1. Regulatory status

TokenNest Inc. is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business for dealing in virtual currencies and money transferring, and holds a money-services business licence from Revenu Québec. Registration and licence numbers are shown in the footer of every page and can be verified in the FINTRAC MSB Registry and Revenu Québec's public register. A Chief Compliance Officer, independent of the business and reporting to the board, is responsible for this program; it is reviewed by an independent firm every two years.

2. Identity verification

Every client is identified before their first transaction. Individuals: government-issued photo ID checked against a live selfie, plus address and date of birth; where documents cannot be verified electronically, a second method is used. Businesses: certificate of incorporation, register of directors, identification of every beneficial owner at 25% or more, and ID for each authorised user. Politically exposed persons and heads of international organisations are identified and subject to enhanced due diligence. Information is refreshed on a risk-based schedule and whenever a material change is detected.

3. Transaction monitoring

Transactions are screened in real time against rules tuned for a non-custodial virtual-currency business — first transfers to new external addresses, velocity, structuring below thresholds, mismatches between stated purpose and activity, and known scam patterns. Alerts are reviewed by a compliance analyst and resolved with documented reasoning by a second person. We may delay, request information on, or decline a transaction; the client is informed unless the law prohibits it. Source of funds is requested for individuals at $100,000 CAD and above and for all business clients at onboarding.

4. Sanctions screening

Clients, beneficial owners and payees are screened at onboarding and on every transaction against Canadian sanctions lists (Special Economic Measures Act, Justice for Victims of Corrupt Foreign Officials Act, United Nations Act regulations) and the Criminal Code terrorist-entity list, together with OFAC and UN consolidated lists. We do not serve, or pay to, persons or jurisdictions under comprehensive Canadian sanctions — currently including Russia, Belarus, Iran, North Korea, Syria and Myanmar — or FATF call-for-action jurisdictions. Wallet addresses are screened against blockchain-analytics risk data before funds are sent.

5. Reporting obligations

We file with FINTRAC: large virtual currency transaction reports for $10,000 CAD or more (single or aggregated within 24 hours); suspicious transaction reports whenever there are reasonable grounds to suspect money laundering or terrorist financing; and terrorist property reports where required. Records of client identification and of virtual-currency transfers of $1,000 CAD and above are kept for five years. We cooperate with lawful requests from FINTRAC, Revenu Québec and law enforcement. We do not report to the Canada Revenue Agency on clients' behalf; clients are responsible for their own tax reporting.

6. Contact the Compliance Officer

[email protected] · TokenNest Inc., Chief Compliance Officer, 401 West Georgia Street, Vancouver, BC V6B 5A1. Suspected fraud or scam activity involving a TokenNest client can be reported to the same address; wallet addresses reported to us are flagged across our monitoring and shared with other registered platforms where the law allows.