Regulation, oversight and the rules we follow
How Lumen Payments is registered, which laws apply to it, and how the compliance program is organized and governed.
- FINTRAC
Registered MSB
Registered with the Financial Transactions and Reports Analysis Centre of Canada.
- PCMLTFA
Governing law
The Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations.
- AML/CTF
Written program
Policies and procedures approved by the Board and based on a documented risk assessment.
- KYC/KYB
Due diligence
Verification of each client company, its directors and its beneficial owners.
- PIPEDA
Privacy
The federal law that governs how we collect and handle personal information.
- FATF
Global standards
Our policies follow the recommendations of the Financial Action Task Force.
What registration means
LUMEN PAYMENTS LIMITED is registered with FINTRAC as a money services business. That status requires us to run an AML/CTF compliance program, report prescribed transactions to FINTRAC and keep the records the PCMLTFA sets out.
FINTRAC registration is not a licence and is not prudential supervision. It does not mean that FINTRAC or the Government of Canada endorses our services.
Search the FINTRAC MSB registry- Legal name
- LUMEN PAYMENTS LIMITED
- Registration type
- Money services business
- Regulator
- FINTRAC
- MSB registration number
- N300001690
- BC registration number
- BC1582665
- Registered office
- 5307 Victoria Drive #1277, Vancouver BC V5P 3V6, Canada
The AML/CTF program
The program covers the whole client lifecycle, from the first enquiry to the end of the relationship, and continues through record retention afterwards.
- 01
Risk-based due diligence
Standard, intermediate or enhanced review, depending on the client’s risk rating.
- 02
Enhanced due diligence
For high-risk clients: evidence of source of funds and source of wealth, profiles of beneficial owners and wider adverse media checks.
- 03
Sanctions and PEP screening
Checks against Canadian sanctions, the Criminal Code list of terrorist entities, UN Security Council and OFAC lists, at onboarding and on an ongoing basis.
- 04
Transaction monitoring
Activity is compared with the expected profile, and the compliance team reviews every alert.
- 05
Reporting to FINTRAC
Suspicious transaction reports, terrorist property reports and other prescribed reports are filed where the law requires.
- 06
Record keeping
Records are retained for at least five years and can be provided to FINTRAC within 30 days of a request.
- 07
Staff training
Onboarding and compliance staff are trained each quarter on due diligence, red flags and reporting duties.
- 08
Effectiveness review
The program is tested at least every two years, and the findings are reported to senior management.
Governance and oversight
Authority and responsibility are assigned in writing and set out in our Corporate Governance framework.
Board of Directors
Ultimately responsible for strategy, regulatory compliance and risk appetite. At least one director is independent and non-executive.
Compliance Officer
Oversees every AML/CTF obligation, approves high-risk clients, is the contact point for FINTRAC and reports directly to the Board.
Executive management
A small team responsible for operations, risk and information technology runs the business day to day under authority delegated by the Board.
New product approval
Nothing new launches without Board approval and a documented risk assessment that includes money laundering and terrorist financing exposure.
Conflicts of interest
Directors declare conflicts in writing, each declaration is entered in a register kept by the company, and a conflicted director does not vote.
Restricted jurisdictions
We do not work with individuals, companies or businesses that are located in, incorporated in or otherwise connected with the countries and territories below.
- Afghanistan
- Belarus
- Cuba
- Iran
- Myanmar
- North Korea
- Russia
- Russian-occupied territories of Ukraine
- South Sudan
- Sudan
- Syria
- Venezuela
- Yemen
A connection to any jurisdiction that FATF lists as having strategic AML/CFT deficiencies triggers enhanced due diligence and may result in the relationship being declined. We keep this list under review.
Every client relationship begins with a review
Describe your company and the payments you need to make. Our team will explain the onboarding procedure and the documents it requires.