Financial Crime Prevention Framework
Last Updated: December 1, 2025
Protecting Your Business, Safeguarding the Financial System
At Unicorn Currencies, preventing financial crime is not just a regulatory obligation—it's 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
Independent Verification
Our compliance program is:
Audited annually by independent external auditors
Subject to regulatory examination by FINTRAC and oversight through our FCA-authorized partners
Tested through regular internal audits and compliance reviews
Benchmarked against industry best practices and peer institutions
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
Frontline Detection: Identifying and escalating suspicious activity indicators during daily client interactions
Empowerment and Training:
All frontline staff receive comprehensive AML/CTF training upon hire and annually thereafter
Staff are empowered and expected to challenge unusual requests or activity
Clear escalation procedures ensure concerns reach compliance specialists quickly
Second Line of Defense: Compliance and Risk Management
Our dedicated Compliance function provides independent oversight, policy development, and specialist expertise.
Responsibilities:
Policy and Procedures: Developing and maintaining comprehensive AML/CTF policies, procedures, and controls
Risk Assessment: Conducting enterprise-wide money laundering and terrorist financing risk assessments
Independent Review: Reviewing and challenging decisions made by the first line, including KYC approvals and transaction decisions
Suspicious Activity Analysis: Investigating alerts and unusual activity flagged by frontline staff or monitoring systems
Regulatory Reporting: Preparing and filing Suspicious Transaction Reports (STRs) / Suspicious Activity Reports (SARs) to FINTRAC and the National Crime Agency (UK)
Regulatory Liaison: Serving as primary point of contact with FINTRAC, FCA partners, and law enforcement
Quality Assurance: Conducting quality assurance reviews of KYC files, transaction decisions, and compliance processes
Advisory Support: Providing guidance and training to business teams on complex compliance scenarios
Independence and Authority:
The Head of Compliance reports directly to the Chief Operating Officer and has direct access to the Board of Directors
Compliance has authority to block transactions, suspend accounts, or terminate relationships where financial crime risk is identified
Compliance is independent from sales and revenue-generating functions, ensuring objective decision-making
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: Conducting annual audits of AML/CTF compliance program effectiveness
Testing Controls: Testing key controls including KYC procedures, transaction monitoring, sanctions screening, and suspicious activity reporting
Gap Identification: Identifying weaknesses, gaps, or areas for improvement in the compliance framework
Recommendations: Providing actionable recommendations to strengthen controls and mitigate risks
Management Response: Tracking management's implementation of corrective actions
Reporting to Board: Reporting audit findings, control effectiveness, and risk issues directly to the Board Audit Committee
Independence:
Internal Audit operates independently from both business operations and compliance
Internal Audit reports directly to the Board Audit Committee, ensuring objective oversight
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, ensuring comprehensive coverage while minimizing friction for legitimate clients.
Identity Verification - Verify365 Platform
Robust, Multi-Layer Identity Verification
Our identity verification process, powered by leading providers integrated into our Verify365 platform, combines:
Document Verification:
Advanced optical character recognition (OCR) and machine learning to extract and verify data from government-issued identity documents (passports, driver's licenses, national ID cards)
Forgery detection algorithms identifying tampered, altered, or counterfeit documents
Real-time verification against issuing authority databases where available
Support for 10,000+ document types from 195+ countries
Biometric Verification:
Facial biometric matching comparing live selfies to photo ID documents
Liveness detection preventing use of photos, videos, or deepfakes
Advanced anti-spoofing technology ensuring genuine identity verification
Data Verification:
Cross-referencing identity information against global data sources, credit bureaus, and public records
Address verification through utility bills, bank statements, and official correspondence
Phone and email verification to confirm contact details
Corporate Verification (for business clients):
Company registry searches confirming legal existence, registration number, and registered address
Beneficial ownership identification through corporate registries and ultimate beneficial owner (UBO) databases
Director and officer verification ensuring authorized signatories are legitimate
Business activity verification through websites, social media, and trade references
Outcome: Comprehensive identity assurance before any client can access our services, preventing identity fraud, synthetic identities, and criminal exploitation.
Real-Time Sanctions and PEP Screening
Continuous Screening Against Global Watch Lists
Every client, beneficial owner, director, and transaction counterparty is screened in real-time against:
Sanctions Lists:
Office of Foreign Assets Control (OFAC) - USA
Office of Financial Sanctions Implementation (OFSI) - UK
United Nations Security Council Consolidated List
European Union Sanctions
Canadian sanctions administered by Global Affairs Canada
Additional country-specific sanctions programs
Politically Exposed Persons (PEPs):
Comprehensive global PEP databases covering heads of state, government ministers, senior officials, judges, military leaders, and state-owned enterprise executives
Family members and close associates of PEPs
PEP status triggers enhanced due diligence and ongoing monitoring
Adverse Media and Watch Lists:
Criminal records and law enforcement databases
Financial crime allegations and convictions
Terrorism, human trafficking, and organized crime affiliations
Regulatory enforcement actions and sanctions violations
Reputation risk indicators
Technology:
Integration with leading screening providers (Dow Jones Risk & Compliance, Refinitiv World-Check, ComplyAdvantage)
Real-time screening at onboarding and ongoing periodic rescreening (at least annually, or more frequently for higher-risk clients)
Automated alerts for match hits, with expert review and disposition by trained compliance analysts
False positive reduction through fuzzy matching algorithms and intelligent filtering
Outcome: Criminals, terrorists, sanctioned entities, and high-risk individuals are blocked from using our platform, ensuring compliance with global sanctions regimes and preventing reputational risk.
Transaction Monitoring and Behavioral Analytics
Sophisticated Monitoring Detecting Suspicious Patterns
Every transaction processed through Unicorn Currencies is monitored using advanced rules-based and machine learning-powered analytics:
What We Monitor:
Transaction amounts, frequencies, and patterns
Beneficiary countries, banks, and counterparties
Payment purposes and descriptions
Client business profiles and expected activity
Geographic risk factors and high-risk jurisdictions
Structured transactions (layering, splitting to avoid thresholds)
Rapid movement of funds or circular transactions
Inconsistencies between declared business activity and actual transactions
Detection Capabilities:
Rule-Based Alerts: Pre-configured rules detecting known typologies of money laundering, trade-based money laundering, terrorist financing, and fraud
Behavioral Analytics: Machine learning models establishing normal behavior baselines for each client and flagging deviations
Network Analysis: Graph analytics identifying relationships between clients, beneficiaries, and transactions that may indicate layered schemes or organized crime
Velocity Checks: Monitoring transaction velocity and cumulative amounts over time periods
Geographic Risk Scoring: Enhanced scrutiny for transactions involving high-risk jurisdictions (FATF grey/blacklist countries, offshore financial centers, conflict zones)
Alert Investigation Process:
Automated Triage: Alerts prioritized by risk score and assigned to compliance analysts
Investigation: Analysts review transaction details, client profile, historical activity, supporting documentation, and external intelligence
Risk Assessment: Determination whether activity is consistent with legitimate business or indicative of financial crime
Disposition: Alerts closed with documentation (legitimate activity) or escalated for suspicious activity reporting
Continuous Learning: Alert outcomes feed back into monitoring rules and machine learning models, improving detection accuracy over time
Technology Partners:
Proprietary transaction monitoring systems calibrated to our business model and risk profile
Integration with leading AML technology providers for advanced analytics
Continuous system tuning and threshold calibration to optimize detection while minimizing false positives
Outcome: Suspicious activity is detected early, investigated thoroughly, and reported to authorities where appropriate, preventing criminals from successfully laundering proceeds through our platform.
Holistic Risk Assessment
Every Client Has a Risk Rating
We assign comprehensive risk ratings to every client based on multiple factors:
Risk Factors Considered:
Client type: Individual, sole proprietor, SME, large corporation, trust, partnership
Ownership structure: Transparency of beneficial ownership, complex structures, use of nominees
Business model: Industry sector, products/services offered, customer base
Geographic exposure: Countries of operation, transaction destinations, supply chain locations
Transaction profile: Expected volumes, amounts, frequencies, currencies, counterparties
Source of funds: Clarity and legitimacy of wealth and income sources
Regulatory status: Licensed businesses, regulatory oversight, compliance history
PEP status: Whether client or beneficial owners are politically exposed persons
Adverse information: Any negative news, regulatory actions, or reputational concerns
Risk Rating Scale:
Low Risk: Well-established businesses in low-risk sectors and jurisdictions with transparent ownership and straightforward transaction needs
Medium Risk: Most commercial clients with standard business models, clear ownership, and moderate complexity
High Risk: Clients with elevated risk factors requiring enhanced due diligence, frequent reviews, and transaction monitoring
Prohibited: Certain high-risk categories (e.g., cryptocurrency exchanges, arms dealers, shell companies without substance) may be declined
Risk-Based Approach:
Higher-risk clients receive more intensive scrutiny (enhanced due diligence, senior management approval, frequent reviews, lower alert thresholds)
Lower-risk clients receive streamlined processes while maintaining essential controls
Risk ratings are dynamic—reviewed periodically and adjusted based on changes in client circumstances or transaction behavior
Robust Processes and Controls
Know Your Customer (KYC) and Know Your Business (KYB)
Comprehensive Client Verification Before Any Service Delivery
No client can transact through Unicorn Currencies without completing our rigorous KYC/KYB process:
For Individuals and Sole Proprietors:
Government-issued photo identification (passport, driver's license, national ID)
Proof of residential address (utility bill, bank statement, tax document dated within 3 months)
Source of funds and source of wealth declaration and verification
Screening against sanctions, PEPs, and adverse media
Risk assessment and risk rating assignment
For Corporations and Partnerships:
Corporate registry documentation (certificate of incorporation, articles, registry extract)
Proof of registered address
Corporate structure chart and beneficial ownership information (identifying all individuals owning 25%+ and ultimate controlling persons)
Verification of directors, officers, and authorized signatories
Business activity documentation (business plan, website, client references, financial statements)
Screening of the entity and all beneficial owners, directors, and signatories
Risk assessment and risk rating
For Complex Structures (trusts, foundations, SPVs):
Full transparency of structure, beneficial ownership, and control
Source of assets and purpose of structure
Enhanced due diligence and senior management approval
Ongoing Due Diligence:
Periodic reviews of client information (at least annually for higher-risk clients, every 3 years for lower-risk)
Triggered reviews when client circumstances change (change of ownership, business model, transaction patterns)
Continuous transaction monitoring and sanctions screening
Enhanced Due Diligence (EDD)
Certain clients and situations trigger Enhanced Due Diligence, requiring additional information, verification, and approval:
EDD Triggers:
Politically Exposed Persons (PEPs) and their family members or close associates
High-risk jurisdictions (FATF-identified high-risk countries, offshore financial centers with weak AML controls, conflict zones)
High-risk business sectors (money service businesses, virtual asset service providers, cash-intensive businesses, charities with international operations)
Complex ownership structures lacking transparency
Large transaction volumes or unusually complex transaction patterns
Adverse media or reputational concerns
Prior relationship termination or sanctions screening hits (false positives requiring careful review)
EDD Requirements:
Additional source of funds/wealth documentation and verification (bank statements, tax returns, business contracts, audited financials)
Independent verification through third-party sources (corporate registries, news databases, business intelligence)
Senior management approval for account opening
More frequent periodic reviews (semi-annual or quarterly)
Lower alert thresholds in transaction monitoring
Executive-level relationship oversight
Suspicious Activity Reporting
When We Identify Suspicious Activity, We Report It
Where our monitoring, investigations, or frontline observations identify transactions or patterns that give rise to reasonable grounds to suspect money laundering, terrorist financing, or other financial crime, we are legally obligated to report to:
FINTRAC (Canada): Suspicious Transaction Reports (STRs)
National Crime Agency (NCA) (UK, through FCA-authorized partners): Suspicious Activity Reports (SARs)
Important Legal Protections:
We are legally prohibited from informing clients that a suspicious activity report has been filed (this is called "tipping off" and is a criminal offense)
Clients should be aware that any unusual, inconsistent, or high-risk activity may be reported to financial intelligence authorities
Reporting suspicious activity does not mean a client is guilty of a crime—it means we have identified patterns requiring expert law enforcement review
We take our reporting obligations seriously and cooperate fully with law enforcement and regulatory authorities in their investigations.
Record Keeping and Data Retention
Comprehensive Records Maintained for Regulatory and Investigative Purposes
We maintain detailed records of all client information, transactions, and compliance activities for a minimum of seven (7) years from the date of account closure or last transaction, in accordance with:
Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada) - Section 6
Money Laundering Regulations 2017 (UK) - Regulation 40
FINTRAC Guidance on record-keeping requirements
FCA Handbook requirements for transaction records
Records Retained:
Client identification and verification documents
Beneficial ownership information
Business activity documentation
Transaction records (dates, amounts, currencies, counterparties, purposes)
Correspondence and communications
Risk assessments and due diligence reports
Sanctions screening results
Transaction monitoring alerts and investigation outcomes
Suspicious activity reports (internal documentation; actual reports filed with FINTRAC/NCA are maintained by those authorities)
Training records and compliance program documentation
Purpose of Retention:
Regulatory Compliance: Meeting legal record-keeping obligations
Regulatory Examinations: Providing records to FINTRAC, FCA, or other authorities during compliance examinations
Law Enforcement: Supporting criminal investigations, prosecutions, and asset recovery proceedings
Audit Trail: Demonstrating due diligence, compliance with policies, and reasonableness of decisions
Litigation and Dispute Resolution: Defending against claims or resolving disputes
Security and Confidentiality:
All records stored securely with encryption at rest and in transit
Access restricted to authorized compliance, legal, and audit personnel on a need-to-know basis
Records protected against unauthorized access, loss, or destruction
Confidentiality maintained in accordance with Privacy Policy and data protection laws
Training and Culture
Comprehensive Staff Training
Every employee is trained to recognize and prevent financial crime:
Induction Training: All new employees complete comprehensive AML/CTF training within 30 days of hire, covering money laundering typologies, red flags, sanctions compliance, and reporting obligations
Annual Refresher Training: All staff complete annual refresher training on emerging threats, regulatory updates, and lessons learned
Role-Specific Training: Frontline staff (sales, operations, customer service) receive enhanced training on recognizing suspicious activity in client interactions
Compliance Specialist Training: Compliance team members receive advanced training on investigation techniques, regulatory requirements, and typologies
Testing and Certification: Training effectiveness measured through assessments and knowledge tests
Culture of Vigilance
Financial crime prevention is embedded in our culture:
Tone from the Top: Senior leadership and the Board set clear expectations that compliance is non-negotiable and financial crime will not be tolerated
Speak Up Culture: Employees are encouraged and empowered to raise concerns without fear of retaliation; whistleblower protections ensure safe reporting channels
No Pressure to Compromise: Employees are never pressured to onboard risky clients, overlook red flags, or compromise compliance for revenue targets
Recognition and Accountability: Employees who demonstrate vigilance and prevent financial crime are recognized; those who fail to follow policies face disciplinary action
Continuous Learning: We share case studies, typologies, and regulatory updates regularly to keep the team informed and alert
What This Means for You
Security and Peace of Mind
Our comprehensive Financial Crime Prevention Framework provides you with:
Protection:
Assurance that your business is transacting through a platform with rigorous controls, reducing your own risk of unwitting involvement in financial crime
Safeguarding against fraud and identity theft through robust verification processes
Confidence that your funds are held at reputable, regulated banking institutions with strong AML controls
Transparency:
Clear, upfront communication about our KYC requirements and compliance processes
Respectful, professional handling of your information with strong data protection safeguards
Support from knowledgeable compliance professionals when you have questions
Reputation:
Partnering with Unicorn Currencies demonstrates your commitment to ethical business practices and compliance
Association with a compliant, well-controlled financial services provider enhances your own 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 or refusal to provide required KYC documentation
Provision of false, misleading, or fraudulent information
Unusual evasiveness about business activities, ownership, or transaction purposes
Requests to circumvent compliance procedures or "expedite" verification
Transaction patterns inconsistent with declared business activities
Suspected involvement in sanctioned activities, money laundering, fraud, or other financial crimes
If we identify such red flags, we may decline to onboard, suspend services, or terminate the relationship in accordance with our risk-based approach and regulatory obligations.
Regulatory Transparency and Reporting
Our Regulatory Standing
FINTRAC Registration: Current, active registration with no compliance examinations resulting in material findings or enforcement actions
Clean Regulatory Record: No fines, sanctions, or public enforcement actions related to AML/CTF compliance
Proactive Engagement: Regular dialogue with regulators, participation in industry consultations, and commitment to continuous improvement
Independent Assurance
External Audits: Annual independent audits of AML/CTF compliance program by qualified external auditors
Audit Reports: Audit results reviewed by Board Audit Committee; material findings addressed through management action plans
Regulatory Examinations: Cooperation with FINTRAC compliance examinations and FCA oversight (through authorized partners), with findings addressed promptly
Continuous Improvement
Evolving Threats, Evolving Defenses
Financial crime is constantly evolving. So are we.
Threat Intelligence: Continuous monitoring of emerging money laundering typologies, terrorist financing methods, and fraud schemes through regulatory alerts, law enforcement bulletins, and industry intelligence sharing
Technology Investment: Ongoing investment in advanced AML technology, artificial intelligence, and machine learning to stay ahead of criminal innovation
Regulatory Engagement: Active participation in regulatory consultations, industry working groups, and public-private partnerships combating financial crime
Benchmarking: Regular benchmarking against peer institutions and international best practices
Lessons Learned: Post-incident reviews of any compliance failures, near-misses, or regulatory feedback to strengthen controls
Industry Collaboration
We collaborate with industry partners, law enforcement, and regulatory authorities to combat financial crime collectively:
Information Sharing: Participation in financial intelligence sharing initiatives (subject to legal frameworks)
Public-Private Partnerships: Engagement with Joint Money Laundering Intelligence Taskforce (JMLIT) and similar initiatives
Industry Associations: Membership in fintech and payments industry associations sharing AML best practices
Regulatory Dialogue: Open communication with FINTRAC, FCA, and law enforcement on emerging threats and effective controls
Contact Information
Compliance Inquiries
For questions about our compliance processes or to report concerns:
Compliance Officer / Head of Compliance
Email: compliance@unicorncurrencies.com
UK Phone: +44 (20) 8064-0818
Canada Phone: +1 (548) 488-0818
Suspicious Activity Reporting
If you suspect financial crime involving our services, please contact us immediately. Your vigilance helps protect the integrity of the financial system.
Related Policies
Anti-Bribery and Corruption Policy: www.unicorncurrencies.com/abc-policy
Modern Slavery Statement: www.unicorncurrencies.com/modern-slavery-statement
Privacy Policy: www.unicorncurrencies.com/privacy
Whistleblower Policy: www.unicorncurrencies.com/whistleblower-policy
Safeguarding Policy: www.unicorncurrencies.com/safeguarding
Our Financial Crime Prevention Framework is designed to be robust, effective, and proportionate—protecting legitimate businesses while denying criminals access to the financial system. We are proud to partner with clients who share our commitment to integrity, transparency, and compliance.
© 2025 Unicorn Currencies. All rights reserved.