Anti-Money-Laundering & Counter-Terrorist-Financing Policy

BELEM Blockchain Technology Co., Ltd. ("BELEM") is committed to the highest standards of anti-money-laundering (AML) and counter-terrorist-financing (CTF) compliance. As a Money Services Business registered with FINTRAC (registration number M23331281), BELEM maintains a documented compliance programme designed to detect, deter, and report financial crime.

1. Legal framework

Our programme is built to comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations, and is aligned with the standards of the Financial Action Task Force (FATF), the EU Anti-Money-Laundering Directives, and the FATF Travel Rule for virtual asset service providers.

2. The five pillars of our programme

1. Compliance Officer. BELEM has appointed a designated Compliance Officer with authority and independence to administer and enforce the AML/CTF programme.
2. Written policies and procedures. Documented, board- approved policies governing client onboarding, monitoring, reporting, and record-keeping, reviewed and updated regularly.
3. Risk assessment. A documented assessment of money- laundering and terrorist-financing risk across our products, clients, delivery channels, and geographies, with risk-based mitigation.
4. Ongoing training. A continuing training programme for all staff and agents involved in client-facing or transaction-handling roles.
5. Independent review. An effectiveness review of the programme conducted at least once every two years, as required by the PCMLTFA.

3. Client identification (KYC) and due diligence

Every client must complete identity verification before transacting. We apply a risk-based approach to customer due diligence (CDD) and enhanced due diligence (EDD) for higher-risk clients, including politically exposed persons (PEPs), heads of international organisations, and their associates. Full document requirements are set out in our KYC & AML Verification policy.

4. Sanctions screening

All clients and counterparties are screened at onboarding and on an ongoing basis against consolidated sanctions and watch lists, including those maintained by the United Nations, OFAC (United States), the European Union, HM Treasury (United Kingdom), and Canadian sanctions instruments. BELEM does not onboard or transact with sanctioned persons or residents of sanctioned jurisdictions.

5. Transaction monitoring & blockchain analytics

BELEM applies continuous, risk-based transaction monitoring and uses blockchain analytics tooling to assess the provenance of digital assets, screen wallet addresses, and identify exposure to illicit sources such as darknet markets, mixers, ransomware, and sanctioned entities. Transactions that fail risk thresholds are held for manual review.

6. Reporting obligations

In accordance with the PCMLTFA, BELEM files the following reports with FINTRAC where applicable:

• Suspicious Transaction Reports (STRs) where there are reasonable grounds to suspect a transaction is related to money laundering or terrorist financing.
• Large Cash Transaction Reports (LCTRs) and Large Virtual Currency Transaction Reports (LVCTRs) at or above the prescribed thresholds.
• Terrorist Property Reports where required.

Where the law requires it, BELEM does not "tip off" clients about reports filed or investigations underway.

7. Record-keeping

BELEM retains client identification, account, and transaction records for a minimum of five years from the end of the client relationship or the date of the transaction, as required under the PCMLTFA.

8. Travel Rule

For qualifying virtual-currency and electronic-funds transfers, BELEM collects, retains, and where required transmits originator and beneficiary information in accordance with the FATF Travel Rule and applicable regulations.

9. Prohibited activity

BELEM strictly prohibits the use of its platform for money laundering, terrorist financing, sanctions evasion, fraud, market manipulation, or any other unlawful purpose. We reserve the right to freeze, restrict, or close any account and to decline, hold, or reverse any transaction where required by law or by our risk assessment.

10. Contact the Compliance Officer

Compliance Officer: verification@belem-services.com
General support: Support@belem-services.com