Anti-Money Laundering (AML) Policy

Silicon Silk Ltd. is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business (MSB No. C100000527) and is committed to preventing money laundering, terrorist financing, and sanctions evasion through its services.

Our compliance program is governed by Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), associated regulations, and applicable international standards.

Before establishing a business relationship, we conduct customer due diligence proportionate to the assessed money laundering and terrorist financing risk presented by the customer, products, channels, and geographies involved.

Enhanced due diligence is applied to higher-risk customers, including politically exposed persons, complex ownership structures, and high-risk jurisdictions.

We verify the identity of every business customer, beneficial owner holding 25% or more of the entity, and every authorized representative — using government-issued identification, registry data, and reliable third-party verification sources.

Customer information is reviewed periodically and updated whenever there are material changes to ownership, business activity, or risk profile.

All transactions executed through Silicon Silk are subject to automated monitoring against rules and risk models calibrated to detect patterns indicative of money laundering, terrorist financing, sanctions evasion, or fraud.

Alerts are reviewed by trained compliance analysts who may request additional information, hold transactions for review, or escalate findings to the Compliance Officer.

Where we have reasonable grounds to suspect that a transaction or attempted transaction is related to the commission or attempted commission of a money laundering or terrorist financing offence, we will file a Suspicious Transaction Report (STR) with FINTRAC in accordance with Canadian law.

We also file Large Cash Transaction Reports, Electronic Funds Transfer Reports, and Terrorist Property Reports as required by applicable regulation.

We retain customer identification records, transaction records, risk assessments, and compliance documentation for a minimum of five years as required under the PCMLTFA, and longer where additional regulations or contractual obligations apply.

Records are stored securely and made available to FINTRAC and other competent authorities on lawful request.

All Silicon Silk employees, contractors, and agents who handle customers, transactions, or compliance matters complete an AML training program upon onboarding and annually thereafter.

Our Compliance Officer maintains the program, oversees independent effectiveness reviews at least every two years, and reports directly to senior management.