1Who we are and what this policy covers
Rem International Payments Inc. operates as REMPIC. We are registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business. We are also registered with the Bank of Canada as a payment service provider under the Retail Payment Activities Act. These registrations relate to separate regulatory frameworks.
This policy applies to the REMPIC website, web app and mobile apps. It explains how we address money laundering, terrorist financing and sanctions evasion under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and applicable regulations, and what we may ask of you when you use our services.
2Personal account verification
When you apply for an account or use certain services, we may ask for your legal name, date of birth, address and contact details. Depending on the checks required, we may ask for a valid government-issued identity document, proof of address, or information about your occupation and how you intend to use the account.
For remote verification, we may use a verification provider and ask for a selfie or a liveness check to confirm that the person presenting the document is its holder. We may ask you to provide a clearer image, replace an expired document or complete another permitted verification step before you can use certain services. Where permitted, we may verify your identity using information from two independent, reliable sources.
3Business accounts and acting for someone else
Where business services are available, we may ask for incorporation or registration documents, business activities and expected payment flows, and details of directors, authorised representatives and beneficial owners. We may also ask for proof that the person applying can act for the business and for information to confirm who owns or controls it.
Tell us if you are acting on behalf of someone else. Where required, we take reasonable steps to determine whether a third party is involved and may ask for their identity and relationship to you or to the transaction. Keep your personal or business details current and tell us when relevant information changes.
4Risk assessment and additional checks
We assess risk using factors such as the customer profile, the services used, payment activity and the jurisdictions involved. For businesses, we also consider the industry. We reassess risk as the relationship develops. Higher-risk situations may require more frequent reviews, further verification or additional documents. Requests for higher transaction limits may also require further checks.
We may ask about the purpose of a payment, who will receive it and where the money came from. Depending on the circumstances, an invoice, payslip, bank statement or sale agreement may help explain a payment. We may also ask for information about how your overall wealth was acquired where relevant or required. A request for more information does not by itself mean we consider the activity suspicious.
5Sanctions and politically exposed persons
We screen relevant persons and entities against applicable sanctions lists and assess potential matches. We also take the required steps to identify politically exposed persons and heads of international organisations and, where applicable, their family members or close associates. The outcome may call for additional review or information.
Service availability depends on the customer’s location, the destination and applicable restrictions, including Canadian ministerial directives. We will not process a payment where doing so would breach a legal prohibition. Where required, we may restrict access to funds or services and notify the appropriate authorities.
6Transaction monitoring and payment reviews
We monitor transactions and review activity over time. A review may be prompted by an unusual change in activity, updated account information, or a payment that differs from what we know about the account’s purpose. We may ask you to confirm the payment details, explain a change or provide supporting documents.
While checks are under way, we may delay a payment or limit access to a service. We may decline a payment or restrict an account if we cannot complete required checks, if the risk is outside what we can accept or if the law requires it. We may be limited in what we can tell you about a particular review.
7Reporting to FINTRAC
We report completed and attempted suspicious transactions to FINTRAC when we have reasonable grounds to suspect a link to money laundering, terrorist activity financing or sanctions evasion. There is no minimum amount for a suspicious transaction report.
We file other reports when applicable, including prescribed reports on certain international electronic funds transfers, large cash or virtual currency transactions, and property of listed persons or entities. We may be legally restricted from sharing details of a report or investigation.
8Privacy and record keeping
We use information collected during verification and monitoring to provide services, manage risk and meet our legal obligations. We may use service providers to help carry out checks and disclose information to competent authorities when the law requires or permits it. Our Privacy Policy explains how we handle personal information.
We retain identity, transaction and reporting records as required by Canadian law. For many prescribed records, the minimum retention period is five years. The date from which that period runs depends on the type of record. Please use the secure upload channel we provide for verification documents.
9Compliance oversight training and reviews
Our designated Compliance Officer oversees the AML program, including internal procedures, risk assessments and regulatory reporting. Staff with compliance responsibilities receive initial and ongoing training on verification, recognising unusual activity, escalating concerns and handling customer information.
We test the effectiveness of our compliance program at least every two years. We document the findings and follow up on corrective actions. We review our AML policy annually and update this public version when relevant laws or services change and make the current version available across the website and apps.
10Contact REMPIC
If you have a question about a verification request or a payment review, use the secure support channel in your account or contact support@rempic.com. Do not send identity documents, passwords or one-time security codes by email.