Anti–Money Laundering & Anti-Terrorist Financing (AML/ATF) Policy

Stygvir Inc.
Effective Date: 23 November, 2025

1. Purpose

This policy establishes Stygvir Inc.’s framework for preventing money laundering and terrorist financing, in compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated Regulations.

Although Stygvir is not a financial institution, our activities involving precious metals and high-value equipment require appropriate due diligence when onboarding or transacting with third parties.

2. Scope

This policy applies to all owners, directors, employees, contractors, and representatives involved in sales, procurement, customer onboarding, and business operations.

3. Company Activities Covered

Stygvir may engage in activities considered higher-risk for AML/ATF, including:

• Sale of high-value laser welding and precision-manufacturing equipment.
• Occasional handling of precious metal products (e.g., wire purchases, sample materials).
• Cross-border transactions with international suppliers and clients.
• Refunds, high-value orders, or unusual payment methods.
  

While Stygvir is not a reporting entity under FINTRAC by default, we voluntarily maintain AML controls as part of supply-chain compliance.

4. AML/ATF Compliance Officer

Stygvir designates the following individual as its AML Officer:

Name: Sergey Vetrogonov

Title: Director, Stygvir Inc.

Responsibilities:

• Oversee AML/ATF compliance.
• Conduct ongoing risk assessments.
• Review transactions for suspicious indicators.
• Maintain records and documentation.
• Liaise with suppliers requesting AML evidence.

5. Customer Due Diligence (CDD / KYC)

5.1. Business Clients (B2B)

Before engaging in a high-value transaction (typically CAD $3,000+), Stygvir will collect and verify:

• Legal business name and operating name.
• Business address.
• Names of directors/owners.
• Nature of the business.
• Business registration numbers.
• Tax numbers (HST/QST, as applicable).
  

If a client is purchasing precious metals, or paying unusually large amounts, Stygvir may request:

• Proof of business registration (Articles of Incorporation, GST/HST number, or similar).
• Identification of an authorized signing individual.
• Website or social presence confirming business legitimacy.
  

5.2. Beneficial Ownership

Where applicable, Stygvir will request:

• Names of individuals owning or controlling 25% or more of a business.
• Verification through corporate registries, business filings, or government-issued ID.
  

5.3. High-Risk Situations

The following require enhanced due diligence (EDD):

• Unusual payment methods (crypto, multiple prepaid cards, third-party payor).
• Customers requesting to remain anonymous.
• Clients with no verifiable business presence.
• Transactions inconsistent with the nature of the customer’s business.
• Requests involving rapid movement of funds without legitimate explanation.

6. Recordkeeping

Stygvir will retain the following records for at least 5 years:

• Customer identification information.
• Invoices and contracts.
• Payment records and method of payment.
• Notes on due diligence and risk assessment.
• Any correspondence related to AML reviews.
  

Records will be stored securely and accessible only to authorized personnel.

7. Risk Assessment

Stygvir performs ongoing risk assessments considering:

• Type of client (established business vs. unknown entity).
• Jurisdiction (Canada vs. high-risk countries, as per FATF lists).
• Nature of transaction (equipment vs. precious metals).
• Payment method (bank transfer vs. cash-like instruments).
  

Transactions are categorized as Low, Medium, or High Risk, and documentation is maintained accordingly.

8. Suspicious Transaction Identification

Stygvir will NOT proceed with a transaction if any of the following red flags appear without a legitimate explanation:

• Customer is reluctant to provide basic company information or ID.
• Attempts to use third parties to mask identity.
• Requests for unusual refunds or circular transactions.
• Inconsistent business profile (e.g., small shop buying unusually large quantities).
• Transactions routed through high-risk jurisdictions.
• Customer involved in negative news (fraud, sanctions, financial crimes).
  

In such cases, Stygvir may:

• Request additional documentation.
• Decline or pause the transaction.
• Inform relevant authorities if required.

9. Sanctions & Screening

Stygvir screens clients and suppliers against:

• Public sanctions lists (UN, Canada, OFAC).
• Any known terrorist financing lists or government advisories.
• Negative media checks.
  

No business will be conducted with sanctioned individuals/entities.

10. Training

All individuals involved in sales and procurement will receive periodic training on:

• AML/ATF risks relevant to precious metals and high-value equipment.
• Identifying suspicious activity.
• Recordkeeping requirements.
• Communication protocols.
• Updating and maintaining due diligence records.

11. Reporting Obligations

If Stygvir becomes aware of potential money laundering, terrorist financing, or sanction-evading activities, the AML Officer will:

• Assess the situation.
• Determine if escalation to legal authorities is required.
• Decline or terminate the transaction.
  

Stygvir commits to full cooperation with law enforcement.

12. Supplier & Partner AML Cooperation

Stygvir acknowledges the AML expectations of its partners, including precious metal suppliers, and will:

• Provide due diligence documentation upon request.
• Maintain internal AML controls aligned with PCMLTFA.
• Participate in compliance audits when applicable.

13. Review & Updates

This policy will be reviewed annually or upon:

• Regulatory changes.
• Material changes to Stygvir’s business model.
• Supplier audits or requests.
• Identified compliance gaps.