Anti-Money Laundering and Anti-Terrorist Financing Notice

Last updated on September 10, 2026

1. Regulatory Status and Scope

Varixon Inc., a company incorporated under the laws of Alberta, Canada, with its registered address at 700-602 12 AVE SW, Calgary, Alberta, T2R1J3, Canada and Corporate Access Number 2028407035 (hereinafter – “Company”, “We”, “Our” or “Us”). 

The Company maintains an Anti-Money Laundering and Anti-Terrorist Financing (hereinafter – “AML/ATF”) compliance framework designed to comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (hereinafter – “PCMLTFA”), its associated Regulations, applicable FINTRAC requirements and applicable Canadian sanctions legislation.

This AML/ATF Notice (hereinafter – “Notice”) describes the standards, principles and requirements that the Company applies to prevent and detect money laundering, terrorist financing, sanctions evasion and other illicit activity in connection with its services.

This Notice is provided for general informational purposes only and is intended to provide an overview of the Company’s AML/ATF compliance approach. More detailed operational requirements, internal controls, risk assessment procedures, escalation measures and recordkeeping arrangements are set out in the Company’s internal AML/ATF compliance framework and are implemented through its onboarding, compliance and operational processes.

As part of its AML/ATF compliance framework, the Company appoints a Compliance Officer responsible for implementing the compliance program, maintains an ongoing AML/ATF training program for relevant personnel, and conducts a review of the effectiveness of its compliance program at least once every two (2) years in accordance with applicable Canadian AML/ATF requirements. 

2. Client Identification and Verification

The Company is required to verify the identity of persons and entities in the circumstances prescribed by the PCMLTFA and its associated Regulations. The Company may also require identity verification as part of its own onboarding and risk-management procedures before providing over-the-counter virtual currency exchange services (hereinafter – “OTC Services”).

Prior to executing any transactions, clients must complete mandatory onboarding checks:

  • valid government-issued photo identification or another identity verification method permitted under applicable Canadian AML/ATF requirements; 
  • official corporate documentation confirming legal existence, registered address, and authorized signatory powers for corporate entities;
  • full identification of beneficial owners directly or indirectly holding or controlling 25% or more of an entity, along with its directors;
  • determinations regarding politically exposed persons, heads of international organizations, and their family members or close associates;
  • information and, where required, supporting documentation concerning the source of funds, source of virtual currency and, where appropriate, source of wealth; 
  • ongoing monitoring and periodic or event-driven updates of client information, as required under the Company’s risk-based compliance framework. 

The Company strictly prohibits anonymous trading and will not execute transactions for unverified parties.

Clients are responsible for ensuring that all submitted information and documentation are accurate, complete, and up to date, and must promptly notify the Company of any material changes.

The Company may use appropriate third-party service providers to support identity verification, sanctions screening and other compliance checks, while remaining responsible for its applicable regulatory obligations. 

3. Transaction Monitoring and Reporting

The Company monitors transactions and activities in accordance with applicable AML/ATF requirements.

Where required by law, the Company reports transactions or activities to FINTRAC or other competent authorities, including reportable virtual currency transactions and suspicious transactions.

The Company is required to submit Suspicious Transaction Reports where there are reasonable grounds to suspect that a transaction or attempted transaction is related to the commission or attempted commission of a money laundering offence, terrorist activity financing offence or sanctions evasion offence, in accordance with applicable law.

The Company also maintains records and information relating to transactions and activities as required by the PCMLTFA and its associated Regulations.

4. Travel Rule

The Company complies with applicable Canadian Travel Rule requirements for qualifying virtual currency transfers. This may require the Company to obtain, record and/or transmit prescribed information relating to the originator and beneficiary of a virtual currency transfer. The information required may depend on the nature of the transfer and the parties involved.

Where required information is missing or incomplete, the Company will take reasonable measures to obtain the information and apply its risk-based procedures to determine whether the transfer may proceed, should be suspended, or should be rejected. 

5. Blockchain and Sanctions Screening 

As part of its AML/ATF and sanctions compliance measures, the Company may conduct screening of virtual currency addresses and transaction activity using blockchain analytics and other compliance tools.

Such screening may identify exposure to sanctioned persons or jurisdictions, illicit activity, fraud, ransomware, darknet markets, mixers or other high-risk or unlawful activity.

Where a transaction or wallet address presents a compliance concern, the Company may request additional information or take appropriate action in accordance with applicable law and its internal compliance framework.

6. Prohibited Clients 

The Company does not provide its OTC Services to clients or persons whose activities or circumstances are prohibited under applicable law or are inconsistent with the Company’s AML/ATF and sanctions requirements.

This may include, for example:

  • persons or entities subject to applicable sanctions or restrictions, or connected with jurisdictions or territories subject to applicable comprehensive sanctions or other prohibitions; 
  • persons or entities whose identity, ownership or control cannot be verified in accordance with applicable identification and verification requirements;
  • persons or entities that refuse to provide information or documentation reasonably required for due diligence or compliance purposes;
  • persons or entities that the Company has reasonable grounds to believe are using, or intend to use, the OTC Services for unlawful purposes, including money laundering, terrorist financing, sanctions evasion or fraud; and
  • persons or entities that otherwise fall within prohibited categories or do not meet the Company’s applicable client acceptance and risk requirements.

The Company reserves the right to refuse to establish or maintain a business relationship, or to delay, suspend, reject, decline or restrict a transaction, where due diligence requirements are not met or where the relevant relationship or transaction presents an unacceptable legal, regulatory or compliance risk. 

7. Data Retention and Record-Keeping 

The records maintained by the Company may include client identification and verification information, transaction records, information relating to virtual currency transfers and other records required for AML/ATF and regulatory purposes.

Records are retained for the periods prescribed by applicable law and are maintained in a manner that supports the Company’s legal and regulatory obligations. Where applicable, records are retained for a minimum period of five (5) years, in accordance with the requirements of the PCMLTFA and its associated Regulations.

8. Amendments to this Notice 

The Company may amend or update this Notice from time to time to reflect changes to applicable laws, regulations, regulatory requirements or the Company’s AML/ATF framework.

The updated version of the Notice will be made available through the Company’s website or other appropriate channels. Clients are encouraged to review the Notice periodically to remain informed of the Company’s applicable AML/ATF requirements.

9. Contact Information 

For questions regarding the Company’s AML/ATF requirements, client identification and verification, or other compliance matters, You may contact the Company using the following:

  • Company name: Varixon Inc.
  • Registered address: 700-602 12 AVE SW, Calgary, Alberta, T2R1J3, Canada
  • Email: varixon.financial@gmail.com