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Public Statement
Alpha Payments Inc. is committed to preventing its services from being used for money laundering, terrorist financing, sanctions evasion, fraud or other financial crime.
This Statement summarizes the principal anti-money laundering and counter-terrorist financing (AML/CTF) control standards applicable to regulated services offered by Alpha Payments Inc. (the Company, we, us) through paycot.com, subject to the service availability and limitations described in Section 9. It is written for individual and corporate customers, prospective customers, banking and payment partners, and other public stakeholders.
The Company's AML/CTF framework includes risk assessments, customer due diligence, sanctions controls, transaction monitoring, regulatory reporting, record keeping, training and compliance reviews, as required by applicable law and its risk-based procedures. Customer due diligence and other controls apply at onboarding and on an ongoing or event-driven basis where required. This Statement provides a general overview and does not reproduce the Company's internal policies, procedures or operational controls.
Alpha Payments Inc. is incorporated in Newfoundland and Labrador, Canada (Incorporation No. 97095). The Company is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business under registration number N300000919. The services listed in the Company's FINTRAC registration include foreign exchange, money transferring and dealing in virtual currency.
The Company is also registered with the Bank of Canada as a payment service provider under the Retail Payment Activities Act (RPAA) for the payment functions identified in its registry entry.
Important regulatory notice. Registration with FINTRAC or the Bank of Canada is not a licence, approval or endorsement of the Company, its products or its business practices, and does not constitute confirmation of ongoing compliance. It means that the Company is entered on the applicable registry and is subject to the relevant statutory obligations and supervisory framework.
Under the current service model, the Company does not offer customer-facing stored-value balances, reusable customer value, virtual-currency custody, pooled customer wallets or investment services. Any funds received in connection with a transfer are handled in accordance with applicable law and the relevant service terms.
The Company's governing body oversees the compliance framework. The Company has appointed a Compliance Officer / Money Laundering Reporting Officer (MLRO) responsible for implementing and maintaining the compliance program. The Compliance Officer / MLRO has appropriate authority, access to information, resources and escalation rights to support objective compliance decision-making.
The Company assesses risk across customers, beneficial owners, products, services, delivery channels, geographies, transaction types, virtual assets, payment and liquidity arrangements, technology and third-party dependencies. Controls are calibrated to the identified risk and are reviewed periodically and, where appropriate, following material changes to relevant laws, services, systems, providers, typologies or operating conditions.
A higher-risk classification does not automatically mean that a customer will be declined. It does mean that enhanced information, approval, monitoring or restrictions may be required. The Company applies controls designed to prevent activity prohibited by applicable law and may decline or restrict activity that is outside its approved risk appetite, is not supported under applicable payment-provider or payment-network requirements, or cannot be adequately understood or mitigated.
Before activating a relationship or processing a regulated service, the Company applies customer due diligence as required by applicable law and appropriate to the customer, service and risk. Depending on the circumstances, this may include:
The Company applies enhanced measures where required by applicable law, including in relation to customers or activities assessed as high risk. The nature and extent of those measures are determined by applicable requirements and the identified risk. Measures may include additional identity or corporate documents, deeper ownership evidence, information and evidence about source of funds or source of wealth, transaction purpose and counterparties, financial or business information, wallet history, or other corroboration. Where required, the Company obtains the relevant information and approvals. Other measures may include lower limits, manual review, more frequent information updates or increased monitoring.
Where supported by the relevant service, customers may receive payments from other persons or entities, including their customers and business partners, and make payments to third-party beneficiaries. Such payments do not require separate prior approval of each counterparty solely because the payer or beneficiary differs from the customer. Customers must provide accurate payment information and disclose when they are acting on behalf of another person or entity where required by applicable law or the relevant service terms. Concealing or misrepresenting the parties or purpose of a transaction is not permitted. The Company applies the identification, screening and third-party determination measures required by applicable law and its risk-based procedures, and may request supporting information or documents where needed. Transactions remain subject to applicable service, provider and payment-network restrictions. Unexplained or inconsistent information may result in additional review, restriction or rejection, and reporting where a reporting obligation arises.
When processing customer activity, the Company applies risk-based monitoring across relevant products, payment rails, assets, wallets, counterparties, providers and channels. Monitoring is designed to identify activity that is unusual for the customer, inconsistent with the stated purpose or profile, structured to avoid controls, connected to prohibited parties or otherwise relevant to money laundering, terrorist financing, sanctions evasion or fraud.
Where the Company provides virtual-currency services, it uses approved assets, networks, wallet arrangements and liquidity providers. Relevant wallet addresses and transaction exposure may be reviewed using blockchain analytics. The Company may request evidence that a customer owns or controls a wallet or that an identified third-party beneficiary is entitled to receive the transfer. Applicable originator and beneficiary information is obtained, transmitted and retained in accordance with Travel Rule requirements.
The Company complies with Canadian sanctions laws, including Canadian measures implementing United Nations Security Council obligations, and with any foreign sanctions laws or restrictive measures that are legally applicable to the Company or to a particular service or transaction. As an additional risk-based control, the Company may conduct screening against relevant foreign or international sanctions lists. Such additional screening may inform the Company's customer acceptance, transaction and service-availability decisions, but does not by itself make a foreign sanctions regime legally binding on the Company.
The Company applies screening and other sanctions controls to relevant customers, beneficial owners, authorized persons, payers, beneficiaries, counterparties, providers and, where applicable, virtual-currency addresses and exposure, as required by applicable law and its risk-based procedures. Such controls may be applied before onboarding or execution, periodically, and when material information changes.
A potential match is subject to review. Where identified before execution or release of value, the relevant transaction or processing is delayed or restricted until the match is resolved, subject to applicable law and the relevant terms. Where a legal prohibition, freeze, reporting or other restriction applies, the Company will take the action required by applicable law.
The Company may use regulated payment providers and other providers of identity verification, screening, monitoring, blockchain analytics, technology or liquidity services. Providers are subject to risk-based due diligence, contractual safeguards and oversight appropriate to the services and risk. The Company remains responsible for its legal obligations where applicable and retains oversight of outsourced compliance activities.
Where a reporting obligation arises, the Company submits reports to FINTRAC and makes reports or disclosures to other competent authorities where and as required by applicable law. Reporting decisions and submissions are supported by records maintained in accordance with applicable requirements.
Information about a suspicious transaction report, a contemplated report or a related investigation is restricted and may not be disclosed to a customer or other person where disclosure is prohibited or could prejudice an investigation. The Company may therefore be unable to explain the full reason for a delay, restriction, rejection or termination.
The Company authenticates and responds, as required by applicable law, to lawful requests from regulators, law-enforcement bodies and other competent authorities through controlled channels.
The Company creates and retains customer, ownership, transaction, monitoring, screening and regulatory records for the periods required by applicable law. The Company maintains administrative, technical and physical safeguards designed to protect records against unauthorized access, alteration or deletion. Records are made available to competent authorities where legally required.
Personal information is collected, used, disclosed, retained and disposed of in accordance with applicable privacy and data-protection laws and the Company's Privacy Policy. Where biometric or liveness technology is used for identity verification or fraud prevention, related personal information is processed in accordance with applicable privacy law and the Company's Privacy Policy, including applicable notice and consent requirements, purpose limitation, data minimization, retention, security and service-provider oversight. Other identity, device, payment and wallet data may be processed where necessary for identity verification, fraud prevention, AML/CTF, sanctions, security, service delivery or other identified lawful purposes.
Customers are expected to:
Subject to applicable law, the relevant customer terms and provider or payment-network requirements, the Company may refuse onboarding; request additional information; delay, reject, cancel, restrict or return a transaction; apply limits; suspend access; or end a relationship. Where funds are available for return following a failed or cancelled transaction, they will normally be returned to the original funding source, subject to applicable law, the relevant customer terms, and provider or payment-network requirements. Where permitted, an alternative verified account or wallet may be used after appropriate checks of the recipient's identity and entitlement to the funds and a review of the reason for the alternative return arrangement. No return will be made in breach of a legal prohibition, freezing requirement or other applicable restriction.
Registration does not mean that every product, asset, payment rail, customer category or jurisdiction is available. Availability is subject to applicable law, the Company's approved risk appetite, provider capability, applicable payment-provider and payment-network restrictions, and customer-facing product terms. Restrictions may relate to customer activities, jurisdictions, relevant owners or representatives, counterparties or individual transactions, depending on the service and requirements concerned. A restriction imposed by a provider or payment network does not necessarily mean that the activity is prohibited by Canadian law.
The Company will not offer or provide money services in Quebec, including to Quebec residents, where doing so requires a Quebec money-services business licence that the Company does not hold. Any service requiring such a licence may be provided only where the applicable licensing and other regulatory requirements have been met and the service falls within the Company's approved service scope. This is a licensing-based service limitation and does not represent a risk classification of Quebec.
Under the current service model, the services do not include acceptance or disbursement of cash or negotiable instruments, stored value, virtual-currency custody, pooled client wallets, derivatives, margin, leverage, lending, yield, staking-as-a-service or investment management. The Company applies controls designed to prevent services from being provided to persons or activity that are legally prohibited or outside the Company's approved service scope and geographic coverage.
The Company does not publish its internal country-risk methodology or a static regulatory list in this Statement. Applicable restrictions are determined using current law, official sanctions and directive sources, risk assessment, applicable payment-provider and payment-network requirements, and the product terms in force at the time of the request.
This Statement is provided for general information and is not a complete description of the Company's legal obligations, internal controls or contractual rights. It does not form part of or amend any contract and does not create contractual rights or obligations, including a right to receive a product or to have a transaction processed. Applicable law prevails, and contractual rights and obligations are governed by the relevant customer terms.
This Statement reflects the Company's general approach as of the publication date shown. It may be reviewed and updated from time to time at intervals the Company considers appropriate and may not be revised immediately following every change in law, regulatory guidance, services, risks, controls or internal arrangements. The Company will update this Statement where required by applicable law or where it considers an update necessary to prevent the Statement from becoming materially misleading. The timing of updates to this public Statement does not govern the review or updating of the Company's internal policies, procedures or controls, which are maintained in accordance with applicable legal requirements. A revised version is effective for informational purposes from the date it is published and does not amend the customer terms.
Company contact: Paycot contact page
Privacy: Privacy Policy
Customer terms: Terms and Conditions
FINTRAC: Money Services Business Registry
Bank of Canada: Registry of Payment Service Providers