Our Regulatory Commitment
Encore Payment Technologies Ltd., operating as Paiisay, is a registered Money Services Business (MSB) with FINTRAC (Registration No. M23402268). As an MSB, we are subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations.
We are firmly committed to preventing our services from being used for money laundering, terrorist financing, sanctions evasion, or any other financial crime. Compliance is not optional — it is a core part of how we operate.
Know Your Customer (KYC)
Before providing services, Paiisay is required by law to verify the identity of every customer. Our KYC process includes:
- Identity verification: Collection and verification of government-issued photo identification (e.g., passport, driver's licence)
- Date of birth confirmation
- Address verification where applicable
- Business verification: For corporate clients, we verify the entity's registration, directors, and beneficial ownership
- Politically Exposed Person (PEP) screening: Identification of individuals who hold or have held prominent public positions
- Sanctions screening: Checks against OFAC, OSFI, UN, and other applicable sanctions lists
Failure to provide required identification documents will result in our inability to onboard or service your account.
Anti-Money Laundering (AML) Program
Paiisay maintains a comprehensive written AML Compliance Program that includes:
- Appointment of a designated Chief Compliance Officer (CCO) responsible for the AML program
- Written AML policies, procedures, and internal controls
- Ongoing employee training on AML/KYC obligations and suspicious activity recognition
- A risk-based approach to assessing and monitoring customers and transactions
- Regular independent review and audit of the compliance program
- Record retention for a minimum of five (5) years as required by FINTRAC
Transaction Monitoring
We employ automated and manual transaction monitoring systems to identify potentially suspicious or unusual activity. Monitoring covers:
- Transactions that exceed FINTRAC reporting thresholds (Large Cash Transactions — LCTs — of CAD $10,000 or more)
- Patterns of structuring or layering designed to evade reporting requirements
- Transactions inconsistent with a customer's profile or expected behaviour
- Activity involving high-risk jurisdictions or counterparties
Reporting Obligations
As a FINTRAC-regulated MSB, Paiisay is obligated to file the following reports with FINTRAC where applicable:
- Suspicious Transaction Reports (STRs): Filed when we have reasonable grounds to suspect a transaction is related to money laundering or terrorist financing
- Large Cash Transaction Reports (LCTRs): Filed for cash transactions of CAD $10,000 or more received in a single transaction or within 24 hours
- Terrorist Property Reports (TPRs): Filed if we identify property owned or controlled by a listed terrorist entity
- Electronic Funds Transfer Reports (EFTRs): Filed for international electronic fund transfers of CAD $10,000 or more
Sanctions Compliance
Paiisay screens all customers and transactions against applicable sanctions lists, including those issued by the Office of the Superintendent of Financial Institutions (OSFI), the United Nations Security Council, and other relevant authorities. We do not facilitate transactions that would violate applicable sanctions.
No Facilitation of Financial Crime
Paiisay will not knowingly facilitate transactions associated with:
- Money laundering or the proceeds of crime
- Terrorist financing
- Human trafficking or arms dealing
- Fraud or tax evasion
- Sanctions violations
We reserve the right to refuse, delay, block, or reverse any transaction and to terminate any customer relationship where we have concerns regarding financial crime.
Customer Responsibilities
By using Paiisay services, customers confirm that:
- All information provided to us is accurate, complete, and up to date
- Funds transferred are from legitimate sources and are not proceeds of crime
- They are not conducting transactions on behalf of an undisclosed third party
- They will promptly notify us of any changes to their information that may affect their risk profile
Contact Our Compliance Team
If you have questions about our AML/KYC program or wish to report a concern, please contact us at:
Encore Payment Technologies Ltd. — Compliance Department
5577 153A Street, Suite 207, Surrey, BC, Canada V3S 5K7
Email: compliance@paiisay.com
FINTRAC Registration: Encore Payment Technologies Ltd. (operating as Paiisay) is registered with FINTRAC as a Money Services Business under registration number
M23402268. This registration can be verified on the FINTRAC public MSB registry at
www.fintrac-canafe.gc.ca.
