AML / CTF Statement

1. Our commitment and scope

CREDIUM DIGITAL LTD. maintains an anti-money laundering and counter-terrorist financing programme for its Canadian conversion service. It addresses money laundering, terrorist financing, sanctions evasion and related financial crime risks under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, its applicable regulations and other applicable Canadian requirements.

This is a public overview of our approach and the information customers may be asked to provide. Detailed operating procedures and confidential reporting controls are maintained internally. FINTRAC MSB registration N300001308 is not an endorsement or licence of the business.

2. Programme governance

Our programme includes a designated compliance function, written policies and procedures, a documented risk assessment, ongoing staff training, transaction monitoring, reporting and recordkeeping controls, and periodic effectiveness reviews. Management oversees the programme. Using an external verification or screening provider does not transfer Credium's responsibility for its own obligations.

3. Identity, businesses and beneficial ownership

We verify every customer before permitting a conversion, irrespective of the order value. Individuals provide reliable identity and contact information. Businesses provide evidence of their existence, business activities, ownership and control, together with information about directors, beneficial owners and authorised representatives. We verify a representative's authority and may request updated information during the relationship.

4. Same-owner accounts and wallets

Orders must be for the customer's own account. Fiat funding and payout accounts must be verified in that customer's legal name. Business customers use the business's accounts and wallets, not the personal accounts of directors or shareholders.

Private wallets are verified using a message-signing challenge or an approved method appropriate to the wallet. The challenge does not authorise spending. For accounts at other crypto institutions, we require evidence of ownership. We never ask for a seed phrase or private key. Third-party funding, payouts to unrelated persons, anonymous use and undisclosed intermediaries are not supported.

5. Risk assessment and ongoing checks

We screen relevant customers, controlling persons, representatives, accounts, wallets and transactions for sanctions and other financial crime indicators. Checks include politically exposed person and head-of-international-organisation exposure, relevant adverse information and blockchain activity where applicable.

We assess the customer, geography, product, delivery channel and transaction risk, apply enhanced checks where required and permitted by our admission policy, and monitor whether activity is consistent with the information provided. A request for more information does not mean that a customer has committed wrongdoing.

6. Source of funds and assets

We may request bank statements, purchase or sale records, transaction history, business documents or other proportionate evidence establishing ownership, the source of funds or assets, and the purpose of an order. Missing, inconsistent or unreliable evidence must be resolved before execution. We do not accept an incoming transfer as proof of ownership merely because it arrived.

7. Transfer information and Travel Rule

We obtain and transmit the originator and beneficiary information required for applicable transfers. Information is exchanged through approved secure channels with recipients entitled to receive it. Required identity information is not published on a public blockchain. A customer-owned private wallet does not remove the obligation to identify the relevant parties.

8. Holds, refusals, reporting and returns

We may request further information, apply limits, delay or refuse an order, or suspend a route where required by law or our risk policy. Sanctions restrictions and legal orders may prevent release or return. Unsolicited or unsupported receipts are reviewed and are not automatically sent to an unverified address or third party.

We make reports to FINTRAC and other competent authorities when required. Legal confidentiality restrictions may prevent us from disclosing whether a report has been made or explaining every aspect of a review. Where a return is lawful, it follows our published return policy and same-owner verification controls; the applicable costs and timing are described in Pricing and execution.

9. Records, privacy and providers

We retain the records required by law and our AML retention schedule, with periods and starting dates appropriate to each category. The Privacy Notice explains retention, provider disclosures, international processing, access and correction requests, and the privacy contact.

Sumsub and other relevant providers may support verification, screening or lawful information exchange. Information is shared only for an appropriate purpose and on a lawful basis, with access limited to the relevant role. The Canadian and Bulgarian companies maintain separate customer and AML records; a shared brand does not create automatic access.

10. Eligibility and customer responsibilities

Eligibility and financial crime controls

Individuals must be at least 18, meet any higher applicable age or legal-capacity requirement and transact for their own account. Businesses must be validly established, provide ownership and control information and act through authorised representatives.

We do not onboard residents of the EEA, the UK or the United States, or businesses established in those jurisdictions, for this Canadian service. Customers in Switzerland may be considered subject to applicable law, verification and our admission policy. Other countries, territories, customer categories and business activities may be restricted by law, sanctions or Credium's risk policy. Eligibility is assessed before a route is activated; this page is not an offer in every country outside the excluded regions.

We verify identity, ownership and source of funds or assets where required; screen sanctions and relevant risk indicators; monitor transactions; and obtain and transmit legally required transfer information. We may request additional evidence, impose customer-specific limits, reject an order or suspend access. Applicable customer limits are communicated in the platform. Internal risk thresholds are not published.

Third-party funding, third-party payouts, anonymous use and attempts to conceal the source or ownership of funds are not supported. A shareholder's or director's personal account is not the company's account.

Our Prohibited activities policy lists business categories and uses that are not accepted. These exclusions are mandatory; enhanced due diligence cannot override them.

Where required, information is reported to FINTRAC or other competent authorities. Some legal obligations restrict what we can tell a customer about a review or report. Compliance checks do not permit us to redirect funds to an unverified recipient.

Keep your information current, respond to reasonable verification requests and use only funds or assets you lawfully own and may transfer. Customer-specific limits are communicated in the platform. This statement does not publish internal monitoring thresholds or confidential reporting criteria.

11. Contact

For questions, contact support@credium.com with the subject “Compliance — Canada”, or use in-app livechat. Use the Complaints page for a formal complaint and the Privacy Notice for personal-data requests.