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GOVERNANCE AND CONTROL

Compliance Policy

A rigorous framework protecting clients, partners and the integrity of operations.

Public version · Updated: 25 September 2026

BBS

About BBS

Legal name
BBS INVEST GROUP LTD
Status
Money Services Business (MSB) registered with FINTRAC in Canada
MSB No.
M23496431
Corporation No.
1522333-4
Head office
1370 Hasting Drive, London, Ontario, Canada N5X 2J3
Group
BBS MASTER GROUP
01

Governance and responsibilities

The risk and compliance function has access to management and coordinates the framework with operational and technology teams. Responsibilities are defined, controls are documented and action plans are tracked. Sensitive decisions are reviewed at the appropriate level to protect transaction integrity.

02

Risk-based approach

Risk assessment considers the customer, business activity, beneficial owners, countries, products, channels and transaction characteristics. It determines due diligence, supporting documentation and approval requirements. Assessments are reconsidered during periodic reviews and following events that may change the risk profile.

03

KYC, KYB and beneficial ownership

Individual identity, corporate existence, declared activities, ownership structures and controlling persons are verified using appropriate information and sources. Representatives’ authority is reviewed. The file establishes who BBS is dealing with and on whose behalf transactions are conducted.

04

Anti-money laundering, counter-terrorist and counter-proliferation financing

The purpose of the relationship, economic rationale of transactions and source of funds are assessed according to risk. Additional documents are collected where transaction characteristics or amounts warrant them. Inconsistencies, opaque structures and unusual behaviour are reviewed and escalated to compliance.

05

Sanctions and politically exposed persons

Relationship and transaction parties are screened against applicable sanctions lists, including UN lists and, as relevant to the activity, Canadian, OFAC, European Union and UK lists. Potential matches are reviewed. Politically exposed person status triggers appropriate assessment and due diligence and is not treated as evidence of wrongdoing.

06

Enhanced due diligence and onboarding decisions

Higher-risk situations receive additional scrutiny of business activity, funds, ownership and involved parties. Approvals and any restrictions are recorded. Where risk cannot be managed or information remains insufficient, the relationship or transaction is declined, deferred or restricted under the applicable framework.

07

Transaction monitoring

Flows are reviewed against known activity, expected volumes and available information. Unusual, structured or inconsistent transactions and those linked to prohibited activities are analyzed. Alerts and their handling are recorded; transactions may be suspended while checks are completed, subject to applicable conditions.

08

Partners and service providers

Initial and periodic due diligence assesses partners’ identity, authorizations, governance, controls and risks. Agreements define each party’s responsibilities. Incidents, business changes or regulatory developments may lead to additional review, corrective actions or changes to the collaboration scope.

09

Keeping records up to date

Customer knowledge is maintained throughout the relationship. Documents and information are reviewed according to risk and significant events, including changes in management, beneficial ownership, activities or operating countries. Customers and partners are contacted when information requires clarification or renewal.

10

Reporting and cooperation with authorities

Situations subject to reporting obligations are assessed and reported to the competent authority under the relevant jurisdiction’s rules. BBS responds to lawful requests and preserves relevant records. Confidentiality requirements attached to certain reports may limit the information disclosed to customers about checks or decisions.

11

Retention and confidentiality

Identification files, supporting documents, analyses, decisions and audit records are securely retained for applicable periods. Access is limited to authorized people according to their roles. Disclosure is governed by legal obligations, service needs and data protection rules.

12

Training, review and continuous improvement

Teams receive awareness guidance suited to their roles and encountered risks. Controls, framework reviews, incidents and regulatory changes inform procedure updates. Identified issues lead to actions tracked through closure, with attention to the practical effectiveness of the measures taken.

Regulatory information

BBS INVEST GROUP LTD is registered as a Money Services Business with FINTRAC in Canada. Services are provided subject to applicable authorizations in each jurisdiction.

Reporting and cooperation

Required reports are made where an obligation applies. Certain restrictions or checks cannot be explained when statutory confidentiality rules prohibit disclosure.

A risk-proportionate program

This public framework works alongside internal procedures, local obligations and service-specific contractual terms. It does not replace individual checks.

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