SPARTAKGlobal Services

AML/CTF Policy

Last updated: March 14, 2026

1. Introduction

SPARTAK GLOBAL SERVICES CORP. is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our procedures and controls designed to prevent the use of our services for money laundering, terrorist financing, or other financial crimes. We comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and all applicable FINTRAC regulations.

2. Regulatory Framework

  • Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).
  • FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) guidelines.
  • Criminal Code of Canada provisions related to money laundering and terrorist financing.
  • United Nations and Canadian sanctions regulations.
  • Any applicable provincial legislation.

3. Customer Due Diligence (CDD)

We perform Customer Due Diligence on all clients before establishing a business relationship. This includes verifying the identity of the client using reliable, independent documentation (government-issued photo ID, proof of address), determining whether the client is acting on behalf of a third party, and assessing the purpose and intended nature of the business relationship.

4. Enhanced Due Diligence (EDD)

  • Politically Exposed Persons (PEPs) — domestic, foreign, or international organization PEPs.
  • Clients from high-risk jurisdictions as identified by FATF.
  • Transactions that are unusually large or complex with no apparent economic purpose.
  • Clients whose source of funds or wealth cannot be easily verified.
  • Any situation where the risk of money laundering or terrorist financing is assessed as high.

5. Transaction Monitoring

We continuously monitor client transactions to detect suspicious activity. Our monitoring procedures include reviewing transactions against known typologies of money laundering and terrorist financing, identifying unusual patterns or behaviors, maintaining records of all transactions in accordance with FINTRAC requirements, and using risk-based approaches to allocate monitoring resources effectively.

6. Suspicious Transaction Reporting

When we identify a transaction or activity that gives rise to reasonable grounds to suspect money laundering or terrorist financing, we file a Suspicious Transaction Report (STR) with FINTRAC. We also report all large cash transactions ($10,000 CAD or more) and electronic funds transfers of $10,000 CAD or more. Tipping off clients about filed reports is strictly prohibited.

7. Sanctions Screening

All clients and transactions are screened against Canadian sanctions lists, the United Nations Security Council consolidated list, and other relevant sanctions databases. We do not provide services to individuals, entities, or countries subject to sanctions. Screening is performed at onboarding and on an ongoing basis.

8. Record Keeping

  • Client identification and verification records — retained for at least 5 years after the business relationship ends.
  • Transaction records — retained for at least 5 years from the date of the transaction.
  • Copies of all reports filed with FINTRAC.
  • Risk assessment documentation and compliance program records.
  • Training records for all staff members.

9. Staff Training

All employees receive regular AML/CTF training, including initial training upon hiring and refresher courses at least annually. Training covers recognition of suspicious activities, reporting obligations, regulatory requirements, and the consequences of non-compliance. Training records are maintained as required by FINTRAC.

10. Compliance Officer

We have appointed a dedicated Compliance Officer responsible for overseeing the implementation of this AML/CTF policy, ensuring compliance with all regulatory requirements, filing required reports with FINTRAC, conducting periodic risk assessments, and managing the compliance training program.

11. Risk Assessment

We conduct periodic risk assessments to evaluate our exposure to money laundering and terrorist financing risks. These assessments consider client risk factors, product and service risks, geographic risks, and delivery channel risks. The results inform our compliance program and resource allocation.

12. Contact

For questions about this AML/CTF Policy, please contact our Compliance Officer at info@spartakexchange.com or at our registered address: 208 14993 101A AVE, SURREY BC V3R 0T1, CANADA.