General Policy Statement

The Compliance Regime stipulated under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) [the ACT] and its supporting Regulations sets out that all organizations must put in place “ … effective policies and procedures to prevent, detect and address non-compliance”. The organization’s owner ensuring the level of accountability and responsibility required under the Compliance Regime has adopted policies and procedures. The policies are of such a nature that they are informative and descriptive. Furthermore, all policies incorporate both the applicable legislative and regulatory requirements.

Accountability

Policy: “The owner, employees and agents of BABYLON are committed to meet and maintain all relevant, money service business compliance requirements set down under Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its supporting Regulations.”

Customer Awareness

BABYLON will make every effort to inform current and future customers of its responsibility to comply with the ACT and its various supporting Regulations as included in the following policy.
Policy: “The owner, employees and agents of BABYLON inform all customers, current and future, of its requirement to comply with the various legislative and regulatory requirements under Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act.”

Mandatory Compliance Regime

The following policy confirms the intent of BABYLON to address all five elements of the government’s stated Compliance Regime set down in the Regulations. It reads as follows:
Policy: “BABYLON has put in place an appropriate Compliance Regime that addresses the five key elements set down in the Act’s Regulations, Specifically:

• Appointment of a compliance officer.
• The development and application of compliance policy and procedures.
• An assessment and documentation of risk related to money laundering and terrorist financing.
• An ongoing compliance employee/agent training program that is in writing and maintained.
• conduct regularly scheduled compliance reviews.

Risk Assessment

Policy: “The owner of BABYLON undertakes an assessment and documentation of risk related to money laundering and terrorist financing, and subsequently implements controls (risk mitigation) to handle the identified risks, at both the company and customer levels.”

Compliance Training Program

BABYLON owner has developed, delivered and maintained a training program for all new and continuing employees and agents. The training manual was developed by ABC solutions Inc. an external knowledgeable consultant

Compliance Reviews

Policy: “BABYLON will undertake an independent compliance review of its compliance regime on an annual basis as set out under FINTRAC’s guidelines. A copy of each Review Report will be made available to FINTRAC when requested.”