details regarding a compliance review, regulatory report or related action.
18. Regulatory Information
Brisk Pay Ltd.
Company No. BC1516153
FINTRAC Registered Money Services Business
Registration No. C100000711
Registered Address:
22420 Dewdney Trunk Road, Suite 300
Maple Ridge, BC V2X 3J5
Canada
Email: support@briskpay.ca
For questions relating to verification, compliance reviews or the operation of your Brisk Pay account, please contact us using the details above.
Important Regulatory Notice
Registration as a Money Services Business with FINTRAC confirms that Brisk Pay has satisfied the legal requirements applicable to registration. FINTRAC registration does not constitute licensing, certification or endorsement of Brisk Pay by FINTRAC.
This AML Programme overview is provided for general information about Brisk Pay’s compliance approach. It does not replace Brisk Pay’s Terms and Conditions, Privacy Policy or any applicable legal or regulatory requirements. Brisk Pay may update its compliance policies, procedures and controls from time to time to reflect changes in law, regulation, regulatory guidance, its services or its assessment of financial crime risk.
