Compliance Policy
Last Updated: 15 September 2025
Market Sense Ltd is a Canadian-registered Money Services Business (MSB Reg. No. C100000629).
1. Introduction
The Company operates in full compliance with:
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), including the 2025 amendments;
- Retail Payment Activities Act (RPAA) with supervisory requirements effective September 8, 2025;
- Personal Information Protection and Electronic Documents Act (PIPEDA);
- International standards of the Financial Action Task Force (FATF);
- Sanctions regimes of Canada, United States (OFAC), European Union, United Kingdom, and the United Nations.
We maintain a zero-tolerance policy towards money laundering (AML), terrorist financing (CTF), sanctions evasion, corruption, fraud, and other illegal activities.
2. Core Compliance Principles
- Full compliance with Canadian and international regulatory requirements, including enhanced obligations effective in 2025.
- Independent compliance function, reporting directly to senior management and overseeing the AML/CTF framework under PCMLTFA and RPAA.
- Adoption of a comprehensive risk-based approach (RBA), including enhanced due diligence (EDD) for high-risk jurisdictions and activities.
- Transparency, accountability, and strong internal controls supported by documented policies and procedures.
- Protection of client funds, personal data, and operational integrity — in line with safeguarding requirements under RPAA effective September 2025.
3. Restricted Jurisdictions and Sanctions
3.1 Fully Prohibited Jurisdictions
- North Korea (DPRK)
- Iran
- Syria
- Sudan
- Cuba
- Afghanistan
- Russia
- Belarus
- Crimea, Donetsk and Luhansk regions of Ukraine
- Venezuela
- Myanmar
- Algeria
- Angola
- Burkina Faso
- Cameroon
- Côte d’Ivoire
- Democratic Republic of Congo
- Haiti
- Kenya
- Laos
- Lebanon
- Mali
- Mozambique
- Namibia
- Nepal
- Nigeria
- South Africa
- South Sudan
- Tanzania
- Vietnam
- Yemen
- Trinidad and Tobago
- Vanuatu
- Transnistria
- Gaza Strip
- Western Sahara
- Other regions subject to international sanctions per UN, EU, OFAC updates
4. Prohibited Clients and Activities
We do not provide services to:
- Anonymous clients and shell banks.
- Clients refusing or unable to complete KYC/AML checks.
- Politically Exposed Persons (PEPs) without Enhanced Due Diligence (EDD).
- Clients engaged in the following restricted or high-risk sectors: Arms and military equipment trade
- Narcotics and precursor chemicals
- Unlicensed gambling
- Pornography and adult industry
- Ponzi schemes, HYIP projects, fraudulent enterprises
- Darknet services, cryptocurrency mixers, and anonymous transaction tools
Market Sense Ltd maintains a confidential and anonymous whistleblowing channel, enabling employees and partners to report suspected violations without risk of retaliation.
5. Transaction Monitoring and Reporting
- All transactions undergo sanctions and AML screening against official lists, including: Canada Consolidated List
- OFAC SDN List
- UN Consolidated List
- EU Sanctions
- UK HMT List
- Suspicious transactions are immediately blocked and referred for manual review following escalation protocols.
- Reports to FINTRAC include: Suspicious Transaction Reports (STR)
- Terrorist Property Reports (TPR)
- Electronic Funds Transfer Reports (EFTR)
- Large Virtual Currency Transaction Reports (LVCTR), per thresholds set by FINTRAC
6. Governance and Oversight
- Senior management holds ultimate responsibility for the compliance framework, strategic oversight, and engagement with regulatory authorities.
- The compliance function is responsible for developing, implementing, and monitoring the AML/CTF program, conducting regular risk assessments, and ensuring timely reporting to regulators.
- The information security function ensures data protection, transaction security, implementation of cybersecurity measures, and control over system integrity and availability.
- All employees and company partners must undergo regular training on AML/CTF, sanctions compliance, and ethical business standards.
- The effectiveness of the compliance system is regularly assessed through internal evaluations and independent external audits.
7. Whistleblowing
Market Sense Ltd maintains a confidential and anonymous whistleblowing channel, enabling
employees and partners to report suspected violations without risk of retaliation.
8. Continuous Improvement
- The Compliance Policy and related procedures are reviewed at least annually or promptly upon regulatory updates.
- Guidance from FINTRAC, the Bank of Canada, and other authorities is continuously monitored to ensure alignment with best practices.
9. Contact Information
Compliance Department – Market Sense Ltd Email: compliace@manitist.io
