1. Purpose and Commitment
Bizoso Consulta is dedicated to preventing money laundering and terrorist financing in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and other applicable Canadian laws. This policy establishes a robust framework to detect, deter, and report any activities related to money laundering or terrorism financing while ensuring compliance with both Canadian and international regulations.
2. Scope
This AML Policy applies to all Bizoso Consulta services, employees, consultants, and third-party agents involved in servicing both local and international clients. It governs client onboarding, transaction monitoring, reporting obligations, and staff training to mitigate risks associated with money laundering or terrorist financing.
3. Client Identification and Verification (Know Your Customer - KYC)
Bizoso Consulta employs a rigorous Know Your Customer (KYC) process to verify the identity of all clients:
- Individual Clients:
- Full name, date of birth, and contact information are collected.
- Government-issued photo identification (e.g., passport, driver’s license, or national ID) and proof of address (e.g., utility bill or bank statement) are required.
- Corporate Clients:
- Company registration documents, business license, and proof of ownership are required.
- Ultimate Beneficial Owners (UBOs) owning 25% or more of the entity must be identified and verified.
- International Clients:
- Additional due diligence is conducted for clients from high-risk jurisdictions or politically exposed persons (PEPs).
- Screening is performed against global sanctions and watchlists.
Bizoso Consulta reserves the right to refuse services if adequate identification is not provided or if the client poses a significant risk.
4. Enhanced Due Diligence (EDD)
For high-risk clients, the following measures are implemented:
- Verification of the source of funds or wealth.
- Additional identification documentation or references.
- Ongoing monitoring of transactions for suspicious activity.
- Regular reviews of the client’s risk profile.
5. Transaction Monitoring
Bizoso Consulta monitors all client transactions to identify and report unusual or suspicious activities:
- Unusual Transactions: Transactions that deviate from a client’s usual activity are flagged for review.
- High-Value Transactions: Transactions exceeding CAD 10,000 are closely scrutinized.
- Cash Transactions: Large cash transactions are discouraged and, if conducted, must comply with reporting requirements.
- International Transactions: Cross-border transfers, especially to or from high-risk jurisdictions, are monitored for compliance with Canadian regulations.
6. Suspicious Transaction Reporting
Bizoso Consulta is committed to meeting its reporting obligations under Canadian law:
- Suspicious Transaction Reports (STRs): If a transaction appears suspicious or inconsistent with the client’s profile, it is reported to FINTRAC immediately.
- Large Cash Transaction Reports (LCTRs): Any cash transaction or series of transactions over CAD 10,000 is reported to FINTRAC.
- Reports are filed promptly and in strict confidentiality, without informing the client of the reporting process.
7. Record Keeping
Bizoso Consulta ensures that all records related to KYC, transactions, and reporting are maintained in compliance with the PCMLTFA:
- Retention Period: All records are kept for at least five years after the completion of the client relationship or transaction.
- Data Security: Client data is stored securely, with access restricted to authorized personnel.
- Documentation: Records include copies of identification, account activity, transaction history, and risk assessments.
8. Employee Training and Awareness
- Mandatory Training: All employees and consultants undergo comprehensive AML training upon hiring and annually thereafter. Training includes recognizing red flags, KYC procedures, and reporting obligations.
- Ongoing Updates: Employees are regularly updated on changes to Canadian AML regulations and industry best practices.
- Testing and Certification: Employees are tested to ensure understanding and compliance with AML protocols.
9. Compliance Officer
A designated Compliance Officer is responsible for overseeing all AML activities, ensuring regulatory compliance, and acting as the primary point of contact with FINTRAC and other regulatory authorities. Responsibilities include:
- Developing and updating the AML policy.
- Monitoring compliance with AML procedures.
- Investigating and reporting suspicious transactions.
- Conducting regular audits of AML processes.
10. Risk Assessment
Bizoso Consulta conducts regular risk assessments to evaluate and mitigate vulnerabilities related to money laundering and terrorist financing:
- Client Risk: Each client is categorized as low, medium, or high risk based on their profile and transaction history.
- Geographic Risk: Clients from high-risk jurisdictions are subject to enhanced due diligence.
- Service Risk: High-risk services, such as cross-border payments, are closely monitored.
The risk assessment is reviewed annually to ensure it reflects changes in business operations or regulatory requirements.
11. Policy Review and Updates
This AML Policy is reviewed annually or as required by changes in Canadian AML regulations or international best practices. Updates are communicated to all employees and implemented promptly.
12. Non-Compliance and Penalties
Failure to comply with this AML Policy may result in disciplinary action, including termination of employment or client relationships. Bizoso Consulta will cooperate fully with regulatory authorities in cases of suspected money laundering or non-compliance.
13. Client Awareness
Bizoso Consulta informs clients of its AML obligations and reserves the right to:
- Request additional information or documentation at any time.
- Refuse or terminate services if AML compliance cannot be ensured.
By implementing this AML Policy, Bizoso Consulta demonstrates its commitment to ethical business practices, regulatory compliance, and the protection of its clients and stakeholders.