Financial Crime Prevention Framework

Protecting Your Business, Safeguarding the Financial System

At Unicorn Currencies, preventing financial crime is not just a regulatory obligation. It is fundamental to who we are and how we operate. We have built a comprehensive, multi-layered Financial Crime Prevention Framework that protects our clients, partners, and the integrity of the global financial system.

This framework combines advanced technology, robust processes, highly trained personnel, and a culture of vigilance to detect and prevent money laundering, terrorist financing, fraud, sanctions violations, and other financial crimes.

Our Commitment to Financial Crime Prevention

Zero Tolerance for Financial Crime

We have zero tolerance for the use of our services for any form of financial crime, including:

• Money laundering and terrorist financing
• Fraud, forgery, and misrepresentation
• Sanctions evasion and trade-based money laundering
• Tax evasion and customs fraud
• Bribery, corruption, and proceeds of crime
• Human trafficking and modern slavery-related transactions

We implement rigorous controls to ensure that criminals cannot exploit our platform, and we work closely with law enforcement and regulatory authorities to combat financial crime.

Regulatory Excellence and Compliance

Our Regulatory Framework

Unicorn Currencies operates under some of the world's most stringent anti-money laundering (AML) and counter-terrorist financing (CTF) regulatory frameworks:

Canada

• FINTRAC Registration: Registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Service Business (MSB) and Payment Service Provider (PSP). Registration No: C100000159
• Compliance with: Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), associated regulations, and FINTRAC guidance
• Oversight: Subject to FINTRAC compliance examinations and regulatory reporting requirements

United Kingdom

• FCA Standards Alignment: Operating in partnership with FCA-authorized Payment Service Providers, we adhere to Financial Conduct Authority standards and UK Money Laundering Regulations 2017
• ICO Registration: Registered with the UK Information Commissioner's Office (ICO Registration No: ZB534346) ensuring data protection compliance in our AML processes

International Standards

• FATF Compliance: Aligned with Financial Action Task Force (FATF) recommendations and international best practices
• Sanctions Compliance: Strict adherence to sanctions programs administered by OFAC (USA), OFSI (UK), UN, EU, and Canadian authorities
• Wolfsberg Principles: Informed by Wolfsberg Group standards for correspondent banking and trade finance AML

The Three Lines of Defense

We employ a Three Lines of Defense model, an internationally recognized framework that ensures multiple, independent layers of control and oversight:

First Line of Defense: Business Operations

Our operational teams are the first line of defense against financial crime.

Responsibilities:

• Client Onboarding: Conducting thorough Know Your Customer (KYC) and Know Your Business (KYB) verification at account opening
• Transaction Screening: Screening every client and transaction against sanctions lists and politically exposed persons (PEP) databases in real-time
• Transaction Monitoring: Monitoring all transactions for suspicious patterns, unusual activity, or red flags
• Customer Due Diligence (CDD): Performing ongoing due diligence and periodic reviews of client relationships
• Enhanced Due Diligence (EDD): Applying enhanced scrutiny to higher-risk clients, jurisdictions, or transaction types

Second Line of Defense: Compliance and Risk Management

Our dedicated Compliance function provides independent oversight, policy development, and specialist expertise.

Responsibilities: Policy and procedures; risk assessment; independent review; suspicious activity analysis; regulatory reporting (STRs/SARs to FINTRAC and NCA); regulatory liaison; quality assurance; advisory support.

Third Line of Defense: Internal Audit

Independent Internal Audit provides assurance that our financial crime controls are effective and operating as designed.

Responsibilities: Periodic audits; testing controls; gap identification; recommendations; management response tracking; reporting to Board Audit Committee.

Governance and Board Oversight

Our Board of Directors provides active oversight of our financial crime prevention program:

• Approves AML/CTF policies and risk appetite
• Reviews quarterly reports on compliance program effectiveness, suspicious activity trends, and regulatory developments
• Ensures adequate resources (budget, staff, technology) are allocated to compliance
• Holds management accountable for compliance performance and regulatory obligations
• Sets the "tone from the top" emphasizing our zero-tolerance culture

Advanced Technology Stack

We leverage cutting-edge technology to detect and prevent financial crime at scale:

Identity Verification

Robust, multi-layer identity verification combining document verification (OCR, forgery detection, 10,000+ document types), biometric verification (facial matching, liveness detection), data verification, and corporate verification for business clients.

Real-Time Sanctions and PEP Screening

Every client, beneficial owner, director, and transaction counterparty is screened in real-time against OFAC, OFSI, UN, EU, Canadian sanctions, and comprehensive global PEP and adverse media databases. Integration with leading screening providers (Dow Jones, Refinitiv World-Check, ComplyAdvantage).

Transaction Monitoring and Behavioral Analytics

Rules-based and machine learning-powered analytics monitoring transaction amounts, frequencies, patterns, beneficiary countries, geographic risk, structured transactions, and behavioral deviations. Alert investigation process with automated triage and continuous learning.

What This Means for You

Protection: Assurance that your business transacts through a platform with rigorous controls; safeguarding against fraud and identity theft; confidence that funds are held at reputable, regulated banking institutions.

Transparency: Clear, upfront communication about our KYC requirements and compliance processes; respectful, professional handling of your information; support from knowledgeable compliance professionals.

Reputation: Partnering with Unicorn Currencies demonstrates your commitment to ethical business practices and compliance; association with a compliant provider enhances your reputation with banks, auditors, and regulators.

What We Ask of You

To maintain the integrity of our platform, we ask that you:

• Provide Accurate Information: Ensure all information provided during onboarding and ongoing relationship is truthful, accurate, and complete
• Respond Promptly: Cooperate with requests for additional information or documentation during due diligence or periodic reviews
• Report Changes: Notify us promptly of any changes to your business structure, ownership, activities, or anticipated transaction patterns
• Transact Legitimately: Use our services only for legitimate business purposes in compliance with all applicable laws
• Be Transparent: Provide clear explanations of transaction purposes, counterparties, and source of funds when requested

Red flags we cannot accommodate: Reluctance to provide KYC documentation; false or misleading information; evasiveness about business activities; requests to circumvent compliance; transaction patterns inconsistent with declared activities; suspected involvement in sanctioned activities or financial crime.

Key Questions