Bendix Foreign Exchange is strongly committed to cooperating with all applicable rules and regulations designed to combat money laundering activity and terrorist financing particularly the rules and regulations requiring reporting of transactions that constitute suspicious activity.

Bendix has developed anti-money laundering and counter-terrorist financing policies to ensure that company personnel comply with applicable laws and regulations when engaging in foreign exchange services to clients.

PROCEEDS OF CRIME (MONEY LAUNDERING) AND TERRORIST FINANCING ACT

The Proceeds of Crime (Money Laundering) Act was amended in December 2001 to become the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). The PCMLTFA and the FINTRAC regulations implementing it, requires all money service businesses like Bendix FX to register with FINTRAC, to create and maintain customer identification records, to report prescribed transactions and to implement a compliance regime.

COMPLIANCE REGIME

Bendix’s compliance regime consists of the following:

1) Adoption of a written anti-money laundering and terrorist financing program

This program includes a system for

• verifying customer identification;
• creating and retaining records;
• filing reports as required by law; and
• internal sanctions for non-compliance by personnel.

2) Designation of a Compliance Officer

The Compliance Officer ensures that

• the policies are implemented;
• procedures are updated as needed; and,
• continuous relevant training is provided.

3) An Ongoing Employee Compliance Training

The Bendix training program

• explains company policies and procedures;
• emphasizes the need for gathering complete documentary requirements from new clients; and,
• teaches how to identify suspicious transactions

4) Periodic Review of the compliance regime.

Any questions or concerns regarding Bendix’s AML-CTF policy should be addressed to:
The Compliance Officer
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100 Adelaide Street West, Suite #1000
Toronto, Ontario M5H 1S3
Canada
Tel: 1 (416) 366-9000
Fax 1 (416) 366-3434