This AML, KYC & Sanctions Policy explains the anti-money laundering, counter-terrorist financing, sanctions, customer due diligence, transaction monitoring, wallet screening, and compliance controls applied by Aurex Financial Technologies Inc., a corporation incorporated under the laws of British Columbia, Canada, Incorporation No. BC1535602, operating under the trading name Coinsfly.
Aurex Financial Technologies Inc. is registered as a Money Services Business, MSB, with the Financial Transactions and Reports Analysis Centre of Canada, FINTRAC, under registration number C100000967.
Registered office:
2-1130 Hachey Ave, Coquitlam, BC V3K 2H4, Canada
In this Policy, “Coinsfly”, the “Company”, “we”, “us”, and “our” refer to Aurex Financial Technologies Inc. operating as Coinsfly. “User”, “Client”, “Merchant”, “you”, and “your” refer to any individual, business, merchant, applicant, customer, beneficial owner, authorized representative, or other person using or attempting to use Coinsfly services.
By accessing or using Coinsfly, creating an account, submitting information, completing verification, purchasing crypto, using card or wire payment methods, adding an external wallet, requesting a withdrawal, using the merchant gateway, or confirming any transaction, you acknowledge that you have read, understood, and agreed to this Policy.
1. Purpose of this Policy
Coinsfly is committed to maintaining strong financial crime controls and preventing the misuse of its platform for money laundering, terrorist financing, sanctions evasion, fraud, scams, illegal activity, or other financial crime.
This Policy explains how Coinsfly:
- Identifies and verifies users;
- Identifies and verifies businesses and merchants;
- Screens users, businesses, merchants, and wallets;
- Applies sanctions and restricted-jurisdiction controls;
- Reviews Source of Funds and Source of Wealth;
- Applies account limits;
- Monitors transactions;
- Screens wallet addresses;
- Detects suspicious activity;
- Handles compliance reviews;
- Reports to relevant authorities where required;
- Maintains records;
- Restricts or refuses access where required.
Coinsfly applies a risk-based approach, meaning that the level of due diligence, monitoring, documentation, and review may vary depending on the user, business type, country, payment method, wallet risk, transaction size, transaction behaviour, merchant activity, and other risk factors.
2. Regulatory Framework
Coinsfly’s AML, KYC, and sanctions framework is designed to align with applicable Canadian laws, regulations, guidance, and regulatory expectations, including:
- The Proceeds of Crime Money Laundering and Terrorist Financing Act, PCMLTFA;
- Regulations made under the PCMLTFA;
- FINTRAC guidance applicable to money services businesses;
- Canadian sanctions laws and regulations;
- Applicable federal and provincial laws;
- Internal compliance policies and procedures;
- Requirements of banking partners, acquirers, payment providers, liquidity providers, verification providers, and other regulated counterparties.
Coinsfly’s MSB registration with FINTRAC indicates that the company is registered as a money services business. It does not mean that FINTRAC endorses Coinsfly, guarantees Coinsfly services, approves any digital asset, or provides deposit protection. FINTRAC explains that registration means a business has fulfilled the legal requirement to register with the federal government, not that FINTRAC endorses the business. (FINTRAC)
3. Scope of this Policy
This Policy applies to:
- Website visitors where relevant;
- Applicants;
- Individual users;
- Business users;
- Merchants;
- Merchant customers;
- Beneficial owners;
- Directors;
- Shareholders;
- Authorized representatives;
- Account holders;
- Payment participants;
- Wallet owners;
- Counterparties involved in transactions;
- Any person or entity connected to a Coinsfly account, transaction, wallet, order, merchant gateway, or compliance review.
This Policy applies to the following Coinsfly services and activities:
- Account registration;
- Login and authentication;
- Email and phone verification;
- Individual KYC;
- Business KYB;
- Merchant onboarding;
- Source of Funds review;
- Source of Wealth review;
- Account limit review;
- Buy Crypto by card;
- Buy Crypto by wire;
- Multi-currency account and deposit options where available;
- Wallet whitelisting;
- Crypto withdrawals to approved external wallets;
- Merchant gateway payments;
- Crypto payment orders;
- Transaction monitoring;
- Refund and cancellation reviews;
- Dispute, recall, and chargeback reviews;
- Suspicious activity reviews;
- Recordkeeping and reporting.
4. Key Definitions
4.1 AML
AML means anti-money laundering controls designed to prevent, detect, report, and mitigate money laundering and related financial crime.
4.2 CTF
CTF means counter-terrorist financing controls designed to prevent, detect, report, and mitigate terrorist financing activity.
4.3 Sanctions
Sanctions are legal restrictions imposed by Canada, the United Nations, and other relevant authorities against certain individuals, entities, countries, territories, sectors, goods, services, wallets, or financial activity.
4.4 KYC
KYC means Know Your Customer, the process of identifying, verifying, and assessing an individual user.
4.5 KYB
KYB means Know Your Business, the process of identifying, verifying, and assessing a business, merchant, legal entity, directors, shareholders, beneficial owners, controllers, and authorized representatives.
4.6 CDD
CDD means Customer Due Diligence, including collecting and verifying information, understanding account purpose, assessing risk, and monitoring the business relationship.
4.7 EDD
EDD means Enhanced Due Diligence, a higher level of review applied to higher-risk users, businesses, merchants, transactions, countries, wallets, payment methods, or activity patterns.
4.8 Source of Funds
Source of Funds means the origin of the specific funds used for a transaction or intended activity.
4.9 Source of Wealth
Source of Wealth means the broader origin of a user’s or beneficial owner’s total wealth.
4.10 PEP
PEP means Politically Exposed Person and includes categories recognized under applicable AML rules and Coinsfly’s internal policy.
4.11 HIO
HIO means Head of an International Organization.
4.12 Whitelisted Wallet
A Whitelisted Wallet is an external wallet address submitted by a user, screened by Coinsfly or its providers, and approved for withdrawals.
4.13 Suspicious Activity
Suspicious Activity means any activity, attempted activity, transaction, pattern, document, wallet, payment, user behaviour, or merchant activity that Coinsfly considers suspicious, unusual, inconsistent, high risk, or potentially connected to money laundering, terrorist financing, sanctions evasion, fraud, scams, or illegal conduct.
5. Compliance Program
Coinsfly maintains a compliance program designed to detect, prevent, and manage AML, CTF, sanctions, fraud, and financial crime risks.
The compliance program may include:
- Appointment of a Compliance Officer;
- Written AML, KYC, KYB, sanctions, and transaction monitoring procedures;
- Risk assessment;
- User and business due diligence procedures;
- Merchant onboarding procedures;
- Ongoing monitoring;
- Wallet screening;
- Sanctions screening;
- PEP and HIO screening;
- Suspicious activity escalation;
- Reporting procedures;
- Recordkeeping controls;
- Staff training;
- Independent or periodic compliance reviews;
- Internal audit trails;
- Provider due diligence;
- Senior management oversight.
FINTRAC guidance states that reporting entities must implement a compliance program, including a compliance officer, written policies and procedures, risk assessment, training, and review. (FINTRAC)
6. Risk-Based Approach
Coinsfly applies a risk-based approach to all users, businesses, merchants, wallets, transactions, and payment flows.
Risk factors may include:
- Country of residence;
- Country of nationality;
- Business location;
- IP location;
- Device signals;
- Payment method;
- Payment account country;
- Transaction amount;
- Transaction frequency;
- Source of Funds;
- Source of Wealth;
- Occupation;
- Business activity;
- Merchant category;
- Customer base;
- Expected transaction volume;
- Wallet exposure;
- Blockchain risk score;
- Sanctions exposure;
- PEP or HIO status;
- Adverse media;
- Suspicious behaviour;
- Chargeback or recall history;
- Provider feedback;
- Prior account history.
Coinsfly may apply different levels of due diligence depending on the risk profile.
7. Customer Identification and Verification
Coinsfly requires users to complete verification before using services.
For individual users, Coinsfly may collect and verify:
- Full legal name;
- Middle name, if applicable;
- Date of birth;
- Nationality;
- Country of residence;
- Residential address;
- Phone number;
- Email address;
- Government-issued identification document;
- Document number;
- Document expiry date;
- Issuing country;
- Selfie or liveness verification;
- Proof of address;
- Occupation;
- Intended use of account;
- Source of Funds;
- Source of Wealth where required;
- Tax-related declarations;
- U.S. person declaration;
- PEP declaration.
Coinsfly may use Sumsub or other approved verification providers to perform identity verification, document checks, biometric/liveness checks, sanctions screening, PEP screening, and adverse media screening.
Coinsfly may refuse services if identity cannot be verified.
8. Business and Merchant Verification
Business users and merchants must complete KYB before accessing business or merchant services.
Coinsfly may collect and verify:
- Legal entity name;
- Trading name;
- Registration number;
- Incorporation documents;
- Registered address;
- Operating address;
- Business website;
- Business activity;
- Industry category;
- Expected transaction volume;
- Ownership structure;
- Directors;
- Officers;
- Authorized representatives;
- Shareholders;
- Ultimate beneficial owners;
- Controllers;
- Corporate documents;
- Licences or regulatory permissions where applicable;
- Proof of business address;
- Source of Funds;
- Source of Wealth where required;
- Merchant payment model;
- Goods or services sold;
- Customer base;
- Countries served;
- Refund and dispute policy;
- Chargeback and recall exposure;
- Supporting documents requested by Compliance.
Business and merchant applications may require manual review by Coinsfly Compliance.
Coinsfly may reject any business or merchant if the activity, ownership, country exposure, transaction model, payment flow, product type, compliance profile, or reputational risk falls outside Coinsfly’s risk appetite.
9. Beneficial Ownership and Control
For business and merchant accounts, Coinsfly may identify and verify beneficial owners, shareholders, directors, controllers, and authorized representatives.
Coinsfly may require information about any person who:
- Owns or controls the business;
- Directly or indirectly owns shares or voting rights;
- Exercises control over the account;
- Controls payment instructions;
- Benefits from transactions;
- Acts as director, officer, signatory, or representative;
- Has material influence over the business.
Coinsfly may request ownership charts, corporate registers, shareholder registers, board resolutions, powers of attorney, or other documents to understand ownership and control.
10. Politically Exposed Persons
Coinsfly screens users, beneficial owners, directors, representatives, merchants, and relevant persons for PEP and HIO status.
Coinsfly’s current policy is:
If PEP = Yes, Coinsfly will not be able to offer services.
This may apply to:
- Politically Exposed Persons;
- Heads of International Organizations;
- Family members of PEPs or HIOs;
- Close associates of PEPs or HIOs;
- Any person treated as equivalent under Coinsfly’s internal risk policy.
If PEP status is discovered during onboarding or after account creation, Coinsfly may:
- Reject onboarding;
- Suspend services;
- Cancel pending transactions;
- Freeze activity;
- Request additional documents;
- Close the account;
- Take any action required by law or compliance policy.
11. Sanctions Screening
Coinsfly screens users, businesses, merchants, beneficial owners, representatives, counterparties, wallets, and transactions against relevant sanctions and watchlists.
Screening may include:
- Canadian sanctions lists;
- United Nations sanctions lists;
- U.S. OFAC lists;
- United Kingdom sanctions lists;
- European Union sanctions lists;
- Other relevant international or internal watchlists;
- Law enforcement lists;
- Provider-specific restricted lists;
- Internal Coinsfly restricted lists.
Coinsfly may reject, suspend, freeze, block, or terminate activity where there is a sanctions match, possible match, unresolved match, high-risk indication, or provider instruction.
Coinsfly may be legally restricted from explaining sanctions-related actions.
12. Restricted and Prohibited Jurisdictions
Coinsfly may restrict access based on:
- Residence;
- Nationality;
- Location;
- IP address;
- Payment origin;
- Bank country;
- Wallet exposure;
- Merchant market;
- Provider restrictions;
- Sanctions laws;
- Internal risk appetite.
Coinsfly does not provide services to U.S. persons, including U.S. citizens or U.S. residents.
Coinsfly does not market to or serve clients from the United Kingdom.
Coinsfly does not solicit clients in the European Union. EU clients may access or request services only on their own initiative, subject to eligibility and applicable law.
Coinsfly may maintain a list of prohibited, restricted, or enhanced-risk countries. This list may be updated at any time without public notice where required for security, legal, provider, or compliance reasons.
Users must not use VPNs, proxies, TOR, remote access tools, false documents, false location information, or similar methods to bypass jurisdiction controls.
13. Age and Capacity Requirements
Coinsfly services are available only to persons who are at least 18 years old or the age of majority in their jurisdiction, whichever is higher.
Users must have full legal capacity to enter into binding agreements and use Coinsfly services.
Coinsfly may reject or close accounts where the user is underage, lacks capacity, acts on behalf of an undisclosed third party, or cannot legally use the services.
14. No Third-Party Payments
Coinsfly generally permits payments only from accounts, cards, wallets, or payment methods held in the verified user’s own name, or in the name of the approved business account holder.
Coinsfly may reject third-party payments.
This applies to:
- Card payments;
- Wire transfers;
- vIBAN/account payments;
- Open banking payments;
- Crypto withdrawals;
- Merchant gateway flows;
- Refunds;
- Any payment method used on Coinsfly.
If a third-party payment is detected, Coinsfly may:
- Reject the transaction;
- Hold funds;
- Request documents;
- Refund to the original source where possible;
- Restrict the account;
- Close the account;
- Report suspicious activity where required.
15. Payment Method Controls
Coinsfly may support payment methods such as:
- Card payments;
- Wire transfers;
- Local bank rails;
- SWIFT;
- SEPA;
- Open banking;
- vIBAN/account options where available;
- Other approved provider methods.
Available payment methods may depend on:
- User profile;
- Business profile;
- Nationality;
- Residence;
- Age;
- Payment amount;
- Currency;
- Payment rail;
- Account limit;
- Verification status;
- Provider availability;
- Compliance review.
Coinsfly may refuse any payment method where it creates legal, compliance, provider, operational, or fraud risk.
16. Source of Funds and Source of Wealth
Coinsfly may request Source of Funds and Source of Wealth information at onboarding, before a transaction, after a transaction, when limits are reached, during ongoing monitoring, or at any time required by Compliance.
Documents may include:
- Payslips;
- Bank statements;
- Tax declarations;
- Loan agreements;
- Sale agreements;
- Dividend records;
- Investment statements;
- Business financial statements;
- Invoices;
- Contracts;
- Proof of inheritance;
- Proof of savings;
- Proof of crypto holdings;
- Other documents requested by Coinsfly.
Documents must be clear, valid, unaltered, complete, and consistent with the user profile and transaction activity.
Coinsfly may reject documents that are expired, unclear, inconsistent, incomplete, forged, altered, unverifiable, or insufficient.
17. Account Limits
Coinsfly may apply account limits based on compliance review.
Limits may be based on:
- Verification status;
- Tier level;
- Source of Funds;
- Source of Wealth;
- User profile;
- Business model;
- Merchant model;
- Provider rules;
- Jurisdiction;
- Transaction history;
- Risk assessment;
- Compliance decision.
Coinsfly Compliance may set a maximum total amount that a user or business may transact.
If a user reaches the assigned account limit, Coinsfly may block further purchases, account issuance, use of vIBAN/account options, withdrawals, or merchant activity until updated documents are provided and approved.
The platform may display a notice such as:
“You reached the maximum amount and/or number of deposits. Please upload updated Source of Funds.”
Coinsfly may increase, reduce, maintain, or remove limits after compliance review.
18. Manage Docs and Compliance Requests
Coinsfly may require users to upload documents through the Manage Docs page.
Documents may be requested for:
- Verification;
- Updated ID;
- Proof of address;
- Source of Funds;
- Source of Wealth;
- Account limit increase;
- Transaction review;
- Merchant review;
- Dispute or chargeback review;
- Refund review;
- Suspicious activity review;
- Periodic review;
- Provider request;
- Regulatory request.
Document statuses may include:
- Pending;
- In Review;
- Approved;
- Declined;
- Expired;
- More Information Required.
Failure to provide requested documents may result in service restrictions.
19. Wallet Whitelisting and Wallet AML Screening
Users may withdraw crypto only to approved whitelisted wallets.
To whitelist a wallet, the user must:
- Select the asset;
- Select the network;
- Enter the wallet address;
- Submit the wallet for review;
- Complete wallet AML screening;
- Wait for approval.
Coinsfly may screen wallets for exposure to:
- Sanctions;
- Darknet markets;
- Fraud;
- Scams;
- Ransomware;
- Stolen funds;
- Mixers;
- Tumblers;
- Privacy-enhancing obfuscation tools;
- High-risk exchanges;
- Unlicensed or non-compliant VASPs;
- Terrorist financing;
- Child exploitation-related activity;
- Human trafficking;
- Illegal gambling;
- Other illicit or high-risk activity.
Coinsfly’s current wallet AML threshold is 65%. If a wallet or transaction risk score is above the permitted threshold, or if the wallet is otherwise flagged, Coinsfly may reject, block, hold, freeze, escalate, or manually review the wallet or transaction.
Coinsfly may change risk thresholds at any time according to legal requirements, provider rules, internal policy, or risk assessment.
20. Crypto Withdrawal Controls
Crypto withdrawals are allowed only to approved whitelisted wallets.
Withdrawal requests may be subject to:
- Available balance;
- Approved wallet status;
- Asset and network compatibility;
- Network fee;
- Email OTP;
- SMS OTP;
- AML wallet screening;
- Transaction monitoring;
- Account limits;
- Compliance review;
- Manual approval;
- Queue processing;
- Blockchain confirmation;
- Provider or infrastructure availability.
Coinsfly may delay, reject, block, cancel, or freeze withdrawals where required by law, compliance review, sanctions, fraud controls, wallet risk, suspicious activity, provider instruction, technical issues, or internal risk policy.
21. Merchant Gateway AML Controls
Coinsfly applies AML and compliance controls to merchant gateway activity.
Merchant gateway controls may include:
- Merchant KYB;
- Business activity review;
- Beneficial ownership review;
- Customer verification where required;
- Payment purpose review;
- Order monitoring;
- Wallet destination review;
- Merchant wallet review;
- Chargeback and recall monitoring;
- Dispute monitoring;
- Transaction volume monitoring;
- Customer pattern analysis;
- High-risk behaviour detection;
- Ongoing merchant review.
Coinsfly may suspend or revoke a merchant gateway link if the merchant presents unacceptable AML, CTF, sanctions, fraud, provider, reputational, or chargeback risk.
22. Transaction Monitoring
Coinsfly monitors transactions on an ongoing basis.
Monitoring may include:
- Transaction size;
- Frequency;
- Velocity;
- Currency;
- Crypto asset;
- Network;
- Payment method;
- Origin of funds;
- Destination wallet;
- Merchant relationship;
- User behaviour;
- IP and device activity;
- Wallet exposure;
- Prior history;
- Account limits;
- Chargebacks, recalls, and disputes;
- Unusual or inconsistent activity.
Transactions may be automatically or manually reviewed.
Coinsfly may request additional documents or explanations before processing a transaction.
23. Suspicious Activity and Reporting
If Coinsfly knows, suspects, or has reasonable grounds to suspect that activity may relate to money laundering, terrorist financing, sanctions evasion, fraud, or another financial crime, Coinsfly may take appropriate action.
Actions may include:
- Rejecting a transaction;
- Delaying a transaction;
- Blocking a transaction;
- Freezing activity;
- Restricting withdrawals;
- Suspending the account;
- Closing the account;
- Requesting documents;
- Reporting to FINTRAC;
- Reporting to law enforcement;
- Reporting to other authorities where required.
FINTRAC guidance confirms that MSBs must submit required reports, including suspicious transaction reports and other reports where applicable. (FINTRAC)
Coinsfly may be legally prohibited from informing you that a report has been filed or that an investigation is underway.
24. Large Transaction Reporting and Records
Coinsfly may be required to keep records or file reports for large transactions, including large virtual currency transactions where applicable.
FINTRAC guidance states that a Large Virtual Currency Transaction Report must be submitted when a reporting entity receives virtual currency in an amount equivalent to CAD 10,000 or more in a single transaction, and FINTRAC guidance also addresses 24-hour aggregation rules. (FINTRAC)
FINTRAC recordkeeping guidance states that MSBs must keep large virtual currency transaction records when they receive virtual currency in an amount equivalent to CAD 10,000 or more, and must keep virtual currency exchange transaction tickets for every virtual currency exchange transaction regardless of amount. (FINTRAC)
25. Travel Rule Compliance
Coinsfly may collect, verify, retain, transmit, or receive originator and beneficiary information for electronic funds transfers and virtual currency transfers where required.
Travel Rule information may include:
- Name;
- Address;
- Account number or reference number;
- Wallet address;
- Beneficiary details;
- Originator details;
- Transaction reference;
- Other required information.
FINTRAC guidance explains that the Travel Rule applies to MSBs and requires certain information to be included, obtained, or retained for qualifying electronic funds transfers and virtual currency transfers. (FINTRAC)
Coinsfly may suspend, reject, delay, or review transfers where required Travel Rule information is missing, incomplete, inconsistent, or cannot be obtained.
26. Prohibited Users
Coinsfly does not permit use of its services by:
- Minors;
- U.S. persons, including U.S. citizens and U.S. residents;
- Persons located in restricted jurisdictions;
- Persons subject to sanctions;
- Persons acting for sanctioned persons;
- Persons using false or stolen identity information;
- Persons refusing verification;
- Persons identified as PEP where Coinsfly policy prohibits service;
- Persons using anonymization tools to hide location or identity;
- Persons previously banned by Coinsfly;
- Persons acting on behalf of undisclosed third parties;
- Persons whose activity exceeds Coinsfly’s risk appetite;
- Any person prohibited by law, provider rules, or internal policy.
27. Prohibited Activities
You must not use Coinsfly for:
- Money laundering;
- Terrorist financing;
- Sanctions evasion;
- Fraud;
- Scams;
- Ransomware;
- Stolen funds;
- Darknet market activity;
- Illegal goods or services;
- Counterfeit goods;
- Weapons-related illegal activity;
- Drug trafficking;
- Human trafficking;
- Exploitation;
- Illegal gambling;
- Unlicensed financial services;
- Market manipulation;
- Tax evasion;
- Bribery or corruption;
- Circumventing account limits;
- Circumventing geographic restrictions;
- Third-party payments;
- Mixers, tumblers, privacy coins, or obfuscation services where prohibited;
- Any other illegal, abusive, deceptive, or high-risk activity.
Coinsfly may update prohibited activity categories at any time.
28. Enhanced Due Diligence
Coinsfly may apply Enhanced Due Diligence where a user, business, merchant, transaction, wallet, country, or pattern presents higher risk.
EDD may include:
- Additional identity verification;
- Additional business documents;
- Proof of address;
- Updated Source of Funds;
- Source of Wealth;
- Bank statements;
- Tax documents;
- Additional ownership verification;
- Interview or questionnaire;
- Video call;
- Manual compliance review;
- Senior compliance approval;
- Reduced limits;
- Increased monitoring;
- Transaction holds;
- Periodic review.
Failure to satisfy EDD requirements may result in account restriction or closure.
29. Ongoing Monitoring
Coinsfly may monitor users, businesses, merchants, wallets, and transactions during the entire relationship.
Ongoing monitoring may include:
- Periodic KYC refresh;
- Periodic KYB refresh;
- Document expiry checks;
- Sanctions rescreening;
- PEP rescreening;
- Wallet rescreening;
- Transaction pattern review;
- Merchant volume review;
- Chargeback and recall review;
- Risk score updates;
- Account limit updates;
- Additional documentation requests.
Coinsfly may request updated information at any time.
30. Recordkeeping
Coinsfly keeps records required for legal, regulatory, compliance, AML/CTF, sanctions, tax, audit, fraud prevention, and dispute purposes.
Records may include:
- Identity records;
- Business verification records;
- Beneficial ownership records;
- Verification results;
- Sanctions screening results;
- PEP screening results;
- Source of Funds documents;
- Source of Wealth documents;
- Wallet screening records;
- Transaction records;
- Virtual currency exchange transaction tickets;
- Large transaction records;
- Suspicious activity records;
- Reports submitted to FINTRAC;
- Merchant records;
- Refund and dispute records;
- Compliance decisions;
- Communications and support records.
The attached competitor policy uses a minimum five-year recordkeeping concept, and FINTRAC guidance also includes five-year retention periods for various MSB records. (FINTRAC)
31. Confidentiality and Data Protection
Coinsfly protects compliance information using technical and organizational safeguards.
Compliance data may be accessed only by authorized personnel and service providers who need access for legitimate business, compliance, legal, security, or operational purposes.
Coinsfly may not disclose certain compliance information to users where disclosure would:
- Breach law;
- Breach AML/CTF rules;
- Tip off a user;
- Compromise an investigation;
- Expose monitoring rules;
- Increase fraud risk;
- Breach provider confidentiality;
- Harm platform security.
Personal information is handled according to the Coinsfly Privacy Policy.
32. User Responsibilities
Users are responsible for:
- Providing accurate information;
- Keeping information updated;
- Completing verification;
- Responding to compliance requests;
- Providing genuine documents;
- Using only own payment methods;
- Not using third-party funds;
- Not hiding identity or location;
- Reviewing transaction details;
- Using only approved wallets;
- Complying with applicable law;
- Not using Coinsfly for prohibited activity;
- Informing Coinsfly of suspicious account activity.
Providing false, misleading, forged, altered, incomplete, or inconsistent information may result in rejection, suspension, termination, transaction cancellation, refund refusal, asset freeze, and reporting.
33. Coinsfly Rights
Coinsfly may, at any time and without prior notice where appropriate:
- Request additional information;
- Request additional documents;
- Refuse onboarding;
- Reject a transaction;
- Delay a transaction;
- Cancel an order;
- Freeze funds or assets;
- Block withdrawals;
- Restrict account access;
- Reject a wallet;
- Disable a whitelisted wallet;
- Reduce limits;
- Increase monitoring;
- Suspend merchant access;
- Revoke a merchant link;
- Close an account;
- File reports;
- Cooperate with authorities;
- Take any action required by law, provider rules, or internal policy.
Coinsfly is not liable for delays or losses caused by lawful or reasonable compliance action.
34. Internal Escalation and Manual Review
Compliance alerts may be escalated internally to authorized personnel.
Manual review may be required for:
- High transaction amounts;
- Unusual activity;
- Failed verification;
- PEP match;
- Sanctions match;
- Wallet risk;
- Merchant disputes;
- Source of Funds issues;
- Chargebacks or recalls;
- Suspicious activity;
- Provider alerts;
- Law enforcement requests;
- Account limit changes.
Final decisions may be made by Coinsfly Compliance, MLRO, senior management, or other authorized roles according to internal policy.
35. Staff Training and Access Controls
Coinsfly provides compliance training to relevant staff, contractors, and authorized personnel.
Training may cover:
- AML/CTF obligations;
- Sanctions;
- KYC/KYB;
- Suspicious activity indicators;
- Wallet risk;
- Merchant risk;
- Escalation procedures;
- Confidentiality;
- Data protection;
- Fraud prevention;
- Security controls.
Access to compliance systems is restricted based on role and business need.
36. Independent Review and Policy Updates
Coinsfly may review and update this Policy periodically to reflect:
- Legal changes;
- FINTRAC guidance;
- Product changes;
- Provider changes;
- New assets or networks;
- New payment methods;
- Internal risk assessment;
- Compliance findings;
- Audit findings;
- Security events;
- Operational experience.
Coinsfly may conduct periodic compliance effectiveness reviews as required by law or internal governance.
37. Relationship with Other Policies
This Policy should be read together with:
- Terms & Conditions;
- Privacy Policy;
- Risk Disclosure;
- Refund & Cancellation Policy;
- Complaints Procedure;
- Law Enforcement Requests Policy;
- Our Fees page;
- Merchant Terms where applicable.
If there is a conflict between this Policy and the Terms & Conditions, the stricter compliance, AML, CTF, sanctions, or risk-control rule will apply, unless applicable law requires otherwise.
38. Contact Information
For compliance-related questions, contact:
Aurex Financial Technologies Inc., operating as Coinsfly
Attn: Compliance Department
Registered Office: 2-1130 Hachey Ave, Coquitlam, BC V3K 2H4, Canada
Compliance: compliance@coinsfly.org
Support: support@coinsfly.org
Legal: legal@coinsfly.org
39. Final Acknowledgment
By accessing or using Coinsfly, creating an account, completing verification, purchasing crypto, using card or wire payment methods, adding a wallet, requesting a withdrawal, using the merchant gateway, submitting documents, or confirming any transaction, you confirm that you have read, understood, and agreed to this AML, KYC & Sanctions Policy.