AML POLICY

Ultramarinex is required to comply with the anti-money laundering and countering financing of terrorism (hereinafter AML) legislation using “know your client” (hereinafter KYC) procedures in order to protect your assets and to ensure the compliance with national and international trade standards. We have established internal rules and procedures based on the risk assessment, so the objectives of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) (https://lois-laws.justice.gc.ca/eng/acts/P-24.501/), and other related laws can be achieved.

Our compliance regime includes:

AML Program oversight from the Compliance Officer,

The development and implementation of compliance policies and procedures,

Executing KYC procedures on all customers,

An assessment of our risks as it relates to money laundering and terrorist financing,

Monitor transactions for potentially suspicious and attempted suspicious activities for the purposes of filing Suspicious Transaction Reports (STR),

Maintaining and providing written, ongoing compliance training for our employees to ensure their understanding of their responsibilities under the Proceeds of Crime Act and Regulations in Canada,

A periodic review of our compliance regime to test its effectiveness related to money laundering and terrorist financing every two years.

The objectives that Ultramarinex is trying to achieve, are to:

Detect and deter money laundering and the financing of terrorist activities and to facilitate investigations and prosecution of the related offences,

Maintain and enhance Ultramarinex international reputation by adopting, where appropriate, recommendations and regulations issued by the FINTRAC, and

Keep Client identification, beneficial ownership information, and the purpose and intended nature of the business relationship record up to date,

Re-assess your client’s risk based on their transactions and activities,

Determine whether the transactions or activities are consistent with information and risk assessment of the Client,

Contribute to public confidence in the financial system.

By registering the Account, you are prompted to agree to the following terms:

You warrant that you comply with all applicable anti-money laundering laws and regulations, including but not limited to the AML laws and associated rules and regulations (in force from time to time),

You are not aware and have no reason to suspect that:

the money used to fund your account with us has been or will be derived from or related to any money laundering or other activities deemed illegal under applicable laws or regulations or otherwise prohibited under any international convention or agreement (“illegal activities”), or

The proceeds of your investment will be used to finance illegal activities,

You qualify as a politically exposed person (PEP) in any jurisdiction, or head of international organization (HIOs) or a family member of a PEP/HIO.

You agree to promptly provide us with true and valid information that we reasonably request in order to comply with all applicable laws and regulations relating to anti-money laundering.

You agree that in case you provide false, inaccurate, or misleading information Ultramarinex has the right to discontinue you access to some or all Services as defined in our Terms and Conditions, without prior notification, and take all necessary measures on informing responsible authorities pursuant to the obligations imposed on Ultramarinex by legislation in force. You are obliged to keep us informed without undue delay of all relevant changes to your information provided to us.

Security measures carried out by Ultramarinex in the course of economic activities include:

Transactions or operations carried out to identify a party,

Collection of information necessary to achieve due diligence,

Identification and prevention of fraud, error, or other abuse of Ultramarinex,

Compliance with our legal obligations.

In accordance with the AML Policy, we will conduct initial and ongoing due diligence for each customer according to risk levels and risk categories posed by the Client. The description of risk levels and risk categories is outlined in our risk assessment.

For you this means that in compliance with applicable legislation and the requirements specified by FINTRAC, we will ask for certain minimum identification information from each customer which opens an account; record customer identification information and the verification methods and results; provide notice to customers that we will seek identification information and compare customer identification information with government-provided lists of suspected terrorists.

The minimum required information may include:

Individual’s full name,

Individual's alias (if applicable),

Individual’s nationality,

Individual’s date of birth,

If the person is not the Client, the person's relationship to the customer (if applicable),

Individual's identifier or company identifier or registration number (if applicable),

Individual's full address,

Telephone numbers,

Address or registered office,

The expected origin of the funds to be used within the relationship,

Jurisdiction of issue,

Country of residence,

Occupation of the individual or employee (if self-employed, the nature of the self-employment) (if applicable),

Information that describes the ownership, control and structure of the legal entity, including corporations and trusts (if applicable),

Names of all the directors, as well as the names and addresses of the beneficial owners (persons controlling 25% or more shares) (if applicable),

Names and addresses of all trustees and known beneficiaries and settlors of the trust (if applicable).

In order to verify the abovementioned information, we may require the following documents:

For individuals:

Canadian passport,

Permanent resident card,

Citizenship card (issued prior to 2012),

Secure Certificate of Indian Status,

Driver's licences,

Provincial services cards,

Provincial or territorial identity cards,

Types of card or international document,

Property tax assessment issued by a municipality,

Provincially issued vehicle registration,

Federal, provincial, territorial, or municipal levels,

Utility bill,

Record of Employment,

Registered investment account statements (for example, RRSP, TFSA or RRIF),

Canadian credit file that has been in existence for at least six months,

Product from a Canadian credit bureau or other third party (containing two trade lines in existence for at least six months),

Insurance documents,

Birth certificate,

Marriage certificate or government-issued proof of marriage document (longform which includes date of birth),

Divorce documentation,

Permanent resident card,

Citizenship certificate,

Travel visa.

For legal entities:

Certificate of Incorporation or equivalent indicating field of economic activity,

Certificate of active corporate status,

Articles of incorporation/association,

Record that has to be filed annually under provincial securities legislation or any other record that confirms the corporation's existence, such as the corporation's published annual report signed by an audit firm, or a letter or notice of assessment for the corporation from a municipal, provincial, territorial or federal government,

Shareholder or partnership agreements,

Copy of register of shareholders,

Any other record that confirms its existence as a legal entity (for example, trust agreement)

Certificate of good standing or other proof of registered and operating address (if different) of the company and valid telephone numbers of the company,

Minute book,

Securities register,

Shareholders register,

Annual returns,

Board of director's meeting records of decisions,

Resolution of the board of directors to open an account and confer authority on those who will operate it.

Proof of identity of directors in case they will deal with us on behalf of the Client (according to the Individual identity verification rules described above),

Proof of identity of the beneficial owner(s) and/or the person(s) on whose instructions the signatories on the account are empowered to act (according to the Individual identity verification rules described above), including individual verification of shareholders/beneficial owners with a holding of 25% or more:

Individual shareholders (copy of a passport and a recent original residential utility bill for each),

Corporate shareholders (a complete list of supporting documentation for each company as listed above),

PEP declaration for all directors and beneficial owners,

Financial statements for the last two years, or company bank statements for the last three months.

PLEASE NOTE that abovementioned lists are not exhaustive and additional documents may be required. We always rely on valid and current information and may combine verification methods if necessary. In order to verify the abovementioned data, we may require you to participate in live video chat sessions or asked to take a "selfie" photo using the camera on your mobile phone or electronic device, with application of facial recognition technology to compare the features of that "selfie" to the photo on the authentic government-issued photo identification document.

In case of legal entities you may be required to provide notarized copies of powers of attorney or other authorities given by the directors in relation to the company. The power of attorney given to the representative of a legal participating in the transaction entity must include at least:

details of the authorizer (name of the competent body, location and registry code),

details of the representative (first and last name, personal identification code or date of birth, and place of residence),

date of issue of the document,

the duration of the mandate,

the scope of authorization,

the right of sub-delegation, if granted to the representative.

In some cases, it may be possible to verify the identity of individual using credit file method (e.g., Canadian credit bureau, in existence for at least three years, and matches the provided name, address and date of birth):

be from a Canadian credit bureau (credit files from foreign credit bureaus are not acceptable),

have been in existence for at least three years,

match the name, address, and date of birth that the individual provided.

In order to verify the abovementioned information, we may require submitting the specified documents. The documents should be provided as color scanned copies in resolution not less than 300 pixels per inch (PPI). We may also request you to provide additional information accompanying respective documents. The customer agrees with such requirements of Ultramarinex and agrees to follow them.

If in the course of reviewing and monitoring, we identify unexplainable or unusual patterns or activity, we will work to obtain further information so that these questions are satisfactorily answered. We may also report the activity internally to the Compliance Officer who is required to maintain a record/log of all internally reported and perform a review to determine if a report is to be filed with FINTRAC.

If we cannot reach a clear understanding of the client’s identity, or the sources and movement of funds, it may result in the account being permanently closed. This will be followed by terminating the relationship and de-marketed account owner without the right of re-opening a new account.

Ultramarinex is obliged and has the right without obtaining prior consent to share with financial institutions, authorities and law enforcement agencies any information about the customer, as required by applicable law, and the customer gives Ultramarinex its consent to these actions. In order to comply with this paragraph, Ultramarinex holds information and records about customer’s transactions for at least five years and in such a way that they can be provided to FINTRAC within 30 days of a request to examine them.

There are two situations where we must send a STR to FINTRAC immediately:

Knowing that a property is owned or controlled by or on behalf of a terrorist or terrorist group; and,

Believing that a property is owned or controlled by or on behalf of a listed person.

We are obliged to report any transactions or attempted transactions where there are reasonable grounds to suspect it relates to money laundering or terrorist activity. There is no monetary threshold for submitting a Suspicious Transaction Report (STR).

The Compliance Officer has the authority to file STRs with FINTRAC and is required to maintain a log of all reports filed in accordance with our record keeping procedures.

‘Reasonable grounds to suspect’ captures predicate offences and that tax evasion is also considered a predicate offence for money laundering. Accordingly, if we suspect transactions are being undertaken to avoid or evade paying income taxes, we are obligated to report the transactions as suspicious to FINTRAC.

Where there are economic sanctions, we are required to prohibit or restrict activities in accordance with the legal requirements. In some cases, we may be required to freeze property, in addition to making reports to various government and law agencies.