Purpose and Scope

This AML & KYC policy applies to all MetaX Payments operations, including the onboarding of individual and business clients, the monitoring of transactions, and the retention of records. The policy sets out the framework for identifying, assessing, and mitigating risks associated with financial crime. It is designed to ensure that MetaX Payments operates within the legal framework of Canadian law, FINTRAC guidelines, and international best practices.

The scope of this policy covers:

• The identification and verification of individual and business clients.
• The monitoring and flagging of suspicious transactions.
• The processes for verifying wallet ownership.
• The use of third-party service providers for identity verification.
• The retention and reporting of records.
• Regular reviews and updates to the policy to maintain compliance with evolving regulations.

Client Onboarding & Verification Process

Individual Clients

Before an individual can transact on MetaX Payments, they must complete our comprehensive KYC process. This process involves collecting and verifying personal information to establish the client’s identity and assess any associated risk.

The information required for onboarding includes:

1. Full Name:
   The individual must provide their full legal name as it appears on official documents.
2. Date of Birth:
   Proof of age is required to ensure compliance with applicable regulations.
3. Government-Issued Photo Identification:
   Individuals must submit valid government-issued identification (e.g., passport, driver’s license, national ID card). This document must include a clear photograph of the client and an identifiable personal number.
4. Proof of Address:
   Clients must submit a utility bill, bank statement, or another official document that verifies their current residential address. The proof of address must be recent, usually dated within the last 90 days.
5. Selfie Verification:
   As an additional layer of verification, individuals may be required to submit a live photo (selfie) to be matched against their provided identification document.
6. Third-Party Verification:
   MetaX Payments uses trusted third-party service providers to validate the information and documentation provided. These third-party providers use advanced technology and adhere to high industry standards to ensure accurate and secure verification.

The onboarding process is designed to detect and prevent identity fraud and ensure that only legitimate individuals are permitted to use MetaX Payments’ services.

Business Clients

MetaX Payments welcomes business clients, but before a business is allowed to transact, it must undergo a thorough KYC verification process. The objective is to understand the nature of the business, its operations, and its ownership structure.

Business clients are required to provide:

1. Company Name:
   The full legal name of the business, as registered in its jurisdiction of incorporation.
2. Company Registration Number:
   Proof of the business’s registration with the relevant authorities in its jurisdiction.
3. Jurisdiction of Incorporation:
   The country or state where the business is legally incorporated.
4. Registered and Operational Addresses:
   The company must provide both its registered office address and the address of its primary place of business.
5. Description of Business Activities:
   A clear explanation of the nature of the business and the services it provides. This helps MetaX Payments assess the risk associated with the business’s operations.
6. Incorporation Documents:
   Businesses must submit incorporation documents, including but not limited to the Certificate of Incorporation, Articles of Association, and other relevant legal documentation.
7. Directors and Ultimate Beneficial Owners (UBOs):
   MetaX Payments requires information about the directors, shareholders, and any individuals who hold a significant interest in the company. UBOs are typically defined as individuals holding 25% or more of the shares or voting rights. Each director and UBO must complete individual identity verification as described in the Individual Clients section.
8. Third-Party Verification:
   Just as with individual clients, MetaX Payments uses third-party providers to verify the information and documents provided by businesses. This ensures that all business clients comply with applicable AML and KYC regulations.

The business verification process ensures that MetaX Payments only works with legitimate companies, reducing the risk of money laundering, fraud, and other financial crimes.

Wallet Ownership Verification

MetaX Payments mandates that all wallets used for the receipt or transmission of USDT must be owned by the client. To ensure compliance with this policy, we take the following steps to verify wallet ownership:

• 1. Proof of Wallet Ownership:
  Clients must provide evidence that the wallet belongs to them. This can be done by submitting screenshots or video recordings that clearly display:
  • The account owner's name.
  • The wallet address.
  • The name of the exchange or platform where the wallet is held.

This requirement applies to both individual and business clients.

• 2. Exchange Platform Verification:
  If the wallet is held on an exchange or third-party platform, MetaX Payments may require additional verification to confirm the legitimacy of the platform and the association between the client and the wallet.
• 3. Ongoing Monitoring:
  MetaX Payments reserves the right to periodically re-verify wallet ownership as part of its ongoing AML procedures.

Failure to provide adequate proof of wallet ownership may result in the rejection of the transaction or suspension of the client’s account.

Transaction Monitoring & Risk Management

MetaX Payments monitors all transactions for signs of suspicious activity. Our system is designed to detect patterns indicative of money laundering, terrorism financing, and other financial crimes.

Transaction Flagging Process

• When a transaction is flagged as potentially suspicious, it is immediately placed on hold.
• The client will be notified and required to complete additional AML & KYC verification steps, including providing further documentation or explanations about the transaction.
• MetaX Payments will assess the flagged transaction based on various factors, including transaction size, frequency, and the parties involved.

Record Keeping

MetaX Payments is committed to maintaining accurate and detailed records for all transactions and client interactions. As part of our compliance with FINTRAC and Canadian regulations, we retain records for at least five (5) years from the date of the last transaction or account closure. This includes:

• Copies of all identification documents provided by clients.
• Verification results from third-party identity providers.
• Documentation of wallet ownership.
• Records of flagged transactions and any associated correspondence.
• Business documentation provided by corporate clients.

These records may be shared with regulatory authorities upon request in accordance with legal requirements.

Third-Party Identity Verification

MetaX Payments partners with industry-leading third-party identity verification service providers to ensure that all individual and business clients are properly vetted. These providers are carefully selected to ensure that their processes meet or exceed international standards for AML and KYC compliance.

These providers use a combination of document analysis, biometric verification, and artificial intelligence to verify the identity of individuals and businesses quickly and accurately. By outsourcing identity verification to these trusted providers, MetaX Payments ensures that its onboarding process is both secure and efficient.

Compliance Reporting

As a regulated MSB, MetaX Payments has a legal obligation to report any suspicious activities or transactions to FINTRAC and other relevant authorities. In compliance with Canadian law, we maintain confidentiality and do not notify clients when their activities are reported.

Our compliance team continuously reviews and monitors all transactions and escalates any suspicious activity for further investigation. Clients are required to cooperate fully with any AML-related inquiries and investigations.

Regular Policy Review and Updates

MetaX Payments recognizes that the regulatory landscape is constantly evolving. As such, this AML & KYC Policy is subject to regular reviews and updates. We are committed to ensuring that our policies remain in full compliance with all applicable laws and regulations, including any updates issued by FINTRAC, the Canadian government, or other international regulatory bodies.

Any changes to this policy will be published on our website, and clients will be informed of significant updates.

Client Responsibilities

All clients of MetaX Payments, whether individuals or businesses, are responsible for:

• Providing accurate and up-to-date information during onboarding and throughout their relationship with MetaX Payments.
• Cooperating with AML & KYC verification processes, including the provision of additional documentation upon request.
• Ensuring that all wallets used for transactions are registered under their own name.
• Notifying MetaX Payments of any changes in ownership, directors, or UBOs for business accounts.

Failure to comply with these responsibilities may result in account suspension or termination.

MetaX Payments remains fully committed to providing a safe and secure platform for the exchange of USDT and fiat currency. Our robust AML & KYC processes are designed to prevent illicit activity and ensure the highest level of compliance with Canadian and international regulations.