KYC/AML Policy
Effective Date: April 15, 2025.
Introduction
CoinExchangeCanada is operated by CryptoLightHouse Ltd., a company incorporated under the laws of the Republic of Seychelles ("CoinExchangeCanada", "Company", "we", "our", or "us"). We are committed to maintaining a secure and compliant environment across our website at https://coinexchangecanada.ca (the "Website") and all associated services provided through it (the "Services").
As part of our dedication to transparency, regulatory compliance, and the safety of our users, we have developed this Know Your Customer (KYC) Policy ("Policy"). This document outlines the principles and procedures for verifying the identity of users ("you", "your", "Customer") and ensuring compliance with applicable legal and regulatory standards.
Note: This Policy does not apply to services provided by any third-party partners. These entities operate under their own terms and may implement different KYC procedures. We encourage you to review their respective policies when using their services.
By accessing and using our Website and Services, you confirm that you are not located in, a resident of, or a citizen of any of the following Prohibited Jurisdictions: the United States, European Union countries, the United Kingdom, Afghanistan, North Korea, Crimea and Sevastopol, Democratic Republic of Congo, Eritrea, Libya, Somalia, South Sudan, Sudan, Yemen, Iran, Iraq, Cuba, Syria, Mali, Central African Republic, Guinea-Bissau, Lebanon, or any other jurisdiction listed on the United Nations Security Council Sanctions List or equivalent international sanctions list.
CoinExchangeCanada reserves the right to amend this Policy at any time without prior notice. Any changes become effective upon publication on the Website. Continued use of the Website and Services after such updates constitutes your acceptance of the revised Policy.
If you have any questions or concerns about this Policy, please contact us at: [email protected].
1. Scope
This KYC Policy applies to all individuals who register, access, or otherwise make use of the Services offered through the CoinExchangeCanada Website. By using the Website, you acknowledge and agree that CoinExchangeCanada may request, review, and verify your personal information and/or identification documents as part of its Know Your Customer (KYC) procedures, in accordance with this Policy.
2. Circumstances for Verification
CoinExchangeCanada reserves the right to conduct KYC verification under the following circumstances:
(i) At our discretion: To safeguard the integrity of our platform, prevent unauthorized access from Prohibited Jurisdictions (as outlined in this Policy and our Terms of Use), and ensure compliance with our internal standards, we may initiate KYC verification at any time, without prior notice.
(ii) Upon request from third-party partners: Since cryptocurrency exchanges on CoinExchangeCanada are facilitated through external providers, we may be required to verify your identity in response to their compliance requests. Our partners may have their own regulatory obligations and may require KYC verification before initiating or completing a transaction. You can find more details and review third-party partner policies at: coinexchangecanada.ca/providers.
3. Customer Verification and Due Diligence
Our Know Your Customer (KYC) procedures, implemented both internally and through trusted third-party partners, are designed to verify the identities of users and assess the risks associated with their activity on CoinExchangeCanada. As part of this process, we collect identifying information, apply risk-based verification measures, record verification outcomes, and inform users of the need to provide personal data to confirm their identity.
Where appropriate, and in line with the customer’s risk profile, we aim to gather and verify sufficient information to reasonably confirm the true identity of each user using proven, risk-based methods.
3.1.1. We partner with Sum & Substance Ltd—a certified verification provider that processes customer data in full compliance with our Privacy Policy. This provider assesses whether the submitted information is:
– Logical, consistent, and sufficient to establish a reliable identity;
– Verified against global watchlists, including the Specially Designated Nationals list (OFAC), PEP databases, the EU sanctions list, UN sanctions, HMT, and adverse media sources.
3.1.2. Identity verification is typically completed within a reasonable timeframe, depending on the complexity of the user profile and transaction activity. In some cases, our third-party partners may suspend or delay transactions until the verification process is finalized. If suspicious data is detected that could indicate money laundering, terrorism financing, or other illicit behavior, the information will be escalated internally. Upon consultation with our AML Compliance Officer, it may be passed to our partners, who are authorized to freeze funds and file Suspicious Activity Reports (SARs) in line with the legal requirements of their jurisdiction.
3.2. We use trusted, independent sources to collect and verify customer information, including:
– Government-issued ID (passport, national ID card, etc.);
– Proof of residential address (utility bill, bank statement);
– Documentation verifying the source of funds.
3.3. Enhanced Due Diligence (EDD) is applied to high-risk customers, such as Politically Exposed Persons (PEPs). This process may include:
– Collecting additional identification documents;
– Verifying the source of wealth and funds through bank statements, tax returns, property records, or business financials;
– Conducting negative media checks;
– Securing approval from senior management for maintaining the business relationship;
– Applying ongoing enhanced monitoring measures, such as more frequent transaction reviews and annual reassessment of customer risk.
PEPs are identified and monitored through:
– Screening during onboarding using real-time PEP databases;
– Ongoing checks against updated international PEP lists;
– Pattern monitoring for high-risk behavior associated with PEPs.
3.4. Customer information is regularly updated and re-verified to ensure continued compliance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations.
4. Information Required for KYC Verification
To carry out Know Your Customer (KYC) verification, CoinExchangeCanada may request users to provide reliable and verifiable documentation or data. This may include, but is not limited to, a government-issued ID, passport, bank statement, utility bill, or proof of source of funds. In the case of legal entities, corporate documents and information about the ultimate beneficial owner may be required upon request.
We take appropriate steps to verify the authenticity of all information and documents submitted by users. This may include using external databases, security checks, or additional internal reviews. We also reserve the right to investigate customers who are flagged as high-risk or whose behavior appears suspicious.
Verification of identity may be an ongoing process. If a user's identification details change or their activity deviates from established patterns, we may request updated documentation. Even customers who have previously passed KYC verification may be asked to resubmit documents if needed for compliance or risk reassessment purposes.
All personal data collected during the KYC process is handled, stored, and protected in accordance with our Privacy Policy and applicable privacy regulations.
We may contact you at any time to clarify the information you have provided or to request additional documentation necessary for completing the verification or addressing case-specific risks.
CoinExchangeCanada reserves the right to deny access to the Services if the requested KYC information is not provided or remains incomplete.
5. Compliance Oversight and Management
CoinExchangeCanada has appointed a dedicated Compliance Officer responsible for the implementation and enforcement of this AML/KYC Policy. The Compliance Officer oversees all anti-money laundering and counter-terrorist financing (AML/CTF) initiatives and ensures alignment with regulatory expectations. Their responsibilities include:
– Supervising all AML/CTF-related processes;
– Collecting and verifying customer identity information;
– Developing and updating internal policies and procedures;
– Maintaining a secure and compliant record-keeping system;
– Conducting regular risk assessments and policy updates;
– Coordinating with regulatory bodies and law enforcement as needed.
The Compliance Officer is authorized to interact directly with relevant authorities in matters related to financial crime prevention. If any suspicious transaction is identified, CoinExchangeCanada will prepare a Suspicious Transaction Report (STR) and submit it to the appropriate Financial Intelligence Unit within two business days of identifying the grounds for suspicion.
6. Collaboration with Law Enforcement Agencies
Our third-party service providers maintain all required originator and beneficiary information related to virtual asset transfers and make it available to official authorities upon request.
CoinExchangeCanada remains fully cooperative with law enforcement agencies operating within their legal frameworks. While upholding strict standards for privacy and data protection, we ensure lawful access to relevant information where necessary.
To process official inquiries efficiently, requests must include:
– Full legal name of the requesting authority;
– Credentials and identification of the authorized officer(s);
– Verified contact information for confirmation;
– A clear description of the information being requested;
– Legal basis and jurisdiction for the request;
– Relevant case or reference numbers.
To avoid delays or errors, we recommend submitting wallet addresses, transaction IDs, and other identifiers in plain text or in a structured format such as an XLSX or CSV file.
The standard response time for requests is 1–2 business days. For complex inquiries or bulk data, processing may take 5–10 business days. These timelines do not include delays resulting from requests for additional clarification or supporting documentation.
Since CoinExchangeCanada does not directly perform asset exchanges but acts as a platform facilitating access to third-party providers, we are not liable for technical inaccuracies or processing delays. Data is provided as-is, and its accuracy cannot be guaranteed.
We reserve the right to determine the scope and content of each response based on legal obligations, technical feasibility, and available resources.
7. Data Protection
CoinExchangeCanada is fully committed to the privacy and security of all personal data collected through its KYC processes. We apply appropriate technical and organizational measures to ensure the confidentiality, integrity, and lawful handling of all customer information.
All data is processed in accordance with our Privacy Policy and relevant data protection regulations.