Anti-money laundering and sanctions policy

Volta Square LLC is registered with FinCEN (United States) and Volta Square Inc. with FINTRAC (Canada) as Money Services Businesses. Both are subject to anti-money laundering and counter-terrorist financing obligations, which we apply to every client and every payment. This page summarises our approach; it is not exhaustive.

1. Knowing our clients

• We serve registered businesses only.
• Before any operation, we verify the company, its directors, its authorised signatories and every person who owns or controls 25% or more of it, or otherwise controls it.
• We ask about the activity, the expected payments, the countries involved and the origin of funds, and keep this information up to date.
• Enhanced checks apply to higher-risk situations, such as politically exposed persons or certain sectors and countries.

2. Checking each payment

• Each payment must match a genuine transaction backed by an invoice or equivalent document.
• Funds must come from an account in the client’s own name; third-party funds are returned.
• Clients, beneficiaries and counterparties are screened against sanctions lists, including those of OFAC, the United Nations, the European Union, the United Kingdom and Canada.

3. Monitoring and reporting

We monitor activity against what each client declared and review unusual operations. Where the law requires it, we report suspicious transactions to the competent financial intelligence unit, such as FinCEN or FINTRAC, without informing the client. We may delay, refuse or block an operation and close a relationship.

4. Records and training

We keep identification and operation records for at least five years, with access restricted by role. Our team is trained on these obligations, and our programme is reviewed as our activities and markets evolve.

5. What we do not accept

Payments in cash or crypto-assets, payments for undeclared third parties, and payments linked to the industries and countries on our prohibited list.