BOF Pay is committed to preventing money laundering, terrorist financing, fraud, and other financial crime. This page summarizes our anti-money laundering ("AML") and know-your-customer ("KYC") program. The full program is maintained internally and reviewed regularly by our compliance team and external auditors.
1. Regulatory framework
BOF Pay operates as a registered money services business with FINTRAC (Canada) and FinCEN (United States), along with state money-transmitter licenses where required. Our program is designed to comply with applicable AML laws and regulations, including the Bank Secrecy Act and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.
2. Customer due diligence
Before opening an account, we collect and verify information about the customer, including identity, address, date of birth, and (for businesses) ownership and control structure. We may request additional documentation and conduct enhanced due diligence for higher-risk customers, including politically exposed persons.
3. Ongoing monitoring
We monitor account activity on an ongoing basis using automated systems and manual review. Unusual or suspicious activity is investigated, and, where required, reported to the appropriate authorities. We may request information about the source of funds or the purpose of a transaction at any time.
4. Sanctions screening
We screen customers and transactions against sanctions and watchlists maintained by OFAC, the UN, the EU, the UK, FINTRAC, and other authorities. Transactions involving sanctioned individuals, entities, or jurisdictions will be blocked or rejected.
5. Record-keeping
We retain customer-identification records and transaction records for the periods required by applicable law, typically five to seven years after account closure or the date of a transaction.
6. Suspicious activity reporting
BOF Pay files Suspicious Transaction Reports (or equivalent) with the relevant Financial Intelligence Units when required. By law, we may not disclose to a customer that a report has been filed.
7. Training and governance
All BOF Pay employees receive AML training appropriate to their role. The program is overseen by a designated AML Compliance Officer and reviewed by senior management and the Board.
8. Cooperation with authorities
BOF Pay cooperates fully with regulators and law-enforcement agencies, including responding to lawful production orders, requests for information, and account-freezing requirements.
9. Contact
Compliance inquiries: info@bofpay.ai.