Compliance & AML Policy

Fortress Algo Incorporated, operating under the trade name Wiremi, is a corporation incorporated under the laws of Canada with Registry ID 4363756. We are licensed by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business (MSB) under License Number M23401666. This Compliance and Anti-Money Laundering (AML) Policy outlines our comprehensive approach to preventing financial crimes, including money laundering, terrorist financing, fraud, and other illicit activities.

As a licensed financial services provider operating across multiple jurisdictions, we recognize our critical role in the global effort to combat financial crime. We are committed to maintaining the highest standards of regulatory compliance and ethical business practices. Our compliance program is designed to detect, prevent, and report suspicious activities while ensuring that our services are not misused for illegal purposes.

This policy applies to all employees, officers, directors, contractors, and agents of Wiremi, as well as to all users of our services. We require strict adherence to this policy and related procedures, and we provide regular training to ensure that all personnel understand their compliance obligations. Failure to comply with this policy may result in disciplinary action, termination of employment or services, and referral to relevant authorities.

Customer Due Diligence (CDD) is the cornerstone of our compliance program. We are committed to knowing our customers and understanding their financial activities to detect and prevent misuse of our services. Our Know Your Customer (KYC) procedures are designed to verify the identity of all users, understand the nature and purpose of business relationships, and assess the risk profile of each customer.

Identity Verification

Before a customer can use our services, they must complete our identity verification process. For individual customers, this requires submission of a valid, government-issued photo identification document such as a passport, national identity card, or driver's license. We verify the authenticity of these documents using advanced document verification technology that checks for signs of tampering, forgery, or alteration. We also collect proof of address through documents such as utility bills, bank statements, or government correspondence dated within the last three months.

Biometric Verification

To ensure that the person opening an account is the same person whose identity documents have been submitted, we employ biometric verification technology. This includes selfie verification, where customers take a photograph of themselves that is compared against the photo on their identity document using facial recognition technology; and liveness detection, which ensures that the person is physically present during verification and that static images or videos are not being used fraudulently.

Enhanced Due Diligence (EDD)

For customers identified as higher risk, we apply Enhanced Due Diligence measures that go beyond our standard verification procedures. Factors that may trigger EDD include customers from high-risk jurisdictions as identified by FATF or our own risk assessment; Politically Exposed Persons (PEPs) and their close associates or family members; customers with unusual transaction patterns or unclear sources of wealth; complex business structures or beneficial ownership arrangements; and any other factors that suggest elevated money laundering or terrorist financing risk.

Source of Funds Verification

For higher-value transactions or higher-risk customers, we require verification of the source of funds. This may involve collecting documentation such as bank statements, employment records, business financial statements, sale contracts, inheritance documents, or other evidence that demonstrates the legitimate origin of the funds being transferred through our platform.

Ongoing Monitoring and Reviews

Customer due diligence is not a one-time event but an ongoing process. We continuously monitor customer activity and periodically review customer profiles to ensure that information remains current and accurate. Customers may be required to provide updated identification documents, confirm or update their personal information, and answer questions about changes in their circumstances. Risk assessments are updated based on transaction behavior and any new information that becomes available.

Economic sanctions are powerful tools used by governments and international organizations to combat terrorism, weapons proliferation, human rights abuses, and other threats to international peace and security. Compliance with applicable sanctions is a legal requirement and a cornerstone of our commitment to preventing financial crime.

Sanctions Lists We Screen Against

We screen all customers and transactions against multiple sanctions lists, including the United Nations Security Council Consolidated List, which includes individuals and entities subject to UN sanctions; the U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List (SDN List); the European Union Consolidated Sanctions List; the Canadian Consolidated Autonomous Sanctions List and the Regulations Establishing a List of Entities (Criminal Code); and other relevant national and international sanctions lists.

Screening Process

We employ automated screening systems that check all customers and transactions in real-time against applicable sanctions lists. Screening occurs at multiple points, including customer onboarding, before processing any transaction, and on an ongoing batch basis to catch any changes to sanctions lists. Our screening systems use sophisticated matching algorithms that account for name variations, transliterations, and common aliases to minimize both false positives and false negatives.

Handling of Matches

When a potential sanctions match is identified, the transaction or account is immediately frozen pending review by our compliance team. Our analysts conduct a thorough investigation to determine whether the match is a true positive or a false positive due to common names or other factors. If a match is confirmed as a true positive, we immediately block the transaction, freeze the account, and report the matter to relevant authorities as required by law.

Prohibited Jurisdictions

We do not provide services to customers located in countries subject to comprehensive sanctions, nor do we process transactions to or from such jurisdictions. The list of prohibited jurisdictions is reviewed and updated regularly based on changes to applicable sanctions programs. We also maintain heightened scrutiny for transactions involving jurisdictions identified by FATF as having strategic deficiencies in their AML/CTF frameworks.

Fraud prevention is a critical component of our compliance program. We are committed to protecting our customers, our business, and the integrity of the financial system from fraudulent activities. Our anti-fraud measures are designed to prevent, detect, and respond to a wide range of fraud types.

Types of Fraud We Protect Against

Our anti-fraud program addresses multiple categories of fraud, including account fraud involving the creation of accounts using stolen or synthetic identities, or the takeover of legitimate customer accounts; payment fraud including unauthorized transactions, stolen payment credentials, and chargeback fraud; identity theft where criminals use stolen personal information to access financial services; document fraud involving the submission of forged, altered, or counterfeit identity documents; and AML-related fraud such as the use of shell companies, nominees, or false documentation to disguise the origins or ownership of funds.

Prevention Mechanisms

We employ multiple layers of fraud prevention controls, starting with robust KYC verification using advanced document authentication and biometric verification technology. Our transaction monitoring systems analyze patterns in real-time to identify potentially fraudulent activity. We use device fingerprinting and behavioral analytics to detect anomalies that may indicate account compromise or synthetic identity fraud. Strong authentication measures, including multi-factor authentication and biometric login options, protect account access. All sensitive data is encrypted using industry-standard encryption protocols.

Fraud Detection and Response

When potential fraud is detected, our systems can automatically block suspicious transactions or accounts pending investigation. Our fraud investigation team conducts thorough reviews of flagged activity and takes appropriate action, which may include requiring additional verification, blocking transactions, suspending or terminating accounts, recovering funds where possible, and reporting confirmed fraud to law enforcement.

Customer Protection

We are committed to protecting our customers from becoming victims of fraud. This includes educating customers about common fraud schemes and how to protect themselves, providing tools such as transaction alerts and account security settings, promptly investigating customer reports of unauthorized activity, and working to recover funds in cases where customers have been defrauded.

Comprehensive record keeping is a legal requirement and an essential component of our compliance program. We maintain detailed records of all customer information, transactions, and compliance activities in accordance with the PCMLTFA and other applicable regulations.

Types of Records Maintained

We maintain comprehensive records including customer identification documents and verification results; transaction records including date, amount, currency, sender and recipient information, and purpose of transaction; copies of all reports filed with FINTRAC and other regulatory bodies; documentation of compliance reviews, risk assessments, and investigations; training records for all employees who handle compliance responsibilities; and correspondence related to customer accounts and compliance matters.

Retention Periods

In accordance with Canadian regulations, we retain all required records for a minimum of five years from the date of the transaction or the date the business relationship ends, whichever is later. Certain records may be retained for longer periods if required by other applicable laws or regulations, or if we determine that longer retention is appropriate for risk management purposes.

Secure Storage and Access

All records are stored securely using encryption and access controls that limit access to authorized personnel only. We maintain both electronic and, where required, physical copies of essential records. All records must be readily accessible and producible to FINTRAC or other regulatory authorities upon request. We have procedures in place to ensure that records can be retrieved and provided within the timeframes required by law.

Prompt reporting of suspicious activity is critical for effective compliance and for supporting law enforcement efforts to combat financial crime. We have established clear procedures for internal and external reporting of suspicious activity.

Internal Reporting by Employees

All employees are required to report any suspicious activity or concerns to the compliance team immediately. Reports can be made through our internal reporting system, by email to our compliance department, or through our anonymous whistleblower hotline for those who prefer to report concerns confidentially. Employees are protected from retaliation for good-faith reporting of compliance concerns.

Customer Reporting

Customers who observe or experience suspicious activity, including potential fraud or scams, should report it to us immediately. Reports can be made through our in-app "Report Fraud" feature, which provides a direct channel to our compliance and fraud teams, by contacting our customer support team via phone, email, or chat, or by emailing our compliance department directly.

External Reporting to Authorities

When required by law or when we believe it is appropriate, we file reports with FINTRAC and other relevant authorities. These reports include Suspicious Transaction Reports (STRs), Large Cash Transaction Reports (LCTRs), Electronic Funds Transfer Reports (EFTRs), and Terrorist Property Reports. We cooperate fully with law enforcement investigations and respond promptly to lawful requests for information.

Confidentiality and Non-Disclosure

In accordance with the tipping off provisions of the PCMLTFA and similar laws in other jurisdictions, we are prohibited from disclosing to customers or any other unauthorized person that a suspicious transaction report has been or will be filed, or that related information has been provided to law enforcement. Violation of this prohibition is a criminal offense.