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AML / CFT Policy (summary)

Last updated: March 2026

This summary describes the key elements of the Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) programme maintained by Capitolio Inc. The full policy is available to clients upon request.

1. Company Overview

CAPITOLIO INC. is registered as a Money Services Business (MSB) with FINTRAC (registration number M24928320) and is subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and applicable FINTRAC guidelines.

Our services include: virtual currency exchange (fiat-to-crypto, crypto-to-fiat), virtual currency transfer, and money transfers.

Registered address: 700-602 12 Ave SW, Calgary, Alberta, T2R 1J3, Canada

Compliance contact: [email protected]

2. Compliance Officer

Capitolio has designated a qualified Compliance Officer (Money Laundering Reporting Officer) responsible for:

  • overseeing the AML/CFT programme;
  • reviewing and updating policies and procedures;
  • managing FINTRAC reporting obligations; and
  • providing AML/CFT training to staff.

3. Risk-Based Approach

We apply a risk-based approach to AML/CFT compliance. Customers are assessed for risk based on factors including jurisdiction, transaction size, customer type, and source of funds. Enhanced due diligence is applied to higher-risk customers.

4. Customer Identification and Verification (KYC)

We verify the identity of customers in accordance with FINTRAC guidelines and our Customer Identification Programme (CIP). Key elements include:

  • Identification of all customers above FINTRAC reporting thresholds (generally CAD 1,000 for virtual currency transactions and CAD 3,000 for certain other transactions);
  • Verification using government-issued identity documents;
  • Liveness check (biometric verification via SumSub);
  • Collection of proof of address for higher-tier customers;
  • Source of funds documentation for high-value or higher-risk transactions; and
  • Enhanced due diligence for Politically Exposed Persons (PEPs), High-Risk Third Countries, and customers transacting above CAD 450,000.

5. Ongoing Monitoring

We conduct ongoing monitoring of business relationships and transactions, including:

  • transaction monitoring against customer risk profiles;
  • blockchain analytics and virtual currency transaction screening;
  • periodic review of customer information; and
  • monitoring for changes in customer risk profile.

6. Sanctions Screening

All customers and transactions are screened against applicable sanctions lists, including:

  • UN Security Council Consolidated List;
  • OSFI Consolidated Sanctions List (Canada);
  • EU Consolidated Financial Sanctions List; and
  • PEP databases.

Transactions involving sanctioned individuals, entities, or jurisdictions are blocked and reported as required by law.

7. FINTRAC Reporting

We comply with all mandatory FINTRAC reporting obligations, including:

  • Large Cash Transaction Reports (LCTR) — cash transactions of CAD 10,000 or more;
  • Large Virtual Currency Transaction Reports (LVCTR) — virtual currency transactions of CAD 10,000 or more;
  • Suspicious Transaction Reports (STR) — transactions suspected of being related to money laundering or terrorist financing;
  • Terrorist Property Reports (TPR) — property owned or controlled by a terrorist; and
  • Electronic Funds Transfer Reports (EFTR) — international EFTs of CAD 10,000 or more.

8. Record Keeping

We maintain records in accordance with PCMLTFA requirements, including customer identification records, transaction records, and business relationship records, for a minimum of five years.

9. Training

All staff involved in customer-facing or compliance functions receive AML/CFT training at onboarding and at least annually thereafter.

10. Prohibited Jurisdictions

We do not provide services to customers in jurisdictions subject to comprehensive sanctions or identified as high-risk by FINTRAC/FATF. A full list of prohibited jurisdictions is maintained internally and reviewed regularly.

11. Policy Review

This policy and summary are reviewed at least annually and updated as required to reflect changes in applicable law, FINTRAC guidance, or business activities. Last reviewed: March 2026.

Company
Registered in Canada
CSSF registration number: B00000408
RCS number: B222310
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Investing in cryptoassets involves significant risk. You should not invest more than you can afford to lose, and you should ensure that you fully understand the risks involved. We are not regulated by the Financial Conduct Authority and investments in cryptoassets are not covered by the Financial Ombudsman Service or subject to protection under the Financial Services Compensation Scheme.

Regulatory Status

Capitolio Inc. is incorporated in Alberta, Canada and operates as a registered Money Services Business (MSB) in accordance with Canadian federal law. FINTRAC registration number: M24928320. Registered address: 700-602 12 Ave SW, Calgary, Alberta, T2R 1J3, Canada.

AML/CFT Compliance

We operate under a comprehensive AML/CFT compliance programme, including: customer identification and verification (KYC) for all users; ongoing monitoring of transactions and business relationships; screening against sanctions lists and PEP databases; and suspicious activity reporting to FINTRAC as required by the PCMLTFA.

High-Risk Crypto Asset Warning

Transactions involving virtual currencies carry a high risk of financial loss, including the possible loss of the entire amount. The value of virtual currencies is highly volatile. Past performance is not indicative of future results. Before using our services, please read our Risk Disclosure Statement.

Supervision Disclaimer

Unless explicitly stated otherwise, Capitolio Inc. is not a bank, payment institution, or investment firm and does not provide investment services within the meaning of applicable Canadian financial regulations. Capitolio is not subject to prudential supervision in the same way as traditional financial institutions.
Risk Disclosure

© 2026 Capitolio. LTD. All rights reserved. Information on this website is of a general nature and does not constitute investment advice, legal advice, tax advice or an offer of financial instruments. Transactions in crypto-assets involve a high level of risk. Please read our Risk Disclosure and Terms & Conditions carefully before using our services.

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