AMX Payments Inc. (operating as BitsBazar)

Last updated: 06 April 2026

1. Purpose and Scope

This Anti-Money Laundering and Know Your Client Policy (“AML & KYC Policy”) describes the framework implemented by AMX Payments Inc. (“AMX”, “Company”, “we”) to detect, prevent, and report money laundering, terrorist financing, and other financial crimes.

AMX operates as a Money Services Business (MSB) registered in Canada and complies with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and related FINTRAC guidance.

This Policy applies to:

• all users and clients of the Services;
• employees, officers, and contractors of the Company;
• third-party service providers involved in onboarding, payments, or compliance.

2. Compliance Governance

The Company maintains a compliance program designed to meet regulatory requirements and industry standards.

A designated Compliance Officer is responsible for:

• implementation and oversight of AML/CTF controls;
• ensuring compliance with applicable laws and regulatory obligations;
• internal training and awareness programs;
• monitoring and reporting suspicious or reportable activities;
• periodic review and improvement of the compliance framework.

3. Customer Due Diligence (CDD)

The Company performs identity verification prior to providing Services.

Clients are required to provide sufficient information to verify their identity, which may include:

• full legal name;
• date of birth;
• residential address;
• government-issued identification;
• additional supporting documentation where required.

The Company may use a combination of:

• automated verification tools;
• third-party providers;
• manual review processes.

Verification must be successfully completed before access to Services is granted.

Bitsbazar screens all clients and transactions against applicable global sanctions lists and domestic Canadian sanctions regimes. Transactions involving PEP/HIO, sanctioned persons, entities, or jurisdictions are prohibited. 

4. Enhanced Due Diligence (EDD)

Additional verification measures may be applied where elevated risk is identified.

EDD may be triggered by factors including but not limited to:

• high-risk jurisdictions or geographic exposure;
• unusual transaction patterns; 
• large transaction volumes. 

Enhanced measures may include:

• source of funds or source of wealth documentation;
• additional identity verification steps;
• ongoing monitoring and reassessment.

5. Transaction Monitoring and Risk Assessment

The Company applies a risk-based approach to monitoring user activity.

Monitoring may include:

• analysis of transaction size, frequency, and patterns;
• blockchain analytics and wallet screening;
• geographic and jurisdictional risk indicators;
• behavioral and account-level risk scoring.

Suspicious or unusual activity may result in:

• enhanced review;
• temporary suspension of Services;
• reporting to regulatory authorities where required.

6. Reporting and Recordkeeping

The Company complies with all applicable reporting obligations under Canadian law.

This includes, where applicable:

• reporting large virtual currency transactions (CAD 10,000 threshold within 24 hours);
• submitting suspicious transaction reports (STRs);
• maintaining records of client identification, transactions, and communications.

Records are retained for the period required by applicable law (minimum 5 years).

7. Prohibited Users and Activities 

The following activities and business categories are not permitted in connection with the Services:

• unlicensed financial services, including money transmission or exchange services requiring regulatory approval;
• sale or distribution of counterfeit or infringing goods;
• activities involving stolen property or proceeds of crime;
• narcotics, controlled substances, or related paraphernalia;
• unlawful gambling or betting operations;
• illegal escort or exploitation-related services;
• activities involving violence, harm, or coercion;
• extortion, blackmail, or fraudulent inducement;
• unlicensed sale of weapons;
• deceptive or misleading commercial practices;
• any activity in violation of applicable laws or regulations.

Users are prohibited from engaging in, facilitating, or attempting to engage in:

• violations of applicable laws or regulatory requirements;
• transactions involving proceeds of unlawful activity;
• unlicensed financial services or unauthorized intermediaries;
• drug-related activities or controlled substances;
• use of stolen or unauthorized assets;
• use of shell companies or opaque ownership structures;
• activities involving human exploitation or trafficking;
• high-risk or abusive behavior toward the Platform or other users;
• violent, coercive, or abusive conduct;
• intellectual property infringement;
• fraud, misrepresentation, or deceptive practices;
• system abuse, hacking, or unauthorized access attempts;
• distribution of malware or harmful code;
• unauthorized data collection or scraping;
• resale or misuse of the Services without authorization;
• circumvention of security or compliance controls.

The Company reserves the right to determine, at its discretion, whether an activity presents unacceptable risk and to take appropriate action, including suspension or termination.

8. Client Responsibilities

By using the Services, you agree to:

• provide accurate and truthful information at all times;
• cooperate with verification and compliance requests;
• maintain control and security of your accounts and wallets;
• refrain from engaging in unlawful or prohibited activities.

Failure to comply may result in suspension or termination of Services.

By using our Services, you acknowledge:

• Cryptocurrency carries inherent risks (volatility, irreversible transactions).
• You understand and accept those risks.

9. Confidentiality and Regulatory Cooperation

Client information is handled in accordance with applicable privacy and data protection laws.

The Company may disclose information:

• to regulatory authorities (including FINTRAC);
• to law enforcement agencies;
• where required by law or legal process.

The Company may be legally restricted from informing clients about certain regulatory reports or investigations.

Bitsbazar will treat your personal information as confidential and only use or disclose it as required under PCMLTFA, in response to lawful requests, or for compliance purposes. Bitsbazar may cooperate with law enforcement or regulatory authorities if required under Canadian law.

Bitsbazar is legally prohibited from notifying you if a Suspicious Transaction Report (STR) or other regulatory report has been filed.

10. Policy Updates

This Policy may be updated periodically to reflect:

• regulatory changes;
• evolving risk factors;
• operational or business developments.

Updates will be published on the Platform.

11. Contact Information

For AML/KYC-related inquiries, please contact:
[email protected]