Compliance Policy

Keyhan Exchange provides specialized services in the field of currency exchange and precious metals, including:

• Buying and selling foreign currencies in cash
• Buying and selling gold, silver, jewelry, and bullion
• Reservation of foreign currencies subject to availability
• Transactions conducted exclusively in person
• Transactions carried out in cash in accordance with our internal compliance policies

Our services are offered in a secure and professional environment to ensure a reliable, fast, and transparent experience for our clients.

Keyhan Exchange enforces strict policies in order to:

• Prevent money laundering and fraudulent activities
• Detect unusual or suspicious transactions
• Comply with Canadian regulatory obligations
• Ensure the security of clients and operations
• Maintain high standards of transparency and compliance
• Cooperate with competent regulatory authorities when required by law

Our compliance program includes, among other things:

• Client identity verification (KYC)
• Transaction monitoring and analysis
• Internal controls and compliance procedures
• Retention of regulatory records
• Ongoing staff training
• Regulatory reporting to FINTRAC when required by law

In accordance with Canadian regulatory requirements, Keyhan Exchange may require a valid government-issued identification document, depending on the amount, frequency, or nature of the transaction.

Accepted forms of identification may include:

• Passport
• Driver's license
• Permanent resident card
• Valid government-issued identity card

Additional verification may be required in certain situations, including:

• Large transactions
• Multiple transactions
• Unusual activity
• Incomplete or inconsistent information
• Additional regulatory requirements

Keyhan Exchange reserves the right to refuse any transaction that does not comply with its internal policies or applicable regulatory requirements.

In accordance with FINTRAC (CANAFE) requirements, this legal obligation may include the collection of information such as:

• The client's full name
• Address and contact information
• Identification details
• Transaction details
• Source of funds, when required
• Information regarding a third party involved in the transaction

These measures are intended to prevent money laundering, criminal activities, and financial fraud.

The 24-hour rule applies when multiple transactions made by the same person or entity collectively reach a total of CAD $10,000 or more within a 24-hour period.

In this situation, the transactions may be grouped together and treated as a single transaction for regulatory purposes.

Keyhan Exchange applies internal monitoring procedures to identify such situations in accordance with FINTRAC requirements.

Keyhan Exchange has a legal obligation to report any transaction or attempted transaction deemed suspicious, in accordance with applicable Canadian laws.

A transaction may be considered suspicious in the following situations:

• Refusal to provide required information
• Inconsistent or false information
• Unusual transactions or transactions without reasonable justification
• Attempts to avoid regulatory thresholds
• Activity that may be related to fraud or money laundering
• Suspicious or unusual behavior

In accordance with the law, reports made to FINTRAC remain strictly confidential.

In accordance with Canadian regulatory requirements, Keyhan Exchange may be required to determine whether a transaction is being conducted on behalf of another person or entity.

The client may be asked to confirm:

• That they are acting on their own behalf
• Or that they are acting on behalf of a third party

When required, additional information may be requested regarding the person or entity involved.

All transactions conducted at Keyhan Exchange may be subject to monitoring and analysis in accordance with our internal compliance policies and Canadian regulatory requirements.

This monitoring is intended, among other things, to:

• Detect unusual activity
• Prevent fraudulent transactions
• Identify high-risk transactions
• Meet FINTRAC regulatory obligations
• Ensure the security of clients and operations

Certain transactions may require additional verification before final approval.

Keyhan Exchange places great importance on the confidentiality and protection of its clients' personal information.

The information collected is used solely for the purposes of:

• Legal and regulatory obligations
• Compliance procedures
• Prevention of fraud and illicit activities
• Transaction verification and monitoring

All information is handled securely and confidentially, in accordance with applicable Canadian privacy laws.

No personal information is sold or shared with third parties, except when required by law or a competent regulatory authority.

In accordance with FINTRAC requirements and applicable Canadian laws, Keyhan Exchange is required to retain certain records and information relating to transactions and client identification for the period prescribed by regulation.

Records retained may include:

• Identification information
• Transaction records
• Compliance documents
• Regulatory reports
• Supporting documents related to transactions

All retained information is protected by appropriate physical and administrative security measures.

Processing times may vary depending on:

• Currency availability
• Transaction volume
• Compliance and verification procedures
• Market conditions
• Applicable regulatory requirements

Certain transactions may require additional verification before finalization.

Keyhan Exchange reserves the right to delay, limit, or refuse any transaction deemed non-compliant with regulatory requirements, its internal policies, or presenting a high level of risk.

Keyhan Exchange reserves the right to refuse, limit, or discontinue any transaction that:

• Does not comply with applicable regulatory requirements
• Presents a high risk of fraud or illicit activity
• Contains incomplete, inconsistent, or misleading information
• Contravenes our internal compliance and security policies

In accordance with Canadian regulatory obligations, certain decisions may be made without detailed disclosure of the reasons.

The availability of foreign currencies may vary depending on:

• Market conditions
• Demand
• Suppliers
• International fluctuations

Exchange rates displayed are provided for informational purposes only and are subject to change without notice.

Currency reservations remain subject to availability at the time of the final transaction.

In order to comply with our internal compliance and security procedures:

• All transactions are conducted in person
• Payments are accepted in cash only
• Certain transactions may require additional verification before final approval

Keyhan Exchange reserves the right to limit certain amounts or certain transactions in accordance with applicable regulatory requirements.

Keyhan Exchange cannot be held liable for:

• Fluctuations in the currency or precious metals markets
• Delays caused by regulatory verification or circumstances beyond our control
• Losses resulting from inaccurate information provided by the client
• Temporary unavailability of certain currencies or products

The client remains responsible for the accuracy of the information provided during any transaction.

By conducting a transaction with Keyhan Exchange, the client acknowledges having read, understood, and accepted these compliance policies as well as the applicable regulatory obligations.

Keyhan Exchange reserves the right to modify its compliance policies, procedures, and requirements at any time in order to comply with applicable laws, regulations, and obligations in Canada.

Any update takes effect upon its publication on the official Keyhan Exchange website.

The compliance policies and procedures of Keyhan Exchange are based notably on:

• FINTRAC (CANAFE)
• The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
• Canadian regulation applicable to money services businesses
• AML/KYC requirements applicable in Canada
• Reporting and record-keeping obligations prescribed by FINTRAC

For more information:

• FINTRAC (CANAFE) – Canada
• Money Services Business (MSB) Guide – FINTRAC
• Large Cash Transaction Reporting – FINTRAC
• Suspicious Transaction Reporting – FINTRAC