AML Policy

Last updated: June 2026

1. Commitment

Payca Group maintains a zero-tolerance policy toward money laundering, terrorist financing, and any related financial crime. This policy applies to all entities within the group, including Actisas OÜ (Estonia) and Parex Finance Inc. (Canada).

2. Regulatory Framework

Parex Finance Inc. operates as a registered Money Services Business (MSB) under FINTRAC, licence C10001707, with RPAA registration in progress with the Bank of Canada. Actisas OÜ operates under applicable EU AML directives. All operations are subject to ongoing regulatory oversight.

3. MLRO Function

Payca Group maintains a dedicated Money Laundering Reporting Officer (MLRO) - Evaldas Jurevicius, ICA Certificate with Merit in Financial Crime Prevention (Oct 2020) - responsible for overseeing AML compliance, reporting obligations, and staff training across all group entities.

4. KYB and Client Due Diligence

All business clients are subject to a rigorous Know Your Business (KYB) process prior to onboarding. Enhanced due diligence is applied to clients in higher-risk categories. Ongoing monitoring is conducted throughout the business relationship.

5. Transaction Monitoring

Payca Group employs automated and manual transaction monitoring systems. Unusual or suspicious activity is escalated to the MLRO and reported to the relevant financial intelligence unit where required by law.

6. Independent External Audit

AML policies and procedures are subject to periodic independent external audit. Audit findings are reviewed by senior management and used to continuously improve the compliance framework.

7. Sanctions Screening

All clients, transactions, and counterparties are screened against applicable sanctions lists including OFAC, EU, UN, and OSFI lists prior to and during the business relationship.

8. Contact

AML-related inquiries may be directed to compliance@payca.vc.