AML Policy

SL Virtu ltd., operating as Yoga-pay is committed to maintaining effective prevention and detection measures to assist the

law enforcement authorities in combating financial crime. Yoga-pay adopted a rigorous set of policies and procedures  to meet Yoga-pay's legal obligations under the Canadian, EEA, United Kingdom’s anti-money laundering and counter terrorist legislation.

 

1. Main Objectives

Yoga-pay seeks to ensure at all times that:

a) Clients’ identities are satisfactorily verified in accordance with the firm’s risk based approach before Yoga-pay does business with them

b) Yoga-pay knows its clients and understands their reasons for doing business with us both at the client acceptance stage and throughout the business relationship

c) Our staff are trained and made aware of both their personal legal obligations and the legal obligations of Yoga-pay

d) Our staff is trained to be vigilant for activities where there are reasonable grounds for suspicion that money laundering could be taking place and to make the reports to the Compliance Officer

e) Sufficient records are kept for the required period

f) We establish, maintain and implement appropriate procedures to achieve these objectives

 

2. Law, Regulation and Industry Practice

Yoga-pay is subject to the provisions of the FINTRAC Canada Regulations, including Senior Management Arrangements Systems and Controls sourcebook. The Joint Money Laundering Steering Group guidance 2017 (“JMLSG”) provides practical interpretation of legal and regulatory requirements and indicates good industry practice. Yoga-pay has taken account of the JMLSG when devising a risk-based approach to the prevention of money laundering risk.

 

3. General Principles

a) Anti-Money Laundering Policies

Yoga-pay has implemented policies, procedures and controls aimed at deterring criminals from

using Yoga-pay for the laundering of proceeds of crime. These policies and procedures are

tailored to the risk posed by individual clients, in accordance with the JMLSG.

 

b) Customer Due Diligence (‘CDD’)

Yoga-pay has established Customer Due Diligence procedures to identify the users of its

services and, in relation to higher-risk clients, the principal beneficial owners and origins of funds.

These procedures include knowing the nature of our clients’ businesses and being alert to

abnormal transactions.

 

c) Suspicious Transactions

Unexplained or abnormal transactions or activities that are suspected of being linked to criminal

activity will be reported to the Compliance Officer in writing without delay, who will

determine whether to report the suspicions to FINTRAC.

 

d) Training

All personnel must be informed of their individual and collective responsibilities and Yoga-pay’s

anti- money laundering policies. Personnel are provided with training to enable them to understand

the vulnerabilities of Yoga-pay’s business and to recognize and report suspicious activities.

 

e) Record-Keeping

Yoga-pay keeps records of who has been trained and the timing and form of training sessions.

We retain all records verifying the identity of our clients for at least 5 years following the end of the

business relationship. We also retain the records of any internal reports of suspicion submitted to

the Compliance Officer and any disclosures made to FINTRAC.