AML / KYC policy

1. Introduction

VestAccrue maintains a KYC/AML program covering client identification, ongoing monitoring, record keeping and reporting, aligned with Canadian requirements for money services businesses, including those administered by FINTRAC, and with the purposes of preventing money laundering (AML), terrorist financing (ATF) and other financial crime. Verification is not a bureaucratic hurdle: it protects you from identity theft, protects the platform's clients collectively from criminal abuse, and is a condition of providing service.

2. What KYC is

KYC (Know Your Client) is the process of identifying each client and confirming that the information they provide is genuine. In practice this means collecting your legal name, date of birth and address, verifying them against documents, and recording the result. KYC establishes the baseline that every later check refers back to: when activity later looks unusual, we compare it against who we understood you to be at onboarding.

3. What AML is

AML (Anti-Money Laundering) is the set of measures designed to prevent the platform from being used to disguise the origin of criminally derived funds. It includes a documented risk assessment of the business, controls proportionate to that risk, monitoring of client transactions for suspicious patterns, and mandatory reporting to the relevant Canadian authorities where legal thresholds are met. The program is reviewed periodically and updated as risks and requirements change.

4. Why identity verification is required

Verification serves four concrete purposes: it prevents fraud by ensuring accounts are opened by their real owners; it protects individual accounts from takeover, since an impostor cannot pass verification they do not match; it supports compliance with applicable Canadian requirements, including reporting obligations; and it reduces financial risk for everyone on the platform by making it hostile ground for launderers and scammers. Without verification, none of the other protections would be reliable.

5. Documents we ask for

For identity: a government-issued photo document, such as a Canadian passport, driver's licence or provincial ID card. For address: a document dated within the last three months, such as a utility bill, bank statement or lease agreement showing your name and residential address. Where a session requires liveness confirmation, a short selfie video or photo captured during the flow is compared against your document, and the biometric template is deleted after the check unless you consent to longer retention. We do not ask for documents we cannot process, and we never ask you to send credentials, passwords or codes.

6. The verification process, step by step

1. Registration: you create the account with your name, email and phone number.
2. Provision of data and documents: during onboarding with your account manager, you upload the documents described above through the secure in-dashboard flow.
3. Automated checks: document authenticity, data consistency and watchlist screening run automatically; most cases clear here.
4. Manual review where needed: unclear cases go to a compliance analyst, who may request an alternative document or a short call.
5. Result: you are notified by email, and the result is recorded in your account with its date.

7. Enhanced due diligence

Some situations call for Enhanced Due Diligence (EDD): clients with public functions (politically exposed persons and their close associates), structures such as trusts or corporate accounts, higher expected volumes, or residence in higher-risk jurisdictions. EDD may involve additional documents proving the source of funds (for example, a sale contract, payslips or tax documents), questions about the expected nature of activity, and senior compliance approval before activation. EDD is applied to facts, not opinions, and its criteria are documented in the internal program.

8. How long verification takes

Straightforward cases complete the automated stage within minutes and most are fully verified within one business day. Cases requiring manual review are typically resolved within one to three business days. The variables that drive the timeline are document quality (photos of the whole document, all corners visible, no glare), name or address mismatches between documents, and whether EDD applies. Your account manager tells you which stage your case is in, so you are never guessing.

9. Reasons a verification may be refused or paused

A check can be declined or suspended for: documents that are expired, unreadable or manipulated; a mismatch between the document and the data provided; matches against sanctions lists or adverse-media findings; a failed liveness comparison; or non-response to requests for information within the stated period. A pause is often just a request for a better photo. Where a decision is adverse, we tell you the general ground; we are not always permitted to reveal the specifics where that would undermine a reporting obligation.

10. Transaction monitoring

Once your account is active, transactions and behaviour are monitored against your expected profile. Unusual deposit or withdrawal patterns, sudden changes in instruments or volumes, or activity consistent with third-party use of the account can trigger a review. Pending review, specific functions such as withdrawals may be limited while we ask you what is going on; monitoring measures are proportionate and recorded, and a limitation is lifted as soon as the review resolves.

11. Your responsibilities as a user

You are responsible for providing accurate, current and genuine information and documents, and for updating them when they change. You must not operate the account on behalf of another person, accept deposits from third parties, or use the account for any purpose other than your own investing. Providing false information can lead to suspension, termination of the relationship, and where required, reporting to the authorities.

12. Storage and protection of verification data

KYC/AML records are stored encrypted, with access limited to the compliance personnel who need it and every access logged. Retention periods follow the applicable Canadian requirements, which generally require records to be kept for five years after the end of the relationship. The full handling of personal data, including your rights, is described in the Privacy Policy.

13. Who receives verification data

To run the program, data is shared only with: KYC/verification providers performing document and screening checks; IT service providers hosting or processing data under contractual confidentiality; affiliated companies within the group where services are provided jointly; and regulators or other public authorities, where a lawful request or reporting obligation applies. Each category is covered by agreements restricting use of the data to the purpose it was shared for.

14. Compliance with Canadian requirements

The program is aligned with the requirements applicable to the services provided: federal requirements administered by FINTRAC for money services businesses, including client identification methods, record keeping, suspicious transaction reporting and certain large-transaction reporting, together with provincial requirements relevant to the securities-related aspects of the activity. Where obligations differ by province, the stricter standard is applied as policy. More context on the framework itself is on the Licensing & Regulation page.

15. Contact for KYC/AML questions

Questions about this policy, your verification status, or the data involved go to [email protected] with the subject line "KYC". The compliance team answers such messages with priority during support hours, Monday to Friday, 9:00–17:30 ET. If you believe a decision about your verification was wrong, the Complaints page explains how to have it reviewed formally.