Anti-Money Laundering (AML) & Combating Terrorist Financing (CFT) Policy
BlueArrow Canada Inc.
15-75 Bayly Street W, Ajax, ON L1S 7K7, Canada
Email: blearrowcanada@gmail.com
Introduction
BlueArrow Canada Inc. is fully committed to complying with applicable Canadian and international laws and regulations regarding Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT). This policy outlines our framework for identifying, preventing, and mitigating the risk of our services being used for illicit purposes such as money laundering or terrorist financing. This policy applies to all employees, customers, contractors, and agents of BlueArrow Canada Inc.
Legal Basis
BlueArrow Canada Inc. operates in accordance with the following legal and regulatory frameworks:
Canada:
Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
Regulations under PCMLTFA<
/div>Guidelines issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
International:
Financial Action Task Force (FATF) Recommendations
Sanctions regimes of the United Nations, European Union, and other relevant global authorities
/div>Risk Assessment
BlueArrow Canada Inc. conducts continuous risk assessments to understand and mitigate risks related to money laundering and terrorist financing. These assessments consider:
Customer profiles
Nature and purpose of business relationships
Geographic risks
Types of transactions and delivery channels
Risk profiles are regularly reviewed to ensure controls remain effective.
Customer Due Diligence (Know Your Customer - KYC)
We implement strict identification and verification procedures before establishing business relationships or conducting certain transactions. KYC procedures include:
Verification of identity using reliable, independent source documents (e.g., government-issued ID)
Collection of proof of address
Collection of beneficial ownership information (for entities)
Enhanced Due Diligence (EDD)
For high-risk customers or transactions, additional scrutiny is applied. EDD measures include:
Collection of additional identification or background information
Frequent monitoring of transactions and activities
Senior management approval for establishing or maintaining the relationship
High-risk indicators include:
Politically exposed persons (PEPs)
Clients from high-risk jurisdictions
Complex or large transactions inconsistent with customer profile
Ongoing Monitoring
Transactions and business relationships are continuously monitored for unusual or suspicious activity. Monitoring includes:
Reviewing patterns of behavior
Investigating deviations from expected activity
Use of automated and manual tools for alerts
Suspicious activities are reported internally and escalated to FINTRAC where required.
Reporting Obligations
BlueArrow Canada Inc. complies with mandatory reporting obligations under Canadian law, including:
Suspicious Transaction Reports (STRs)
Large Cash Transaction Reports (LCTRs)
Electronic Funds Transfer Reports (EFTRs)
Terrorist Property Reports (TPRs)
Reports are filed promptly and accurately through FINTRAC's reporting systems.
Record-Keeping
Records of customer identification, transaction details, and internal reports are maintained for at least five years, in compliance with PCMLTFA regulations. Records are securely stored and accessible for audits or regulatory inspections.
Training and Awareness
All employees receive mandatory AML/CFT training upon hiring and at least annually thereafter. Training includes:
Understanding of AML/CFT laws
How to identify and report suspicious activity
Responsibilities under the compliance program
Compliance Officer
A designated Compliance Officer is responsible for overseeing the implementation and enforcement of this policy. The officer:
Ensures ongoing regulatory compliance
Reviews and updates internal policies and procedures
Acts as the point of contact with FINTRAC and other regulatory bodies
Investigates and escalates suspicious activities
Internal Controls and Audit
Internal controls are in place to ensure effective implementation of this policy. These controls include:
Transaction screening tools
Segregation of duties
Periodic internal audits and reviews
Corrective actions when deficiencies are identified
Non-Retaliation
BlueArrow Canada Inc. encourages employees to report concerns without fear of retaliation. Any employee who, in good faith, raises concerns about suspicious activity or compliance violations will be protected from adverse actions.
Cooperation with Authorities
BlueArrow Canada Inc. fully cooperates with Canadian law enforcement, FINTRAC, and other competent authorities in investigations related to financial crimes.
Policy Updates
This policy is reviewed at least annually, or whenever significant changes in regulation or business operations occur. All updates are communicated to relevant staff and training is provided when necessary.
Restricted Activities
BlueArrow Canada Inc. prohibits any transactions that involve:
Proceeds of criminal activity
Sanctioned individuals or entities
Activities involving firearms, controlled substances, or military-related items
Transactions for political or terrorist purposes
Politically Exposed Persons (PEPs)
BlueArrow Canada Inc. does not accept or maintain business relationships with PEPs, as defined by Canadian law, without enhanced due diligence and senior management approval.
Contact Us
If you have any questions or concerns regarding this policy, please contact us:
BlueArrow Canada Inc.
15-75 Bayly Street W, Ajax, ON L1S 7K7, Canada
Email: blearrowcanada@gmail.com
By using our Services, you acknowledge that you have read, understood, and agreed to be bound by these Terms and Conditions.
General
If any provision of this policy is found to be unlawful, void, or unenforceable, the validity of the remaining provisions shall not be affected. This document constitutes the entire AML/CFT compliance policy of BlueArrow Canada Inc.