Legal — Compliance
AML/CFT Policy Statement
A public summary of Trove Payment Limited's Anti-Money Laundering and Counter-Terrorist Financing programme. Our full internal policy is held confidentially and shared with counterparties and regulators on request during onboarding.
Our commitment
Trove Payment Limited ("Trove", "we") is committed to preventing money laundering, the financing of terrorism, and proliferation financing across every part of our business. As a Money Services Business registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), we maintain a compliance programme designed to meet our obligations under Canadian law and to support the integrity of the corridors we serve. We expect the same standard from every counterparty we work with.
Objectives
- Comply fully with the laws, regulations and reporting obligations that apply to a FINTRAC-registered MSB.
- Prevent Trove's services from being used to launder the proceeds of crime, finance terrorism, or fund the proliferation of weapons.
- Identify, risk-rate and monitor counterparties, and detect and report activity that appears unusual or suspicious to the appropriate authorities.
Regulatory framework
Trove's programme is built on the Canadian regime under which we are registered:
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations.
- FINTRAC guidance, registration requirements and reporting obligations for Money Services Businesses.
- Applicable Canadian sanctions legislation, including measures administered under the United Nations Act and the Special Economic Measures Act.
- Travel Rule obligations governing the transmission of originator and beneficiary information.
Where a transaction touches another jurisdiction, we also have regard to the sanctions and financial-crime requirements applicable in that market.
Programme controls
- GovernanceA designated compliance officer is responsible for the AML/CFT programme, with senior accountability for its effectiveness.
- Know Your Business (KYB) & due diligenceCounterparties are verified at onboarding. Enhanced due diligence is applied to higher-risk relationships, including politically exposed persons; risk-rated review continues through the relationship.
- Sanctions & PEP screeningCounterparties and their controllers are screened against applicable sanctions and politically-exposed-person datasets, at onboarding and on an ongoing basis.
- Transaction monitoringActivity is monitored for patterns inconsistent with a counterparty's expected profile, with escalation and reporting pathways.
- ReportingWe make the statutory and regulatory reports required of a FINTRAC-registered MSB, including suspicious-transaction reporting.
- Training, records & reviewStaff receive periodic compliance training; records are retained as required; and the programme is subject to ongoing and independent review.
Counterparties we do not serve
Trove has no appetite for relationships connected to shell entities, unlicensed money transmission, sanctioned parties or jurisdictions, or businesses we judge to present unacceptable financial-crime risk. We serve licensed payment businesses only, and never retail consumers. Counterparties are screened against these categories at onboarding and on a continuing basis, and we reserve the right to decline or exit any relationship.
Requesting our full policy
This statement is a public summary. Trove's complete AML/CFT programme documentation — including procedures reserved for onboarded counterparties — is shared under NDA during KYB. Compliance teams can request it through our onboarding channel.