Sparroz Group LTD is committed to preventing its products, services and infrastructure from being used for money laundering, terrorist activity financing, sanctions evasion, fraud or other financial crime.
We maintain a risk-based Anti-Money Laundering and Anti-Terrorist Financing compliance program designed to support compliance with applicable Canadian legal and regulatory requirements.
This public policy applies to Sparroz Group LTD and to customers, applicants and other persons using or seeking to use our services. Detailed internal controls, procedures, risk methodologies and reporting processes are maintained separately and are not publicly disclosed.
We assess financial-crime risk using factors that may include:
Before providing services, and during a business relationship, we may obtain and verify information concerning a customer’s identity, address, occupation, business activities, ownership, control structure and intended use of our services.
For business customers, we may also request information concerning legal existence, directors, authorized representatives, shareholders, beneficial owners, business model, expected activity, source of funds and purpose of the relationship.
Enhanced due diligence may be applied where a customer, relationship or transaction presents a higher level of risk. Measures may include additional identity or corporate documents, source-of-funds or source-of-wealth evidence, transaction support, adverse-media checks, senior compliance approval, limits and increased monitoring.
We may monitor customer relationships and transactions to assess whether activity is consistent with available customer information, the stated purpose of the relationship and the expected transaction profile. Monitoring may include automated and manual controls and may result in requests for additional information or documents.
Where required by law, Sparroz Group LTD may submit reports or information to FINTRAC, law-enforcement authorities or other competent government bodies. We may be prohibited from informing a customer that a report has been submitted or that a review or investigation is taking place.
We retain records required by applicable law and internal policy, which may include identification records, business and beneficial ownership records, transaction records, supporting documents, risk assessments and compliance-review records.
We may delay, reject, suspend or otherwise restrict a transaction or service where required by law, where information is incomplete or inconsistent, where verification cannot be completed, where fraud or financial-crime concerns arise, or where additional review is reasonably required.
Relevant personnel receive compliance training appropriate to their responsibilities. The compliance program is overseen by a designated compliance function and is subject to periodic testing and review.
Questions about this policy may be sent to compliance@sparroz.io.
