Commitment
EquityFX is committed to assisting governments combat the threat from money laundering and terrorist financing activities around the world. To that end we have put in place a Compliance Regime that addresses the requirements both of Canada's money laundering legislation, The Proceeds of Crime (Money Laundering) & Terrorist Financing Act, as well as the requirements in the United States under the Bank Secrecy Act and the U.S.A. Patriot Act.

"Know Your Client"
To a degree more than ever before, EquityFX is required to "know your client", including documenting and verifying client identification records, and tracking and maintaining detailed records of all transactions.
Currenyhouse is also now required to be sensitive to "suspicious activities", and "suspicious transactions" which must be reported to FinCEN (US) and to FinTRAC (Canada), and must be sensitive to terrorist financing activities of individuals, entities and countries identified by the United Nations and other national and international agencies.

Compliance Regime
These new laws require financial institutions to implement a "Compliance Regime" which includes appointment of a compliance officer, preparation of policies and procedures, periodic review of their effectiveness, and ongoing compliance training of staff. EquityFX currently has employees tasked with the responsibilities of compliance and risk management led by its Senior Compliance Officer. EquityFX has also created a Compliance Committee of key department heads which meets regularly.

Policy and Procedures
Compliance policies and procedures have been established, including detailed client identification and verification requirements. In order to ensure compliance, EquityFX utilizes online resources and corporate search services to access public records when necessary. EquityFX checks all transactions, persons and countries involved against a comprehensive database of undesirable persons, including the UN terrorist lists Required reports are filed with FinCEN and FinTRAC.

It is our goal that EquityFX creates a 'pro-compliance' culture at the company and investes sufficient funds to meet or exceed regulatory standards. It has been the repeatedly stated position of the most senior management that their goal is for EquityFX to be considered an industry leader in anti-money laundering controls. The company has been very responsive in addressing compliance issues that we have identified in the course of our review and continues to research best practices to strengthen its regime.