HIGHNESS GLOBAL CAPITAL INC. ANTI-MONEY LAUNDERING POLICY AND ANTI-TERRORIST FINANCING POLICY
This is an abbreviated policy, please contact [email protected] for a complete version of the AML Policy
The purpose of Highness Global Capital Inc. (Highness) Anti-Money Laundering and Anti-Terrorist Financing Policy (AML Policy) is to demonstrate Highness’ commitment to prevent, detect and address non-compliance in regard to money laundering (ML) and terrorist financing (TF) activities. Highness will not knowingly participate in any capacity in the advancement of a transaction that is suspected to be related to the commission of a ML or TF activity.
Highness will do its best to ensure the AML Policy sets out the standards that employees, agents, and others authorized to act on its behalf must meet. The AML Policy is written plainly to be clearly communicated, understood and followed by all those authorized to act on Highness’ behalf (employees, agents and any others that deal with clients, transactions or other activities).
NOTE ON PRIVACY: The use of personal information collected by Highness is protected by privacy legislation. We will inform clients about the collection of their personal information except when we include their personal information in the reports that we are required to submit to FINTRAC.
Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) Policy Summary
Highness Capital (Highness) is committed to the highest standards of integrity and transparency. We maintain a robust AML/ATF program designed to prevent, detect, and report money laundering (ML), terrorist financing (TF), and sanctions evasion.
Our policy complies with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), related Canadian regulations, and the updated regulatory amendments effective April 1, 2025.
1. Purpose and Scope
The purpose of this policy is to ensure Highness does not knowingly engage in or support transactions involving illicit funds. This policy applies to all employees, directors, and third-party contractors. As a small registrant, our program is designed to be proportionate to our size and risk profile while fully meeting all FINTRAC requirements.
2. Core Compliance Elements
Highness adheres to the five pillars of a FINTRAC-compliant regime:
- Designated Compliance Officer: Our Chief Compliance Officer (CCO) oversees the day-to-day administration of the AML program.
- Written Policies and Procedures: Rigorous internal controls govern client onboarding, transaction monitoring, and record-keeping.
- Risk Assessment: We continually evaluate risks related to our clients, products, and geography.
- Ongoing Training: All staff undergo annual mandatory training on current regulations and emerging threats.
- Effectiveness Reviews: An independent review of our AML regime is conducted every two years to ensure continued effectiveness.
3. Risk-Based Approach (RBA)
Highness utilizes a Risk-Based Approach to focus resources on higher-risk areas. We conduct Enhanced Due Diligence (EDD) for:
- Politically Exposed Persons (PEPs) and Heads of International Organizations (HIOs).
- Entities with complex or opaque ownership structures.
- Clients or transactions involving high-risk or sanctioned jurisdictions.
4. Client Identification and Transparency
We implement strict Know-Your-Client (KYC) and Beneficial Ownership protocols:
- Verification: Identity is verified through government-issued photo ID, credit file methods, or dual-process methods.
- Beneficial Ownership: We require the disclosure and verification of all individuals who own or control 25% or more of a corporate client or trust.
- Sanctions Screening: All clients are screened monthly against the consolidated sanctions lists published by OSFI and international bodies.
5. Reporting and Monitoring
Highness complies with all mandatory FINTRAC reporting, including:
- Suspicious Transaction Reports (STRs): Filed when there are reasonable grounds to suspect ML/TF or sanctions evasion (as per 2024/2025 mandates).
- Terrorist Property Reports (TPRs): Filed immediately if we possess property owned or controlled by terrorists.
- Anti-Tipping Off: We are legally prohibited from disclosing that a report has been filed or that an investigation is underway.
6. Restricted Activities
To mitigate risk, Highness maintains the following restrictions:
- No Cash: Highness does not accept cash or monetary instruments (money orders, etc.).
- No Virtual Currency: Highness does not currently engage in or accept virtual currency/crypto-asset transactions.
- No Crowdfunding: Highness does not participate in crowdfunding activities.
7. Governance and Accountability
Ultimate accountability for our AML/ATF regime rests with our Ultimate Designated Person (UDP). We maintain all records for a minimum of five years and cooperate fully with FINTRAC audits to safeguard the integrity of the Canadian financial system.