A summary of Ardenpay's anti-money laundering and counter-terrorism financing programme.
Ardenovirex Inc., trading as Ardenpay, operates an anti-money laundering and counter-terrorism financing ("AML/CFT") programme designed to comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada), associated regulations, and guidance issued by FINTRAC. We also have regard to the Financial Action Task Force (FATF) recommendations applicable to virtual asset service providers.
This page provides a public summary of the programme. The full policy and supporting procedures are made available to clients during onboarding and to regulators on request.
The programme is owned by our Chief Compliance Officer, who reports to senior management. Compliance has the authority and resources required to discharge its responsibilities, including the authority to decline or suspend client relationships and transactions.
The programme is documented in writing, reviewed periodically, and adjusted to reflect changes in regulation, typology, and our client base. It is subject to independent review on a periodic basis.
We maintain an enterprise risk assessment that considers ML/TF risks associated with our clients, products, services, delivery channels, jurisdictions, and the digital assets we transact in. The risk assessment informs the calibration of our customer due diligence, transaction monitoring, and screening controls.
We apply customer due diligence to every client and conduct enhanced due diligence on higher-risk relationships. Measures include:
Clients, beneficial owners, counterparties, and beneficiaries are screened against major sanctions lists (including OFAC, UN, EU, UK, OSFI) and politically exposed persons databases at onboarding, on an ongoing basis, and prior to each relevant transaction. Positive matches are reviewed and escalated in accordance with our procedures.
We perform risk-based transaction monitoring covering both fiat movements and on-chain activity. Monitoring is calibrated against the established profile of the client and includes both rule-based detection and analyst review. Activity inconsistent with the client's profile or otherwise warranting closer attention is reviewed by compliance.
We implement travel rule requirements applicable to virtual asset transfers, including the collection and transmission of originator and beneficiary information for qualifying transactions, in accordance with applicable Canadian regulation and consistent with FATF Recommendation 16.
We file reports required by law, including reports of suspicious transactions, large cash transactions, large virtual currency transactions, and electronic funds transfers, where applicable thresholds are met. Reports are filed in the prescribed manner and within prescribed timeframes.
We maintain records relating to client identification, transactions, compliance reviews, and reports for the periods required by applicable law and make them available to FINTRAC and other competent authorities on lawful request.
All relevant personnel receive AML/CFT training on appointment and at appropriate intervals thereafter. Training is tailored to role and reflects the typologies and red flags relevant to our business.
Where we rely on third parties to perform elements of customer due diligence, we conduct due diligence on those third parties and remain accountable for the performance of the obligations.
Compliance enquiries, including law enforcement and regulator enquiries, should be directed to our Chief Compliance Officer at compliance@ardenpay.com.
