Legal

Anti-Money Laundering and CFT Policy.

The AML and CFT Policy of Paily (PAILY PAYMENT SYSTEMS INC.) aims to prevent risks of the platform being involved in illegal activities. This policy addresses measures adopted under relevant laws to prevent money laundering, covering crimes related to narcotics, organized crime, terrorism, smuggling, graft, bribery, financial fraud, and breaches of financial regulation.

Last updated
May 7, 2026
Operator
Paily Payment Systems Inc.
FINTRAC MSB
M23824357

Introduction

The AML and CFT Policy of Paily aims to prevent risks of the platform being involved in illegal activities. This policy addresses measures adopted under relevant laws to prevent money laundering activities, covering crimes related to narcotics, organized crime, terrorism, smuggling, graft, bribery, financial fraud, and breaches of financial regulation.

Definitions

Anti-Money Laundering (AML) — laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legal income.

Counter the Financing of Terrorism (CFT) — government laws and regulations designed to restrict funding access for designated terrorist entities.

Client Due Diligence (CDD) — measures to identify and verify client identity and ultimate beneficial owner, gathering business relationship data.

Enhanced Due Diligence (EDD) — additional verification measures applied when clients present higher money laundering or terrorist financing risks.

Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) — Canada’s financial intelligence agency facilitating detection and prevention of ML and TF activities.

Politically Exposed Persons (PEP) — individuals holding significant government positions at national, provincial, or municipal levels.

Risk-Based Approach (RBA) — a method for a company to conduct a risk assessment by analysing business, client, and business relationship elements.

Suspicious Activity — activity raising concerns regarding ML or TF or associated criminal conduct.

Suspicious Transaction Report (STR) — reports submitted to FINTRAC when reasonable suspicion exists regarding transaction involvement in ML or TF offences.

Client Due Diligence (CDD) and Enhanced Due Diligence (EDD)

Paily performs comprehensive client due diligence before establishing business relationships. This includes Know Your Client (KYC) checks verifying identity, information, and submitted documents. Enhanced due diligence measures apply where higher-risk relationships exist, with case-by-case client evaluation.

Ongoing Due Diligence (ODD)

Client due diligence continues throughout the relationship to ensure onboarding documents remain appropriate and relevant, including regular ML and TF risk monitoring and review during significant client changes.

Transaction Monitoring

The company monitors transactions and client behavior to prevent fraud and money laundering, report potential crimes, and mitigate financial crime. Paily pays special attention to ongoing monitoring of transactions and client behavior.

The platform reserves the right to request additional information or documentation. Suspicious transactions and unusual patterns represent additional risk factors and increase the client’s overall risk scoring.

Risk-Based Approach (RBA)

Paily employs RBA to combat money laundering and terrorism financing. Risk profiles are created based on user-provided information, geographic location, associated industries, and public positions. The platform may refuse onboarding without specific justification.

Continuous focus is maintained on client identity and transaction history. Risk level adjustments occur promptly upon detecting irregularities or suspicions.

Sanction Regime and Client Screening

Paily’s sanctions regime meets regulatory requirements. Clients, representatives, and ultimate beneficial owners are screened against sanctions lists before business commencement. Active clients undergo screening every 24 hours against sanctions, adverse media, PEP, and enforcement lists.

AML Compliance Officer

The Compliance Officer supervises all AML and CFT efforts, including:

  • Establishing and updating internal policies and procedures.
  • Collecting and verifying client identification information.
  • Gathering and analyzing unusual transaction information.
  • Reporting suspicions to relevant authorities.
  • Organizing employee training.
  • Regularly updating risk assessments.

The officer is authorized to collaborate with law enforcement agencies.

Suspicious Activity Reporting

Upon discovering suspicious activity, Paily fulfills legal obligations by reporting to appropriate authorities. The platform cooperates with judicial and law enforcement requests, furnishing necessary information per applicable legal requirements.

AML Training

Comprehensive AML and CFT training occurs annually for all employees, supplemented by job-specific guidance. New employees receive pertinent training before commencing roles. Our training program is subject to regular updates to align with the most current laws and regulations.

Record-Keeping

Client information and transaction records are maintained confidentially, shared only with authorized personnel and authorities when necessary. Original or copy documents serving as identification and business relationship basis are retained no less than five years after termination of the business relationship.

Transaction documents and reporting documentation are retained no less than five years after making the transaction or performing the duty to report.

Conclusion

Paily remains dedicated to preventing money laundering through continuous program updates addressing regulatory changes and emerging risks.

Questions about this aml policy?

Contact our compliance team and we will get back within one business day.

aml@norvix.com

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Norvix is operated by Paily Payment Systems Inc., 30 Wertheim Court, Unit 12, Suite 201, Richmond Hill, Ontario L4B 1B9, Canada (Canada Registration No. 1000434725), registered with FINTRAC as a Money Services Business (Registration No. M23824357) and with the Bank of Canada as a Payment Service Provider under the Retail Payment Activities Act. Digital asset and virtual currency services are provided by Paily Payment Systems Inc. under the same FINTRAC registration, which includes virtual currency exchange and transfer designations. Norvix is not a bank. Client money is held in dedicated client accounts at licensed partner institutions, separate from Norvix operating funds. Client funds are not deposits: they earn no interest and are not covered by any deposit-guarantee scheme. Accounts, IBAN issuance and SEPA execution are provided through licensed European partner institutions. Product screens and figures shown on this page are simulated data, for illustration purposes only. Complaints: complaints@norvix.com — the full procedure is published at norvix.com/legal/complaints.

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© 2026 Norvix · Paily Payment Systems Inc., 30 Wertheim Court, Unit 12, Suite 201, Richmond Hill, Ontario L4B 1B9, Canada