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AML / CTF Policy

Commitment to Financial Integrity & Regulatory Compliance

Our Commitment

Highest standards of integrity and compliance

Pinov is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. We actively work to prevent money laundering, terrorist financing, sanctions evasion, fraud, and other financial crimes across all jurisdictions in which we operate.

Pinov operates as:

  • A Money Services Business (MSB) registered with FINTRAC (Canada)
  • A Digital Currency Exchange registered with AUSTRAC (Australia)
  • A payment service provider under Bank of Canada's RPAA oversight

Our compliance framework is built on internationally recognized AML/CTF standards and regulatory requirements.

Regulatory Compliance

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Canada

FINTRAC Registered MSB

  • Proceeds of Crime (PCMLTFA)
  • FINTRAC regulations & directives
  • OSFI sanctions requirements
  • Privacy & data protection laws
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Australia

AUSTRAC Registered DCE

  • AML/CTF Act 2006
  • AML/CTF Rules 2007
  • AUSTRAC supervisory guidance
  • Australian sanctions laws
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Bank of Canada

RPAA Compliance

  • Retail Payment Activities Act
  • Risk management obligations
  • Safeguarding of funds
  • Operational oversight

Where regulatory expectations differ across jurisdictions, Pinov applies the stricter standard.

Risk-Based Approach

Pinov uses a comprehensive risk-based AML/CTF program to identify, assess, and mitigate financial crime risks.

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Customer Due Diligence

KYC verification & identity confirmation

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Beneficial Ownership

Identification for legal entities

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Risk Screening

Sanctions, PEPs & high-risk indicators

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Ongoing Monitoring

Continuous account & transaction review

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Enhanced Due Diligence

For higher-risk customers & geographies

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Compliance Framework

Structured AML/CTF program

Reporting & Cooperation with Authorities

Where required by law, Pinov reports suspicious or legally notifiable activity to the appropriate authorities.

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FINTRAC

Financial Transactions and Reports Analysis Centre of Canada

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AUSTRAC

Australian Transaction Reports and Analysis Centre

Pinov does not disclose the existence of such reports to customers or third parties.

Legal Compliance

In addition to financial intelligence units, Pinov cooperates with:

  • Law enforcement agencies
  • Sanctions authorities
  • Regulatory bodies
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Third-Party & Partner Compliance

All partners, agents, and service providers engaged by Pinov are expected to meet appropriate AML/CTF and sanctions-compliance standards.

Due Diligence Process

  • Comprehensive vendor risk assessments
  • Ongoing reviews and monitoring
  • Contractual compliance obligations
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Privacy & Data Protection

Customer information is handled in accordance with applicable privacy legislation and Pinov's Privacy Policy.

Technical Controls

Advanced encryption and security protocols

Administrative Safeguards

Strict access controls and policies

Security Measures

Comprehensive protection of sensitive data

Commitment to Continuous Improvement

Regular Reviews

Pinov's AML/CTF program is reviewed and updated regularly to reflect regulatory developments

Risk Adaptation

Updated to address emerging financial crime risks and evolving industry best practices

Employee Training

Comprehensive training provided to ensure awareness, accountability, and compliance

Contact — Compliance Enquiries

For compliance-related enquiries, please contact:

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Compliance Office

Pinov — Compliance Office

We are committed to maintaining the highest standards of financial integrity and regulatory compliance across all our operations.

This AML/CTF Policy is reviewed regularly and updated as required by changing regulations and risk assessments.