Last updated on September 10, 2026
1. Introduction
This AML/ATF Notice (hereinafter – “Notice”) is adopted by Huxeron Financial Inc. (hereinafter – “Company”, “We”, “Us” or “Our”) to provide general information regarding the anti-money laundering and anti-terrorist financing (hereinafter – “AML/ATF”), sanctions and financial crime prevention measures applied in connection with the Company’s over-the-counter (hereinafter – “OTC”) virtual currency services (hereinafter – “Services”).
The Company is incorporated in Canada under company number 2028406953 and has its registered address at 700-602 12 AVENUE SW, Calgary, Alberta, T2R1J3, Canada. This Notice is published on the Company’s website (hereinafter – “Website”).
The Company’s AML/ATF framework is designed with reference to applicable Canadian legal and regulatory requirements, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (hereinafter – “PCMLTFA”), related regulations, applicable Canadian sanctions requirements, and guidance issued by the Financial Transactions and Reports Analysis Centre of Canada (hereinafter – “FINTRAC”).
This Notice provides a general overview of the Company’s compliance approach and does not limit the Company’s ability to request additional information or documentation, apply further compliance measures, restrict or refuse the Services, or take any other action required or permitted under applicable law or the Company’s internal compliance procedures.
The Company may update or amend this Notice from time to time to reflect changes in its practices, Services or applicable legal and regulatory requirements. Any updated version will be published on the Website and will indicate its effective date. Where appropriate, the Company may also notify You of material changes by email or through other appropriate communication channels.
2. Our AML/ATF Approach
The Company applies a risk-based approach designed to identify, assess and manage AML/ATF, sanctions, fraud and other relevant financial crime risks associated with the Services.
The Company is establishing and will maintain an AML/ATF compliance framework appropriate to its regulated activities, including the appointment of a Compliance Officer responsible for its implementation and ongoing administration as required under applicable Canadian AML/ATF requirements.
Depending on the circumstances and applicable requirements, the Company applies identity and business verification, risk assessment, sanctions and politically exposed person (hereinafter – “PEP”) and head of an international organisation (hereinafter – “HIO”) screening, transaction and wallet monitoring, source of funds or source of wealth review, ongoing monitoring and other appropriate due diligence measures.
The nature and extent of such measures may vary depending on the person or entity involved, transaction type and amount, virtual currency, jurisdiction, wallet exposure and other relevant risk factors.
Where higher risks are identified, the Company may request additional information or documentation, apply enhanced due diligence or enhanced monitoring, impose restrictions or decline to provide the Services.
The Company may use third-party service providers to support identity verification, screening, blockchain analytics, transaction monitoring and other compliance functions. The use of such providers does not remove the Company’s responsibility for its applicable compliance obligations.
3. Identity Verification and Due Diligence
Before providing the Services, and where otherwise required, the Company may collect and verify information concerning You and the proposed transaction. Depending on the circumstances, this may include:
- Your identity, contact details and, where relevant, occupation or business activities;
- the legal status, ownership and control structure of a business or other legal entity, including its directors, beneficial owners and authorised representatives;
- whether You are acting on Your own behalf or on behalf of another person or entity;
- the purpose, nature and expected scope of the relationship or transaction;
- the source of funds, source of virtual currency and, where appropriate, source of wealth; and
- information required for sanctions, PEP/HIO and other compliance screening.
You must provide accurate, complete and up-to-date information and provide additional information or documentation reasonably requested by the Company.
The Company may verify information using third-party verification providers, public records, corporate registries, sanctions lists, blockchain data or other lawful sources.
Where applicable, the Company also takes measures to obtain and confirm beneficial ownership and control information in accordance with Canadian AML/ATF requirements.
4. Ongoing Monitoring and Virtual Currency Transactions
The Company may monitor business relationships, transactions and virtual currency wallets on an ongoing or event-driven basis.
Monitoring may include blockchain analytics, wallet risk screening, review of transaction patterns and counterparties, geographic exposure and assessment of whether activity is consistent with information previously provided to the Company.
The Company may also identify activity associated with fraud, scams, stolen assets, sanctions, illicit markets, structuring, layering, undisclosed third parties or attempts to circumvent compliance controls.
Where further review is required, We may request information concerning a transaction, wallet, counterparty, source or destination of funds or virtual currency, or the purpose of the transaction.
The Canadian Travel Rule applies to virtual currency transfers equivalent to CAD 1,000 or more where the applicable statutory conditions are met. Where the Travel Rule applies, the Company is required to ensure that prescribed identifying information about the sender and beneficiary accompanies the transfer. Where required information is missing or incomplete, the Company will take reasonable measures to obtain the information and will apply risk-based procedures to determine whether the transfer should be allowed, suspended or rejected.
5. Sanctions and Restricted Activity
The Company applies sanctions and other compliance screening designed to prevent the Services from being used in violation of applicable Canadian sanctions, terrorist property restrictions, Ministerial Directives, transaction restrictions or other applicable laws.
The Services must not be used in connection with:
- money laundering, terrorist financing, sanctions evasion, fraud or other unlawful activity;
- proceeds of crime or assets reasonably suspected to have been unlawfully obtained;
- sanctioned or otherwise prohibited persons, entities or jurisdictions;
- transactions intended to conceal the source, destination, ownership or purpose of funds or virtual currency;
- structuring or splitting transactions to avoid compliance or reporting requirements;
- false, misleading or fraudulent information;
- undisclosed third-party activity or use of another person’s identity; or
- attempts to circumvent identity verification, sanctions screening, transaction monitoring or other compliance controls.
The Company may apply additional restrictions where required by applicable law, Ministerial Directives or its risk-based compliance framework.
6. Regulatory Reporting
The Company submits reports and information to FINTRAC where required under applicable Canadian law.
Such reporting may include:
- Suspicious Transaction Reports (hereinafter – “STRs”) in relation to completed or attempted transactions that give rise to the required level of suspicion;
- Large Virtual Currency Transaction Reports (hereinafter – “LVCTRs”) where the Company receives virtual currency equivalent to CAD 10,000 or more in a single transaction or in multiple transactions required to be aggregated under the applicable 24-hour rule;
- Listed Person or Entity Property Reports where applicable reporting obligations arise in relation to property of a listed or sanctioned person or entity; and
- other reports or disclosures required under applicable Canadian law.
The Company may also be required to provide information or records to FINTRAC, law enforcement agencies, regulators, courts or other competent authorities in response to lawful requests, investigations or other applicable legal requirements.
In certain circumstances, applicable law may restrict the Company from disclosing information concerning regulatory reports or related investigations.
7. Restrictions, Refusal and Termination
The Company may request additional information or documentation, delay onboarding, impose transaction limits, delay or suspend a transaction, decline or cancel a proposed transaction, restrict access to the Services, refuse to establish a relationship or terminate an existing relationship where:
- applicable legal or compliance requirements are not satisfied;
- information is incomplete, inconsistent, inaccurate or cannot be verified;
- requested information or documentation is not provided;
- AML/ATF, sanctions, fraud, security or other material risks are identified; or
- the relevant activity falls outside the Company’s risk appetite or internal acceptance criteria.
To the extent permitted by applicable law, the Company may not be able to disclose the specific reason for a compliance-related restriction, refusal, delay or termination.
8. Record-Keeping and Confidentiality
The Company maintains records required in connection with its AML/ATF and related compliance obligations, including, where applicable, identification and due diligence information, beneficial ownership information, transaction and wallet records, Travel Rule information, screening and monitoring results and regulatory reports.
Records are retained for the periods required under applicable law. Certain records subject to Canadian AML/ATF requirements are required to be retained for at least five (5) years, depending on the relevant record type.
The Company applies measures designed to protect the confidentiality, integrity and accessibility of compliance records and limits access to persons who require such information for legitimate compliance, operational, legal or regulatory purposes.
9. Contacts
If You have any questions regarding this Notice or the Company’s general AML/ATF approach, You may contact the Company using the following details:
- Company name: Huxeron Financial Inc.
- Registered address: 700-602 12 AVENUE SW, Calgary, Alberta, T2R1J3, Canada
- Email: huxeron.financial@gmail.com