Licensed MSB Sign in Open Account
Open Account

Legal

Financial Crime Risk Appetite Statement

Ernora Pay
Effective Date: 11.06.2025
Approved by: Board of Directors

1. Purpose and Scope

This Financial Crime Risk Appetite Statement sets out Ernora Pay’s approach to managing financial crime risk and defines the level of risk the company is willing to accept in the course of its business activities. It forms part of our broader governance, risk, and compliance framework and establishes boundaries for customer onboarding, transaction handling, and geographic exposure.

2. Strategic Context

Ernora Pay is a Canadian-registered Money Services Business (MSB). Its principal activities include foreign exchange services, remittance, and cross-border payment processing. Due to the nature of its cross-border and primarily non-face-to-face operating model, Ernora Pay applies a conservative approach to financial crime risk and maintains a limited risk appetite across high-risk areas.

3. Risk Appetite Summary Risk Area

  • Money Laundering (ML): Low – managed through robust onboarding, screening, and monitoring controls
  • Terrorist Financing (TF): Zero Tolerance
  • Sanctions Risk: Zero Tolerance
  • Fraud: Low – controlled through layered preventative and detective controls
  • Bribery and Corruption: Zero Tolerance
  • Facilitation of Tax Evasion: Zero Tolerance
  • Proliferation Financing: Zero Tolerance

4. Prohibited and Restricted Client Business Activities

Prohibited Clients and Activities

Ernora Pay will not onboard, support, or maintain relationships with:

  • sanctioned persons, entities, or jurisdictions;
  • unlicensed virtual asset service providers (VASPs);
  • shell banks or anonymous entities;
  • clients engaged in activities involving:
    • pornography or adult entertainment;
    • arms trading or dual-use goods without proper licensing;
    • human trafficking or smuggling;
    • unregulated securities offerings, ICOs, or token sales;
    • “golden visa” or passport-for-sale schemes;
    • high-yield investment schemes or pyramid structures;
    • hidden, unverifiable, or obscured beneficial ownership arrangements.

Restricted Clients and Activities

The following categories may be considered only subject to enhanced due diligence, heightened review, and approval in accordance with internal controls:

  • regulated crypto-related firms;
  • clients with PEP connections;
  • entities operating through offshore financial centres;
  • clients or activity involving higher-risk jurisdictions;
  • legal cannabis businesses operating outside Canada;
  • licensed online gaming or gambling businesses in higher-risk tiers;
  • foreign MSBs and payment service providers.

5. Prohibited Transactions

Ernora Pay will not process transactions involving, directly or indirectly:

  • sanctioned countries, sanctioned entities, or sanctioned individuals;
  • anonymous digital asset addresses or privacy-enhancing coins;
  • undisclosed third parties or beneficial owners that cannot be independently verified.

We also prohibit transactions including, but not limited to:

  • payments with no apparent lawful or economic purpose;
  • payments for goods or services that may violate export control requirements;
  • transactions involving shell companies in opaque jurisdictions with no identifiable commercial activity;
  • cash equivalents or bearer instruments originating from unverified sources.

6. Prohibited and High-Risk Countries

Prohibited Jurisdictions

Ernora Pay prohibits onboarding, business relationships, and transactions involving jurisdictions subject to sanctions or equivalent prohibitions, including those identified under applicable Canadian sanctions laws and, where relevant, international sanctions regimes.

These may include jurisdictions such as:

  • North Korea
  • Iran
  • Syria
  • Cuba
  • Russia, including comprehensively restricted occupied or controlled regions where applicable
  • Belarus
  • Afghanistan
  • Myanmar (Burma)
  • Venezuela in relation to restricted government-linked entities and state-owned enterprises
  • any other country, territory, or region subject to applicable prohibitions under Canadian or relevant international sanctions lists

Ernora Pay may also reject onboarding or transactions connected to jurisdictions identified by the Financial Action Task Force (FATF) as subject to a call for action or equivalent high-risk designation.

High-Risk Countries

Customers, counterparties, or transactions connected to jurisdictions considered high-risk under internal risk assessment, FATF publications, public regulatory guidance, or other credible risk indicators are subject to mandatory Enhanced Due Diligence (EDD), senior compliance review, and increased transaction monitoring.

High-risk jurisdictions may include countries appearing on current FATF grey-list publications or countries identified internally as presenting elevated exposure to money laundering, terrorist financing, corruption, sanctions evasion, or fraud risk.

Ernora Pay reserves the right to amend its country risk classifications at any time based on legal developments, regulatory guidance, internal assessments, public advisories, or operational experience.

7. Governance and Oversight

This Statement is maintained under the oversight of the compliance function and is reviewed by senior management and/or the Board on a periodic basis, and whenever required due to regulatory, operational, or strategic developments.

Any exception to the risk appetite described in this Statement must be formally documented, supported by a clear rationale, and escalated to the appropriate approval level, which may include senior management or the Board, depending on the nature and significance of the exception.