AML Policy

Last Update: December 2, 2025

Dream Finance Processing Inc., an Alberta corporation formerly incorporated in Ontario as 1000987855 Ontario Inc. (“Dream Finance” or the “Company”), maintains zero tolerance for money laundering, terrorist financing, or any other form of illicit activity. The Company is committed to implementing and enforcing policies, procedures, and internal controls that reflect industry best practices and comply with all applicable Canadian laws and regulations, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated regulations administered by FINTRAC. These standards apply without exception to all Company employees, officers, directors, contractors, consultants, and any other individuals acting on behalf of the Company.

The purpose of this document is to provide the Company’s clients, partners, vendors, contractors, employees, regulators, law enforcement agencies, and other relevant stakeholders with a high-level overview of the core elements of Dream Finance’s Anti-Money Laundering and Anti-Terrorist Financing (AML/ATF) compliance program. This document is not intended to serve as a complete compilation of all internal policies, procedures, or controls implemented by the Company to prevent money laundering, terrorist financing, or related illicit activities.

Dream Finance, prepares this document and all related policies, processes, and procedures in accordance with:

the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated regulations, as amended from time to time;
all applicable guidance and directives issued by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC); and
the FATF Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers.

Dream Finance under Canadian federal law maintains registration as a Money Services Business (MSB) as required for entities providing virtual currency exchange, transfer, or related services. Canada was among the early adopters of comprehensive AML and anti-terrorist financing requirements for virtual asset activities. Accordingly, all MSBs conducting such activities must meet FINTRAC obligations related to reporting, recordkeeping, Know Your Client (KYC) measures, risk assessment, and compliance program oversight.

Dream Finance as a Money Services Business (MSB) authorized to provide services involving the dealing in virtual currency, including virtual currency exchange and transfer services, in accordance with the PCMLTFA and its associated regulations. MSB registration status may be verified through the official FINTRAC MSB registry.

As a regulated business, the Company is required to comply with the PCMLTFA, associated regulations, and applicable ministerial directives. These obligations include identifying and verifying the identities of clients, conducting ongoing monitoring of business relationships and transactions, maintaining records for prescribed periods (typically five years), and submitting required reports to FINTRAC, such as suspicious transaction reports, large virtual currency transaction reports, large cash transaction reports, and terrorist property reports.

For the purposes of its compliance program, the Company understands money laundering to include:

the conversion or transfer of property, knowing or believing that the property is derived from the commission of an offence, for the purpose of concealing or disguising the illicit origin of the property or assisting any person involved in such activity to evade legal consequences;
the concealment or disguise of the nature, source, location, disposition, movement, or ownership of property knowing or believing that it is derived from the commission of an offence;
the acquisition, possession, or use of property knowing or believing, at the time of receipt, that it was obtained through the commission of an offence; and
participation in, attempts to commit, facilitation of, counselling, aiding, or abetting any of the activities described above.

Dream Finance understands terrorist financing to mean the direct or indirect provision, collection, or facilitation of funds with the intention, or knowledge, that they will be used to carry out a terrorist activity. Under Canadian law, terrorist activity includes acts committed for a political, religious, or ideological purpose with the intent to intimidate the public or compel a government, and that intentionally cause death or serious harm, endanger individuals, cause substantial property damage likely to result in harm, or seriously disrupt essential services or systems.

Risk-Based Approach and Risk Assessment

The Company applies a comprehensive Risk-Based Approach (RBA) to customer due diligence in accordance with the PCMLTFA, associated regulations, and FINTRAC guidance. The Company collects sufficient information and documentation on each prospective client to assess the money laundering and terrorist financing (ML/TF) risks associated with the business relationship. Employees are required to exercise sound judgment, diligence, and professionalism when evaluating the nature and purpose of each client relationship. The Company operates according to the highest ethical standards and will not enter into or maintain business relationships that could expose the Company to unacceptable ML/TF risk or harm its reputation.

For the purpose of identification, assessment and analysis of risks of money laundering and terrorist financing related to its activities, the Company prepares a risk assessment, taking account of at least the following categories:

Customer risk;
Geographical Risk;
Product Risk;
Delivery Channel;
Behavioral or Transactional Risk.

Once a risk level has been assigned to a client, the Company conducts periodic reviews of the risk rating based on updated information, behavioural indicators, transactional activity, and any changes in the client’s profile. The frequency and depth of these reviews increase proportionally with the assessed risk level.

MLRO

The Company’s senior management shall appoint a MLRO who is responsible for overseeing the Company’s AML/ATF compliance program and serving as the primary liaison with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). The MLRO reports directly to senior management and is granted the authority, independence, resources, and unrestricted access to all relevant information necessary to perform their duties effectively across all areas of the Company.

The MLRO must possess the education, experience, competencies, integrity, and professional suitability required to carry out the responsibilities of the role, which include the implementation, monitoring, and ongoing enhancement of the Company’s AML/ATF policies, procedures, and controls. The appointment of the MLRO is formally approved by senior management in accordance with PCMLTFA requirements and FINTRAC expectations.

The duties of a MLRO include, inter alia:

organisation of the collection and analysis of information referring to unusual transactions or transactions or circumstances suspected of money laundering or terrorist financing, which have become evident in the activities of the Company;
reporting to the FINTRAC in accordance with the requirements of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations;
periodic submission of written statements on compliance with the requirements arising from the Act to the management board of the Company;
performance of other duties and obligations related to compliance with the requirements of the Act.

The rules of procedure consist of the following:

a procedure for the application of due diligence measures regarding a customer, including a procedure for the application of simplified and enhanced due diligence measures;
a model for identification and management of risks relating to a customer and its activities and the determination of the customer’s risk profile;
the methodology and instructions where the Company has a suspicion of money laundering and terrorist financing or an unusual transaction or circumstance is involved as well as instructions for performing the reporting obligation;
the procedure for data retention and making data available;
instructions for effectively identifying whether a person is a politically exposed person or a local politically exposed person subject to international sanctions.

The Company applies the following due diligence measures:

identification of a customer and verification of the submitted information based on information obtained from a reliable and independent source, including using means of electronic identification and of trust services for electronic transactions;
identification of the beneficial owner and, for the purpose of verifying their identity, taking measures to the extent that allows the Company to make certain that it knows who the beneficial owner is, and understands the ownership and control structure of the customer;
understanding of business relationships, and, where relevant, gathering information thereon;
gathering information on whether a person is a politically exposed person, their family member or a person known to be close associate;
monitoring of a business relationship.

Enhanced Due Diligence

The Company applies enhanced due diligence (“EDD“) measures in order to adequately manage and mitigate a higher-than-usual risk of money laundering and terrorist financing.

EDD measures are applied always when:

upon identification of a person or verification of submitted information, there are doubts as to the truthfulness of the submitted data, authenticity of the documents or identification of the beneficial owner;
the customer is a politically exposed person, except for a local politically exposed person, their family member or a close associate;
the customer is from a high-risk third country or their place of residence or seat in a high-risk third country;
the customer is from such a country or territory that, according to credible sources such as mutual evaluations, reports or published follow-up reports, has not established effective AML/CTF systems that are in accordance with the recommendations of the Financial Action Task Force, or that is considered a low tax rate territory.

The Company applies EDD measures also where a risk assessment prepared on the basis of these rules identifies that, in the case of the economic or professional activity, field or factors, the risk of money laundering or terrorist financing is higher than usual.

EP Definition and Screening

Politically Exposed Persons (“PEP“) (as well as their families and persons known to be close associates, as described below) are required to be subject to enhanced scrutiny by reporting entities. This is because international standards issued by the Financial Action Task Force recognize that a PEP may be in a position to abuse their public office for private gain and a PEP may use the financial system to launder the proceeds of this abuse of office.

PEP means a natural person who is or who has been entrusted with prominent public functions including:

head of State;
head of government;
minister and deputy or assistant minister;
a member of parliament or of a similar legislative body;
a member of a governing body of a political party;

a member of a supreme court;

a member of a court of auditors or of the board of a central bank;
an ambassador, a chargé d’affaires and a high-ranking officer in the armed forces;
a member of an administrative, management or supervisory body of a State-owned enterprise;
a director, deputy director and member of the board or equivalent function of an international organisation,

PEPs do not include middle-ranking or more junior officials

Family member of a PEP means the spouse, or a person considered to be equivalent to a spouse, of a PEP or local PEP; a child and their spouse, or a person considered to be equivalent to a spouse, of a PEP or local PEP; a parent of a PEP or local PEP.

Person known to be close associate of a PEP means a natural person who is known to be the beneficial owner or to have joint beneficial ownership of a legal person or a legal arrangement, or any other close business relations, with a PEP or a local PEP; and a natural person who has sole beneficial ownership of a legal entity or legal arrangement which is known to have been set up for the de facto benefit of a PEP or local PEP.

Sanctions Screening

Dealing with persons against which imposed international sanctions poses a great risk to the Company, its directors, officers and owners.

The Company will perform sanction screening of its customers on the same matching rules, as for PEP screening.

The Company will perform screening, at minimum, against the following sanctions lists:

UN Sanctions;
EU Sanctions;
Sanctions administered by the Office of Financial Sanctions Implementation (“OFSI-UK”)
Sanctions administered by the Office of Foreign Assets Control (“OFAC-US“);
Sanctions imposed under the International Sanction Act.

All matches (true hits) will be escalated to a Compliance Officer for further action and processing.

Suspicious Activity Monitoring and Reporting

Where the Company identifies an activity or facts whose characteristics refer to the use of criminal proceeds or terrorist financing or other criminal offences or an attempt thereof or with regard to which the Company suspects or knows that it constitutes money laundering or terrorist financing or the commission of another criminal offence, a Compliance Officer of the Company must ensure that a Suspicious Transaction Report (STR) is submitted to FINTRAC immediately, but not later than within two working days after identifying the activity or facts or after getting the suspicion.

The Company and all of its employees, officers, and directors are strictly prohibited from disclosing to any person, including a client, their beneficial owner, representatives, or any third party, that a report has been submitted to FINTRAC, that the Company intends to submit such a report, or that a law enforcement investigation or criminal proceeding may be underway. This prohibition on “tipping off” is mandatory under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

Data Retention

The Company must retain the documents and information which served for identification and verification of clients, no less than five years after termination of the business relationship.

The Company implements necessary rules for protection of personal data upon application of the requirements arising from its obligations hereunder.

The Company is allowed to process personal data gathered upon implementation of these rules only for the purpose of preventing money laundering and terrorist financing and the data must not be additionally processed in a manner that does not meet the purpose, for instance, for marketing purposes.

Training

The Compliance Officer shall ensure that Company’s employees are fully aware of their legal obligations under the AML/CTF regime, by introducing a complete employees’ education and training program.

The timing and content of the training provided is determined according to the needs of the Company. The frequency of the training can vary depending on the amendments of legal and/or regulatory requirements, employees’ duties as well as any other changes in the business model. The training program aims at educating the Company’s employees on the latest developments in the prevention of money laundering and terrorist financing, including the practical methods and trends used for this purpose.

Cooperation and Exchange of Information

The Company cooperates with supervisory and law enforcement authorities in preventing money laundering and terrorist financing, thereby communicating information available to the Company and replying to queries within a reasonable time, following the duties, obligations and restrictions arising from legislation. For any relevant requests please contact us at [email protected]. Please note that if you represent a law enforcement agency outside of Canada, any request for information may be subject to the applicable Mutual Legal Assistance Treaty (MLAT) process or other formal international cooperation mechanisms administered by the Government of Canada.