FEARLESS SOLUTION INC. does not market to or serve clients from the United Kingdom. This website and its content are intended for persons outside the United Kingdom. The information provided is not directed at or intended for distribution to, or use by, any person located within the UK. The services described on this website are not available to UK residents. No part of this website constitutes a financial promotion or an offer of services within the UK under the Financial Services and Markets Act 2000.
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ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING POLICY

1. INTRODUCTION

FEARLESS SOLUTION INC. (Legal Name: FEARLESS SOLUTION INC., Incorporation Number: BC1560340, Address: 400 — 565 GREAT NORTHERN WAY, VANCOUVER, BRITISH COLUMBIA, CANADA, V5T 0H8) (also referred to in this Policy as «we», «our» or «us») is a registered Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under registration number N300000196.

This Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Policy is designed to identify, prevent and mitigate the risks of our services being used for money laundering, terrorist financing, fraud, drug and human trafficking, proliferation of weapons of mass destruction, corruption, bribery, or other financial crimes.

We are committed to complying with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and all applicable FINTRAC regulations and guidelines.

Our Services are available exclusively to individual retail clients. We do not provide services to legal entities, corporations, partnerships, trusts, or any form of business organization.

We do not provide wallet services, custodial services, or storage of client crypto assets.

We do not provide investment, advisory, or brokerage services.

2. VERIFICATION PROCEDURE

Before any client can access our services, we must verify their identity. This is required by Canadian law to combat money laundering and terrorist financing.

We collect the following information from every client:

  • Full name;
  • Date of birth;
  • Residential address;
  • Email address;
  • Phone number.

We verify identity using:

  • A valid government-issued identification document (passport or national ID card);
  • Proof of residential address (utility bill, bank statement, or similar document);
  • Source of funds information.

We use SUMSUB for identity verification, which performs document authenticity checks, liveness detection, and facial matching.

We may request additional information from clients who are assessed as higher risk. We reserve the right to verify identity on an ongoing basis, particularly when identification information has changed or when activity appears suspicious.

All client identification information is collected, stored, shared, and protected in accordance with our Privacy Policy and applicable Canadian privacy laws.

3. RISK ASSESSMENT

We apply a risk-based approach to identify, assess, and understand the money laundering and terrorist financing risks to which we are exposed. This enables us to take appropriate mitigation measures in accordance with the level of risk.

3.1. Risk Categories

Risk by Clients:

We assess each client based on:

  • Country of residence;
  • Occupation and source of income;
  • Source of funds;
  • Expected transaction volume;
  • Any discrepancies in identification documents;
  • Any negative information from screening databases.

Politically Exposed Persons (PEPs):

We do not accept PEPs under any circumstances. PEPs include individuals holding prominent public functions such as heads of state, heads of government, ministers and deputy ministers; members of parliament; members of governing bodies of political parties; members of supreme courts or central bank boards; ambassadors and high-ranking officers in the armed forces; and their close family members and associates.

Risk by Countries:

We do not accept clients from FATF blacklisted jurisdictions or countries subject to comprehensive sanctions. For clients from FATF grey-listed jurisdictions, we apply Enhanced Due Diligence, including additional verification of source of funds and source of wealth.

Risk by Transactions:

We assess each transaction based on:

  • Transaction size and frequency;
  • Transaction patterns (e.g., splitting into smaller amounts);
  • Wallet screening results (links to mixers, darknet markets, stolen funds, sanctions).

4. CLIENT DUE DILIGENCE

4.1. Standard Due Diligence

We perform standard due diligence on every client before any transaction is executed:

  • Identity verification (as described in Section 2);
  • Sanctions screening against Canadian, UN, EU, and OFAC sanctions lists;
  • PEP screening;
  • Wallet screening using AMLBot;
  • Source of funds verification.

4.2. Enhanced Due Diligence

Enhanced Due Diligence is applied to:

  • Clients from FATF grey-listed jurisdictions;
  • Clients flagged with any risk indicators;
  • Clients whose transaction volume exceeds our internal thresholds.

Enhanced Due Diligence includes:

  • Requesting additional documentation (bank statements, employment proof, source of wealth);
    Conducting more frequent monitoring;
  • Escalating to the MLRO for approval before any transaction is executed.

5. ONGOING MONITORING

We monitor all transactions on a continuous basis to detect suspicious activity. Our monitoring includes:

Daily Transaction Reviews:

All transactions are reviewed for unusual patterns, including rapid in-and-out movements, multiple small transactions below reporting thresholds, and transactions involving high-risk jurisdictions.

Wallet Screening:

  • Every incoming and outgoing crypto transaction is screened using AMLBot before execution;
  • Wallets flagged for links to darknet markets, mixers, ransomware, stolen funds, sanctions, or terrorist financing are blocked.

Client Behaviour Monitoring:

  • Transactions are compared against the client’s stated profile, expected volume, and historical behaviour;
  • Any deviation triggers a manual review and may result in Enhanced Due Diligence.

Sanctions and PEP Monitoring:

Clients are continuously monitored for changes in sanctions or PEP status using SUMSUB;
Daily alerts are reviewed by our compliance team.

6. TRAVEL RULE

We enforce the Travel Rule for all virtual currency transfers in accordance with FINTRAC requirements.

For every transfer, we collect and transmit the following information:

  • Sender’s name and address;
  • Recipient’s name and address;
  • Transaction amount;
  • Transaction reference number.

If required information is missing, we take reasonable measures to obtain it. If the information cannot be obtained or is inconsistent with the client’s profile, we suspend the transaction and may file a Suspicious Transaction Report with FINTRAC.

We never remove Travel Rule information from a transfer.

7. SUSPICIOUS TRANSACTION REPORTING

We are required by law to report any transaction where we have reasonable grounds to suspect money laundering or terrorist financing.

Reporting Process:

  • Suspicious activity is identified through monitoring or client interaction;
  • The case is escalated to the MLRO (Steve Chang) for review;
  • If reasonable grounds exist, a Suspicious Transaction Report (STR) is filed with FINTRAC;
  • STRs are filed as soon as practicable, treated as a priority over other tasks;
  • We do not inform the client that a report has been made.

Mandatory Reporting Triggers:

  • Client or transaction linked to sanctioned entities or individuals;
  • Client refuses to provide identification or provides false information;
  • Transaction has no apparent economic or lawful purpose;
  • Any other red flags identified in FATF guidance or our AML policy.

8. RECORD KEEPING

We retain all records in accordance with FINTRAC guidelines:

  • Client identification records: minimum 5 years after account closure;
  • Transaction records: minimum 5 years;
  • Suspicious Transaction Reports: minimum 5 years;
  • Travel Rule information: minimum 5 years.

All records are stored securely and are available for inspection by FINTRAC upon request.

9. REPORTING TO FINTRAC

We report to FINTRAC in the following circumstances:

Suspicious Transaction Reports (STRs):

Filed when we have reasonable grounds to suspect money laundering or terrorist financing.

Large Virtual Currency Transaction Reports:

We are not required to report large virtual currency transactions to FINTRAC at this stage.
However, we maintain records of all such transactions internally and apply enhanced scrutiny.

Travel Rule Compliance:

We maintain records of all Travel Rule information and are prepared to report any compliance failures to FINTRAC within 24 hours, though we currently have no instances to report.

10. AML OFFICER

We have appointed a qualified AML Officer, Steve Chang, who is responsible for:

  • Overseeing the implementation of this AML/CTF Policy;
  • Monitoring regulatory developments;
  • Filing Suspicious Transaction Reports to FINTRAC;
  • Acting as the primary liaison with FINTRAC;
  • Conducting internal AML training;
  • Reviewing and updating this Policy annually;
  • Managing the independent effectiveness review.

Contact Person:

Vladyslav Hryshchenko, CEO

Email: support@fearless.solutions

11. TRAINING

All employees receive AML/CTF training:

  • New employees: Complete training within the first two weeks of employment;
  • Ongoing training: At least once per year;
  • Compliance staff: Receive additional training through external providers such as ACAMS and CAMLI.

Training covers:

  • Canadian AML/CTF laws and FINTRAC requirements;
  • Our AML/CTF policies and procedures;
  • Identifying suspicious activity;
  • Reporting obligations;
  • Client identification and verification procedures;
  • Transaction monitoring and wallet screening.

All training sessions are documented with dates, participant lists, and topics covered.

12. INDEPENDENT EFFECTIVENESS REVIEW

We are required by FINTRAC to conduct an independent review of our AML program. Our first independent review is due by April 28, 2028.

The review assesses:

  • The effectiveness of our policies and procedures;
  • Compliance with PCMLTFA and FINTRAC guidelines;
  • Risk assessment accuracy;
  • Employee knowledge of AML requirements;
  • Record keeping and reporting compliance.

13. CONFIDENTIALITY

All AML/CTF related information, including Suspicious Transaction Reports and internal investigations, is treated as strictly confidential.

We do not disclose:

  • That a Suspicious Transaction Report has been filed;
  • Any information related to AML investigations;
  • Client information to third parties except as required by law.

14. PROHIBITED ACTIVITIES

We do not accept clients or transactions involving:

  • Gambling or betting (including online casinos, sports betting, poker);
  • Adult entertainment or adult content platforms;
  • Weapons and munitions production or trade;
  • Unlicensed pharmaceuticals;
  • Forced labor, harmful child labor, or exploitative labor practices;
  • Money services businesses, other crypto exchanges, or financial institutions;
  • Investment and brokerage services, asset management, hedge funds;
  • Network marketing or referral marketing programs.

15. DATA PROTECTION

All personal information collected for AML/CTF purposes is processed in accordance with our Privacy Policy and applicable Canadian privacy laws, including PIPEDA.

We ensure that:

  • Personal information is collected only for legitimate purposes;
  • Information is stored securely;
  • Access is restricted to authorized personnel;
  • Information is retained only as long as required by law;
  • Information is securely deleted when no longer needed.

16. REVIEW AND UPDATES

This Policy is reviewed annually and updated as needed:

  • When FINTRAC issues new guidelines or regulations;
  • When our business model or risk profile changes;
  • When any deficiencies are identified during internal or external audits.

17. CONTACT US

If you have any questions regarding this AML/CTF Policy, please contact us:

Email: support@fearless.solutions

Website: https://fearless.solutions

Address: 400 — 565 GREAT NORTHERN WAY, VANCOUVER, BRITISH COLUMBIA, CANADA, V5T 0H8