NFR Innovation Inc.
Anti-Money Laundering (AML) and Know Your Counterparty (KYC) Procedure

Updated: January 2025

1. Anti-Money Laundering (AML) Policy Statement

NFR Innovation Inc. commits to not engaging in or contributing to money laundering or the finance of terrorism. The company has implemented Know Your Counterparty (KYC) procedures to:

1. Establish the identity of all suppliers and customers;
2. Verify that counterparties and, if applicable, beneficial owners are not named on relevant government lists for individuals or organisations implicated in money laundering, fraud or involvement with prohibited organisations and/or those financing conflict;
3. Maintain an understanding of the nature and legitimacy of the businesses operated by counterparties and;
4. Monitor transactions for unusual or suspicious activity.

For the purpose of this policy and related procedures, money laundering is defined as a process of disguising the financial proceeds of crime to conceal their illegal origin. Finance of terrorism is defined as is any kind of financial support to those who attempt to encourage, plan or engage in terrorism.

2. AML Compliance officer and duties

NFR Innovation Inc. designates Dylan Dix as the Anti-Money Laundering Program Compliance Officer (AMLCO), with full responsibility for its Anti-Money Laundering Program. The AMLCO will ensure:

1. The AML Program is implemented effectively;
2. The AML Program is updated, as necessary; and,
3. Appropriate persons are educated and properly trained.

3. Sharing information with law enforcement agencies

We will respond to any requests from relevant law enforcement agencies about accounts or transactions by immediately searching our records to determine whether we maintain or have maintained any account for or have engaged in any transaction with each individual, entity, or organisation named in the request. Upon receiving an information request, the AMLCO will be responsible for responding to such requests.

4. Checking counterparties against relevant watchlists

Before conducting business with any new suppliers or customers, we will check to ensure that such counterparties are not listed on The Consolidated Canadian Autonomous Sanctions List.

If we determine a prospective counterparty or someone with or for whom the counterparty is transacting is on the list, we will immediately terminate any further dealings with the individual or entity in question.

5. Counterparty identification and verification

We require all new and existing counterparties to verify their identity. This may include personal identity documents for individuals (including copies of passports or national ID cards) and business licences or company registration/tax ID numbers for companies.

6. Other KYC information

Prior to entering into any business relationship, we will collect the following information from all counterparties:

• Name of counterparty (company/organisation/individual).
• Registered address.
• Contact person and information.
• Business registration number.
• Beneficial owners.
• Copies of relevant policies (AML/KYC policy, supply chain policy).

7. Counterparties that refuse to provide information

If a potential or existing counterparty refuses to provide the information described above when requested or appears to have intentionally provided misleading information, NFR Innovation Inc. will immediately terminate any further dealings with the individual or company. In either case, the AML Compliance Officer will determine whether relevant law enforcement agencies should be notified.

8. Record keeping

We will maintain records of all identification and verification information in accordance with local applicable law.

9. Identifying red-flags

Based on the information provided by potential or actual counterparties, the following red flags will be used to signal possible money laundering or terrorist financing:

• Limited knowledge of the industry.
• Requests for unusual financial terms and conditions.
• Lack of established place of business or offices in an unusual location or high-risk jurisdiction.
• Proposals for a transaction that makes no sense.
• Use of unusual or distant banks.
• Use of non-bank financial institutions for no apparent legitimate business purpose.
• Frequent and unexplained changes in bank accounts or accounting personnel.
• Use of companies without any apparent legitimate fiscal, legal or commercial reason.
• Unusually complex organisational structure.
• Unexplained Involvement of third parties in transactions.
• Refusal to identify beneficial owners or controlling interests in cases where this would be commercially expected.
• Attempted anonymity by conducting ordinary business through accountants, lawyers or other intermediaries.
• Use of cash in a non-standard manner.

In cases where suspicious transactions are identified, these will be reported to the relevant law enforcement agency.

10. Review of AML procedures

NFR Innovation Inc. will review its AML and KYC procedures regularly to ensure they remain up to date-and fit for purpose.

 

The above is endorsed by Dylan Dix, Managing Director and Owner, NFR Innovation Inc.