MONEY TRANSFER SERVICES - TERMS AND CONDITIONS OF USE - Canada
Issue Date: January 1, 2018
The following e-debit money Inc. ("E-Debit Money") Money Transfer Services Terms and Conditions is an agreement between the e-debit money customer either Sender or Receiver and e-debit money Inc. ("e-debit money") and applies to your use of e-debit money products and services and any other e-debit money features, technologies, and/or functionalities offered by e-debit money on our website or through any other means (the "e-debit money Services"). The E-Debit Money Services are provided to you subject to your compliance and adherence to the following Terms and Conditions as well as our Privacy Statement and is incorporated in this Agreement by this reference. Additional information regarding the Services may be obtained at www.e-debitmoney.ca.
An E-Debit Money customer (the "Sender") may send a Money Transfer to a designated receiver (the "Receiver") anywhere in Canada where E-Debit Money offers its services over the Internet and at site payout and sales locations (the "Service") using an E-Debit Money branded debit card. Money Transfers will be paid to the Receiver in cash, at selected Canadian sales and payout locations via the E-Debit Money Debit Card subject to currency availability and the conditions applicable to the selected payment location.
For added security and protection of the Sender and Receiver certain additional Question Verification or Personal Identification Numbers ("PIN") are required to be provided for some or all Money Transfers, and in those circumstances, the Receiver may be required to provide either proper identification or the correct answer to the Verification Questions, PIN utilization, or both, to receive payment.
E-Debit Money reserves the right to limit the principal amount of a Money Transfer or to decline to accept or pay any Money Transfer that it or its agents determine in their sole discretion is deemed to violate any applicable law or E-Debit Money policy. You may contact E-Debit Money at the Customer Service telephone number listed below for current information regarding the conditions applicable to the service you have selected or your expected payment location.
E-Debit Money as a reporting entity of FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) Canada's financial intelligence Unit, at its sole discretion may determine any Money Transfer sent or received in Canada to be reported to federal, provincial, local and/or foreign authorities. In such determinations you will be required to provide E-Debit Money with certain information to allow us, among other things: to verify your identity; to receive appropriate Card authorization; and/or to complete the transaction. Please refer to E-Debit Money's Privacy Statement for information concerning e-debit money's use of this and other personal information.
FEES, PAYMENT AND CURRENCY EXCHANGE
Transfer Fees. In consideration for the use of the Service, Sender agrees to pay to e-debit money a fee for each Money Transfer initiated by the Sender at the applicable rate then in effect (the "Transfer Fee"). The applicable Transfer Fee for Sender transactions will be provided to you prior to your final authorization of the transaction, in addition to any applicable fees for additional services. All administration and fee for service charges will be subject to additional 5% GST, 7.5% QST or 13% HST as applicable, depending on the province from where the money transfer originated.
All payments will be made in Canadian currency.
Transfer fees and the principal amount are due and payable before E-Debit Money processes the transaction. You must pay for the Service with cash, credit card or Interac Card. If E-Debit Money does not receive authorization from the Card issuer, the transaction will not be processed and funds will not be transmitted to the Receiver. E-Debit Money assumes no liability for damages resulting from or arising out of non-payment of the Money Transfer by reason of non-receipt of authorization from the Card issuer.
In certain cases Principal refunds and cancellation of the money transfer can be made by the Sender at any time up until payment has been made to the Receiver or If Receiver rejects Sender funds. The transaction administration and related Tax charge fees will be charged by E-Debit Money to the sender and E-Debit Money may charge a fee to refund the principal amount back to the Sender.
Notification to the Receiver that the Money Transfer is available for pick up is offered in Canada destinations by various means including telephone, and internet message delivery. Supplemental messages may be included with domestic Money Transfers. With qualifying Services, Telephone Notification, Messenger Delivery and Supplemental Messages may be included for an additional fee, plus a 5% GST, 7.5% QST or 13% HST.
RESOLUTION OF DISPUTES
The Sender and Receiver understand acknowledge, agree and consent to the exclusive jurisdiction of the courts in Alberta without regard to conflicts of law rules; provided, however, if Sender's domicile or residence is in Quebec at the time of the transaction, the laws of Quebec shall govern.
Except for transactions originating from Quebec, or where otherwise prohibited by applicable law, unless the Sender opt out as set forth below, any dispute arising from or relating to this transaction shall be resolved by final and binding arbitration. The arbitrator shall also decide what is subject to arbitration. The arbitration will be administered by National Arbitration and Mediation ("NAM") under its Comprehensive Dispute Resolution Rules and Procedures, which are available at www.namadr.com/downloads.cfm or at 1-800-358-2550 and explain how to initiate arbitration. You will be responsible for up to $125 CAD of the administration fees. Any arbitration shall take place on an individual basis; class actions or arbitrations are not permitted. If any part of this paragraph is deemed invalid, it shall not invalidate the other parts. If NAM is unavailable, the parties or a court will select another arbitrator.
You may opt out of arbitration within 30 days after initiating a transaction by calling 1-800-325-6000. IF YOU DO NOT OPT OUT, YOU WILL WAIVE ANY RIGHT TO A TRIAL BY JURY OR JUDGE IN COURT AND ANY RIGHT TO PARTICIPATE IN A CLASS ACTION.
LIMITATIONS OF LIABILITY
IN NO EVENT SHALL E-DEBIT MONEY BE LIABLE FOR DAMAGES WHETHER CAUSED BY NEGLIGENCE ON THE PART OF ITS EMPLOYEES, SUPPLIERS OR AGENTS OR OTHERWISE, BEYOND THE SUM OF $250 (CAD) (in addition to refunding the transaction amount and related transaction and administration fees). IN NO EVENT SHALL E-DEBIT MONEY OR ITS AGENTS BE LIABLE FOR ANY INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES.
Sender and Receiver hereby acknowledges, understands and agrees they shall indemnify E-Debit Money and its Agents for all losses of any kind (including lawyers' fees on a solicitor and client basis) arising out of any Agreement breach by Sender or Receiver.
E-debit money and its agents reserve the right to decline to send or refuse to pay any money transfer that either of them determines in their sole discretion violates any applicable law or E-debit money Policy.
This Agreement, together with all items incorporated by reference, embodies the entire understanding among the parties. It supersedes all prior understandings and cannot be modified orally. E-Debit Money has the right to assign this Agreement to any party, at any time without Sender or Recipient consent.
If an Agreement provision is found invalid, remaining provisions shall be valid. Services are directed solely to persons 18 and over (or 19 and over in any jurisdiction where 18 is not the age of majority). The English language version controls if there is an inconsistency between English and non-English Agreement versions. The Sender and Receiver represent that their use of Services does not violate: (a) any law, including, without limit, laws relating to money laundering, illegal gambling activities, support for terrorist activities or fraud; and/or (b) this Agreement. Information provided to E-Debit Money shall be truthful and complete. E-Debit Money reserves the right to change Services without notice.
E-Debit Money reserves the right to withdraw or amend the Sites, and any service or material E-Debit Money provides on the Site, in our sole discretion without notice. E-Debit Money will not be liable if for any reason all or any part of the Sites are unavailable at any time or for any period. From time to time, we may restrict access to some parts of the Sites, or the entire Sites, to users, including registered users. You are responsible for making all arrangements necessary
#12, 3620 - 29th Street NE.
Calgary, Alberta T1Y 5Z8
E-Debit Money and our Agents collect Personal Information about the Sender and the Receiver from the Sender's Service transactions and, where permitted or required by law, from other sources ("Personal Information"), as explained in the E-Debit Money Inc. Privacy Statement ("Statement"). TO REVIEW SEE THE PRIVACY STATEMENT IN THE POLICY SECTION AT www.e-debitmoney.ca
E-Debit Money and our Agents collect and use Personal Information to: (i) authorize and process Service transactions, (ii) to manage our business, including the detection and prevention of fraud and other illegal activity, (iii) provide customer service and (iv) for other purposes set forth in the Statement. E-Debit Money may disclose the Information to: (i) the Receiver, (ii) our Agents, as may be necessary to process and complete your Service transaction, (iv) law enforcement and other governmental authorities to prevent, detect and investigate fraud or other illegal activity, as permitted or required by law, and (v) as otherwise described in the Statement. With your consent, we may use and disclose your contact information to our affiliates and third parties to allow us, and them, to send you offers, promotions or information about additional products and services which may be of interest to you (for example, special offers or services from E-Debit Money, financial institutions and service companies, such as banks, credit card companies, insurance companies and brokerage houses; retailers, such as home furnishers, clothing stores and florists; catalogue companies; direct marketers; affiliated companies that offer financial services; and other non-affiliated companies with which E-Debit Money has joint marketing agreements) (collectively, "Marketing Purposes".
YOU MAY WITHDRAW YOUR CONSENT (OPT OUT FROM) THE USE AND DISCLOSURE OF PERSONAL INFORMATION FOR MARKETING PURPOSES BY REQUEST AT firstname.lastname@example.org OR CALLING 780-276-2221.
NOTE: In the event there is any inconsistency between the English version of the www.e-debit money.ca web site and the French version, the English version shall be binding.
PRIVACY STATEMENT - Canada
Last Updated: January 1, 2018
This Privacy Statement describes how E-Debit Money Inc. ("E-Debit Money", "we", " us" and "our") collects, uses and discloses your personal information.
"Personal information" is information about an identifiable individual, as more particularly defined or limited under applicable Canadian privacy legislation. This Privacy Statement applies to our collection, use and disclosure of personal information about our consumer and business customers and other individuals we deal with in Canada (" you" and "your"). This Privacy Statement does not apply to information that is not personal information.
INFORMATION WE COLLECT
E-Debit Money as a reporting entity of FINTRAC (Financial Transactions and Reports Analysis Centre of Canada) Canada's financial intelligence Unit collects personal information about you from a variety of sources in the course of providing money transfer and payment services and related products and services E-Debit Money provides. Personal information we collect and the sources of such personal information include the following:
E-Debit Money is committed to providing a safe, secure money transfer and financial payment services. Therefore, before permitting you to use our Services, we may require additional information from you in order to verify your identity, address or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.
HOW WE USE PERSONAL INFORMATION
E-Debit Money generally uses personal information in the course of its money transfer, payment and related services and products for the following purposes:
E-Debit Money uses physical, technical, and administrative security measures to protect against loss, misuse, and alteration of personal information under our control and uses industry-standard practices and security measures to safeguard such personal information we collect.
Access to personal information is restricted to employees and service providers who need to have access to that information as described in this privacy statement, in accordance with applicable laws. Our service providers are required to observe standards for the security, collection, uses and sharing of personal information, and to comply with applicable law in the same manner as E-Debit Money.
Regardless of our efforts breaches of our administrative, managerial and technical safeguards can occur. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your E-Debit Money passwords and Personal Identification Numbers ("PIN") with anyone.
INFORMATION WE DISCLOSE
We may disclose your personal information to our affiliates and to unaffiliated third parties in connection with the purposes described in this Privacy Statement as follows:
OFFERS, PROMOTIONS AND OPTING OUT
E-Debit Money may use your contact details and information about your use of our services (e.g. frequency, value of money transfer, or destination country) for marketing and solicitation purposes to send you offers, promotions or information about additional products and services of E-Debit Money and our affiliates that may be of interest to you. In addition, E-Debit Money may disclose your contact details to third parties to permit those organizations to offer and provide information about their products and services that may interest you. These third parties may include, as examples:
You may "opt out" or withdraw consent to the use and/or disclosure of your personal information for the purposes described in this section at any time by checking the appropriate box on an online or offline form, if available, or by calling 1-800-000-0000 or 1-276-2221 or otherwise by contacting us as described in "Contact Us" below. If you do not "opt out" or withdraw your consent as described above, we will assume that you consent to our use and disclosure of your personal information for marketing and solicitation purposes as described in this section.
When you visit our website or use one of our mobile applications, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect certain geo-location information. If you do not agree to our collection of this information, you may not be able to use our Service.
Some of E-Debit Money services (for example money transfers) are made available using online forms at our Web site, www.E-Debit Money.ca. Personal information you provide on online forms or by other electronic means will be collected used and disclosed as described generally in this Privacy Statement.
In addition, when you visit or use our Web sites, we collect information about the domain and host from which you access the Internet; your computer's Internet address; the browser and operating system software you use; the date and time you access our Web site and the Internet address of the site from which you linked to our Web site when you visit us. We use this information to diagnose, administer and optimize our Web sites and web-related services.
When registering or creating an account at our Web sites, we collect your
password and login name and other information we may request in order to
identify you, maintain security of our Web site and verify and control
access to your account or online profile. If you make inquiries through the
e-mail links, forms or other contact methods provided on our Web sites,
these inquiries are forwarded to the relevant office or department, and are
used to respond to your inquiry and maintain a record of correspondence.
We use Internet technologies like cookies and web beacons to facilitate the services we provide on our Web sites and your use of our Web sites, including:
A "cookie" is a text file placed on your computer's hard drive by a web server, which allows for personalization of certain aspects of your visit to that Web site. "Web beacons" are transparent electronic images placed in the web code that collect non-personal data while visiting a web site. Cookies and web beacons can usually be disabled by changing your browser preferences. Your browser usually has documentation on how to disable cookies and web beacons. Note that disabling cookies may limit the performance of E-Debit Money's Web sites. If cookies are disabled, certain features of our Web sites may not function properly, and you may not be able to register or use your online account.
Our Web sites are not directed at children under the age of 18. E-Debit Money does not knowingly collect or maintain personal information at our Web site from those we actually know are under the age of 18.
Our Web sites may be linked to or from third party Web sites. These links are provided as a convenience only, and E-Debit Money is not responsible for the content or privacy practices of Web sites that are linked to or from our Web site. You are advised to review the privacy policies of any third party Web sites you visit.
Generally, by providing us with personal information, we will assume that
you consent to our collection, use and disclosure of such information for
the purposes described in this Privacy Statement, if applicable, or
otherwise at the time of collection of your personal information.
Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an "opt out" option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney).
You may withdraw your consent to our collection, use and disclosure of
personal information at any time, subject to contractual and legal
restrictions and reasonable notice. Note that if you withdraw your consent
to certain uses of your personal information, we may no longer be able to
provide certain of our products or services. Note also that where we have
provided or are providing services to you, your consent will be valid for
so long as necessary to fulfil the purposes described in this Privacy
Statement or otherwise at the time of collection, and you may not be
permitted to withdraw consent to certain necessary uses and disclosures
(for example, but not limited to, maintaining reasonable business and
transaction records, disclosures to Canadian and foreign government
entities as required to comply with laws, and reporting on credit
information after credit has been granted, if applicable).
We may also be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
CONFIDENTIALITY AND SECURITY
We endeavor to maintain physical, electronic and procedural safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Authorized employees, agents, representatives and mandataries that require access to your personal information in order to fulfill their job requirements will have access to your personal information.
No data transmission over the Internet or the telephone can be guaranteed
to be perfectly secure, and any personal information you submit to us or
access electronically or over the telephone is done at your own risk, and
E-Debit Money does not guarantee or warrant the security of information
transmitted in these manners. You should be aware that third parties may
unlawfully intercept your transmissions or may wrongly instruct you to
disclose personal information to them while posing as E-Debit Money and you
should exercise caution when providing personal information to any person.
E-Debit Money record retention policies dictate that we maintain information about you, including your opt-out choices, for a fixed time period. If you do not perform another transaction during the fixed time period, your Information, as well as your opt-out choice will be removed. If you perform another transaction or otherwise provide us with personal information thereafter, you will be afforded another opportunity to opt-out.
ACCESS AND CORRECTION
E-Debit Money may establish and maintain a file of your personal information for the purposes described in this Privacy Statement, which will be accessible at the office of our affiliate, Group Link Inc. at #12, 3620 - 29th Street N.E., Calgary, Alberta Canada.
If you wish to request access or correction of your personal information in our custody or control, you may write to the mailing address provided below, attention FINTRAC compliance and privacy officer. Your right to access or correct your personal information is subject to applicable legal restrictions. To protect your privacy and security, we may require additional information to verify your identity when requesting access or correction. NOTE: A RECORD OF THE PRE CHANGE INFORMATION WILL BE RETAINED AFTER THE REQUESTED CHANGES ARE MADE TO YOUR PERSONAL INFORMATION.
E-Debit Money reserves the right to modify this Privacy Statement from time to time. You can get updated Privacy Statements by calling us at the telephone number listed above or by visiting our Web site at www.e-debitmoney.ca.
We urge you to review this Privacy Statement frequently to obtain the current version. Your continued provision of personal information or use of our services following any changes to this Privacy Statement constitutes your acceptance of any such changes.
To provide your personal choice or to change account information go to the profile page of www.E-Debit Money.ca.
Question or requests can be made by regular mail and by telephone at the locations outlined below:
E-Debit Money Inc.
E-Debit Money Inc. Complaisance Office
#12, 3620 - 29th Street NE.
Calgary, Alberta T1Y 5Z8
E-Debit Money Inc. POLICY STATEMENT - ANTI ‐ MONEY LAUNDERING/ANTI ‐ TERRORIST FINANCING AND SANCTIONS
E-Debit Money Inc. is committed to sustaining a secure Money Service/Transfer Business with its' inclusive financial reporting system in Canada and those countries globally where we are engaged. E-Debit Money Inc. takes all necessary action as set out by FINTRAC, using a risk-based approach, to deter and detect the use of its products, services and delivery channels for illegal purposes, and to comply with the anti-money laundering (AML), anti-terrorist financing (ATF) and sanctions laws to which it is subject.
In furtherance of this commitment, E-Debit Money Inc. has established a corporate wide AML/ATF and Sanctions Compliance Program (the "Program") as the key vehicle for effective control over money laundering (ML), terrorist financing (TF) and sanctions risks in all relevant areas of its business network.
The E-Debit Money Inc. President and Chief Executive Officer is designated the Chief AML Officer (CAMLO) and is accountable for the design, development, implementation and maintenance of the Program.
The key elements of the Program are set out below:
ANTI- MONEY LAUNDERING (AML) - ANTI-TERRORIST FINANCING (ATF) - KNOW YOUR CUSTOMER/CLIENT POLICY STATEMENT - Canada
Summary of Canadian E-debit money Inc. Anti-Money Laundering (AML), Anti-Terrorist Financing (ATF) and Know your Client Policy Statement
The E-Debit Money Inc. ("E-Debit Money") policies and procedures comply with all requirements under the following legislation; the Proceeds of Crime (Money Laundering) and Terrorist Financing Act of Canada (PCMLTFA), and Regulations, the Anti-Terrorist Act, the United Nations Suppression of Terrorism Regulations and the Canadian Criminal Code. FINTRAC  (the "Act") has developed guidelines to detect and deter money laundering and terrorist financing. E-Debit Money's policy is to ensure proper adherence to the provisions and intent of the FINTRAC regarding the requirement to implement reasonable procedures to deter money laundering activities and actively search for suspicious activity. The AML Officer is responsible for reviewing any such activity and determining whether a Suspicious Activity Report (SAR) should be filed.
As such, it is the authority, basis and platform for the development, communication, implementation, interpretation and enforcement of appropriate and applicable operating procedures that follow in this section.
In general, the E-Debit Money's Anti-Money Laundering Program (AML Program) is a risk based process that is imbedded within the internal controls of the E-Debit Money. It is the responsibility of the Board of Directors and Senior Management to ensure that the E-Debit Money maintains this effective internal control structure, including suspicious activity monitoring and reporting.
E-Debit Money's AML Program is based upon the:
The President and CEO of E-Debit Money Inc. ("E-Debit Money") acts as the Director, Corporate Security and Chief Anti-Money Laundering Compliance Officer for E-Debit Money and is responsible for oversight of those designated employees who oversee AML/ATF compliance ("The Compliance Group") of E-Debit Money and our corporate affiliations. The Compliance Group is responsible for the development and application of AML/ATF compliance policies and procedures to detect and deter Money Laundering and Terrorist Financing activities, to review these policies on a regular basis to test their effectiveness and for the implementation of ongoing AML/ATF training for employees. The Group verifies and ascertains the identity of all individuals who open up an account and requires government issued recordable identification to satisfy legislative requirements.
E-Debit Money's Anti-Money Laundering Compliance Group is in continuous development of policies, guidelines, training and risk-assessment tools to meet and expand on national and international requirements to help E-Debit Money and its' employees deal with ever-evolving money laundering and terrorism financing risks. E-Debit Money has implemented robust automated systems and analytical processes to detect, track and assess transactions for suspicious activities to assist enforcement agencies to identify criminal and terrorist money laundering activity.
E-Debit Money Inc. is a money remitter and can be classified as aMoney Services Business (MSB) and/or Money Transfer Organization (MTO) and be generally defined as:
A person or company that receives or sends money, either in cash, check or other monetary Instrument, both from within his or her country or to and from any other country via wire, fax, message system or electronic transfer. Any business that does money transfers, regardless of its main business objective, is always considered an MSB.
Money laundering is the attempt to conceal or disguise the nature, location, source, ownership or control of illegally obtained money. Money laundering is illegal.
There are three stages to Money Laundering:
Placement, Layering, and Integration
Structure of Accountability
Risk Analysis and Assessment
As part of its AML Program, E-Debit Money continually conducts risk analysis to identify specific criteria of potential money laundering risks. This risk based approach includes the identification of the money laundering and terrorist financing risks (to the extent that such terrorist financing risk can be identified) of customers, categories of customers, and transactions that allow the E-Debit Money to determine and implement proportionate measures and controls to mitigate these risks.
The E-Debit Money measures money laundering and terrorist financing risks using the following categories. The application of risk categories provides a strategy for managing potential risks by enabling the E-Debit Money to subject customers to proportionate controls and oversight. The weight given to these risk categories (individually or in combination) in assessing the overall risk of potential money laundering may vary depending on the E-Debit Money's unique circumstances.
Country risk, in conjunction with other risk factors, provides useful information as to potential money laundering and terrorist financing risks. Factors that may result in a determination that a country poses a higher risk include: Countries subject to sanctions, embargoes or similar measures issued by the United Nations ("UN") as an example. In addition, some circumstances subject countries to sanctions or measures similar to those issued by bodies such as the UN, but which may not be universally recognized, may be given credence by the E-Debit Money because of the standing of the issuer and the nature of the measures and
E-Debit Money at its sole determination may deny any transaction to any country that does not have effective AML laws and regulations and are viewed as unacceptable higher risk.
Determining the potential money laundering or terrorist financing risks (to the extent that such terrorist financing risk can be identified) posed by a customer or category of customers is a critical component. E-Debit Money at its sole determination and based on its own criteria may determine whether a particular customer poses a high risk. Categories of customers whose activities may indicate a higher risk include:
This category of risk includes the determination of potential risks presented products and services offered by the E-Debit Money, such as risks associated with new or innovative products or services.
The E-Debit Money's risk based approach methodology may take into account risk variables specific to a particular customer or transaction. These variables may increase or decrease the perceived risk posed by a particular customer or transaction and may include the:
While risk assessments are routinely performed at the inception of a customer relationship, for some customers a comprehensive risk profile may only become evident once the customer has begun making transacting through an account. Thus, the monitoring of customer transactions and ongoing reviews is a fundamental component of the E-Debit Money's risk based approach.
The Compliance Group shall conduct ongoing risk assessment reviews to determine all areas of the E-Debit Money where money laundering or terrorist financing may be created. On an annual basis a certified third party MSB auditor shall conduct a comprehensive review of the E-Debit Money AML/ATF compliance policies and procedures and make a written report to the Board of Directors with respect to its' program guidelines, procedures and reporting.
Risk Assessment reviews
All risk assessment reviews shall include:
Risk Mitigation Strategies
The E-Debit Money has implemented the following risk mitigation strategies:
Customer Identification, Due Diligence and Know Your Customer.
E-Debit Money has implemented a stringent Know Your Customer ("KYC") to enable personnel to form a reasonable belief that it knows the true identity of each customer and, with an appropriate degree of confidence, knows the types of transactions the customer is likely to undertake. In general, this program:
Suspicious Transaction Reporting.
The regulatory and legal requirement to report suspicious transactions or activity by E-Debit Money provides federal authorities the ability to utilize such financial information to combat money laundering, terrorist financing and other financial crimes. When a legal or regulatory requirement mandates the reporting of suspicious activity once a suspicion has been formed, a report must be made by the E-Debit Money.
Money Laundering and Terrorist Financing Red Flags
The following are examples of potentially suspicious activities, or "red flags" for both money laundering and terrorist financing. Although these lists are not all inclusive, they are designed to help E-Debit Money personnel to recognize possible money laundering and terrorist financing schemes. However, it is the responsibility of E-Debit Money personnel to report suspicious activities, rather than to determine whether transactions are in fact linked to money laundering, terrorist financing, or a particular crime. The mere presence of a red flag is not by itself evidence of criminal activity. E-Debit Money personnel are to use closer scrutiny to help determine whether the activity is suspicious or one for which there does not appear to be a reasonable business or legal purpose.
Customers Who Provide Insufficient or Suspicious Information.
Efforts to Avoid Reporting or Recordkeeping Requirements.
E-Debit Money Employee Red Flags
Detection and Monitoring Procedures
The E-Debit Money follows these policies and procedures that are implemented for the detection and prevention of money laundering activities as part of the E-Debit Money's AML Program:
E-Debit Money procedures for compliance are as follows:
Record Search Procedures. Upon receiving an information request from FINTRAC as described above, the Compliance Group is to search the E-Debit Money's records to determine whether E-Debit Money maintains or has maintained any account for, or has engaged in any transaction with, each individual, entity, or organization named in FINTRAC's request.
The Director, Corporate Security and Chief Anti-Money Laundering Compliance Officer is the point of contact for the E-Debit Money for such investigative issues or similar requests for information from FINTRAC.
It is against E-Debit Money policy to use information provided by FINTRAC in an investigation for any purpose other than:
Additionally, E-Debit Money may not disclose to any person, other than FINTRAC or the Federal law enforcement agency on whose behalf FINTRAC is requesting information, the fact that FINTRAC has requested or has obtained information under this section, except to the extent necessary to comply with such an information request. However, the E-Debit Money is authorized to share information concerning an individual, entity, or organization named in a request from FINTRAC in accordance with this policy. Such sharing shall not disclose the fact that FINTRAC has requested information concerning such individual, E-Debit Money entity, or organization that FINTRAC requires more detail and documents. It is the policy of the E-Debit Money to maintain adequate procedures to protect the security and confidentiality of requests from FINTRAC.
It is against E-Debit Money policy to take any action, or to decline to take any action, with respect to an account established for, or a transaction engaged in with, an individual, entity, or organization named in a request from FINTRAC, or to decline to establish an account for, or to engage in a transaction with, any such individual, entity, or organization. Except as otherwise provided in an information request, such a request shall not require E-Debit Money to report on future account opening activity or transactions or to treat a suspect list received as described by the regulation.
In order for E-Debit Money to comply with its FINTRAC and AML reporting requirements E-Debit Money, under the protection of the safe harbor from liability, may receive, or otherwise share information with any other financial association regarding individuals, entities, organizations, and countries for purposes of identifying and, where appropriate, reporting activities that the individuals suspects may involve possible terrorist activity or money laundering.
The following policy apply:
It is against E-Debit Money policy for information received from another financial institution be used for any purpose other than:
If the E-Debit Money shares information with another financial institution it is protected from liability for such sharing, or for any failure to provide notice of such sharing, to an individual, entity, or organization that is identified in such sharing, to the full extent provided by law.
If, as a result of information shared by the E-Debit Money, and E-Debit Money knows, suspects, or has reason to suspect that an individual, entity, or organization is involved in, or may be involved in terrorist activity or money laundering, and the E-Debit Money is subject to a suspicious activity reporting, the Director, Corporate Security and Chief Anti-Money Laundering Compliance Officer will file a Suspicious Activity Report. In situations involving violations requiring immediate attention, such as when reportable violation involves terrorist activity or is ongoing, the Director, Corporate Security and Chief Anti-Money Laundering Compliance Officer will immediately notify, by telephone, an appropriate law enforcement authority and Senior in addition to filing a Suspicious Activity Report.
It is the intent and policy of the E-Debit Money to have a clear and concise understanding of all customer practices in order to avoid criminal exposure by any "customer" who would use the E-Debit Money's resources for illicit purposes. The objective of this policy is to ensure the immediate detection and identification of suspicious activity.
The President and CEO of E-Debit Money Inc. ("E-Debit Money") acts as the Director, Corporate Security and Chief Anti-Money Laundering Compliance Officer for E-Debit Money and is responsible for oversight of those designated employees who oversee AML/ATF compliance ("The Compliance Group") of E-Debit Money and our corporate affiliations.
The responsibility of the Director, Corporate Security and Chief Anti-Money Laundering Compliance Officer
is to ascertain that E-Debit Money policy is in compliance with the current laws and regulations, and that the policy is communicated to the appropriate employees, agents and affiliate agencies.
All employees and agents have been provided with a copy of this policy. All new employees and agents will be provided with a copy of this policy at their time of hiring. It will be the responsibility of the Compliance Group to provide ongoing training regarding this policy and the procedures for compliance.
Douglas N. Mac Donald, President and CEO
On behalf of the Board
E-Debit Money Inc.
For more information: Reference materials
CONSENT TO RECEIVE ELECTRONIC DISCLOSURES - Canada
Issue Date: January 1, 2018
This Consent Statement describes how E-Debit Money Inc. ("E-Debit Money", "we", " us" and "our") delivers disclosures, notices, statements and other communications
(collectively, "Disclosures") from E-Debit Money relating to your eligible E-Debit Money accounts ("Account(s)") electronically by any of the following means:
Delivery by any of these means will constitute proper notice to you under applicable law. You acknowledge that Disclosures will include, but may not be limited to, the following:
YOUR RIGHT TO REVOKE CONSENT
Your consent is effective until further notice by us or until you revoke your consent to receive electronic Disclosures. You may revoke your consent to receive electronic Disclosures at any time either by clicking the "Contact Us" button on our website or submitting your request in writing to: FINTRAC compliance and privacy officer - E-Debit Money Inc., #12, 3620 - 29th Street NE. Calgary, Alberta T1Y 5Z8 Canada
If you do not consent or if you withdraw your consent, we reserve the right to refuse to accept your Account application, to cancel your Account, place your Account on inactive status, or to provide a paper copy of Disclosures.
If you request a paper copy of a Disclosure within 180 days of the date of the Disclosure and we elect to send you a paper copy, we will waive our standard Disclosure Request Fee for the first two requests. After that, any additional Disclosure Requests may be subject to fees. We will only provide paper copies upon your request if your current mailing address is in your Account profile.
In order to receive Disclosures, whether by text or email, you need to have a means of printing or storing them. So, in addition to having and email address and phone number you must have the following:
We reserve the right to change these System Requirements and will provide you with a Disclosure when we make a material change to the System Requirements.
RECEIVING TEXTS AND EMAILS
In order to receive Disclosures, you must ensure that the primary mobile phone and/or email address that you provide us is your valid, current phone number or email address, and you are able to receive at that address texts or email messages containing Disclosures including attached electronic documents and that such Disclosures, including portions that are attached documents are available for viewing and storing or printing by you.
You agree to promptly update your email address by updating your Account profile if your email address changes.
You acknowledge that our ability to notify you of the availability of your Disclosures is contingent on the validity of mobile phone number and email address in our records. If your mobile phone or email address is no longer valid, we reserve the right to determine your Account is inactive or take other actions as set forth in the User Agreement. You will not be able to conduct any transactions in your Account until you update your mobile phone or email address in your Account profile.
RESERVATION OF RIGHTS
We reserve the right to provide you with any Disclosure in writing, rather than electronically, or to withdraw the right to receive Disclosures electronically at any time. You agree to maintain on file with us your current street address and to promptly update your address in the event it changes by updating your Account profile. Although we may waive our fee for delivery of paper Disclosures, we reserve the right to charge the Disclosure Request Fee and to increase this fee in our discretion.
We recommend that you print a copy of this Consent and any Disclosure that you view electronically for your records as the Disclosure may not be accessible online at a later date.
By clicking on the "I Agree" button below, which you adopt as your electronic signature, you agree that:
You understand and agree that we are responsible for sending the Disclosures to you electronically by email or text to the address in your Account profile or through the Service. We are not responsible for any delay or failure in your receipt of the email or text notices and whether or not you choose to view the Disclosure, subject to your right to revoke your consent to receive Disclosures electronically.
To provide your personal choice or to change account information go to theprofile page of www.e-debitmoney.ca.
Question or requests can be made by regular mail and by telephone at the locations outlined below:
E-Debit Money Inc.
E-Debit Money Inc. Office
#12, 3620 - 29th Street NE.
Calgary, Alberta T1Y 5Z8
 FINTRAC (Financial Transaction and Reports Analysis Centre of Canada) is responsible for investigation of money laundering and terrorist financing cases that are originating or destined for Canada. The financial intelligence unit was created by the amendment of the Proceeds of Crime (Money Laundering) Act in December 2001 (via Bill C-25) and created the Proceeds of Crime (Money Laundering) and Terrorist Financing Act . Financial institutions in Canada are required to track large cash transactions (daily total greater than CAD$10,000.00 or equivalent value in other currencies) that can be used to finance terrorist activities in and beyond Canada's borders and report them to FINTRAC. Review: http://www.fintrac-canafe.gc.ca/fintrac-canafe/antimltf-eng.asp
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