Compliance Statement

Last updated April 17, 2024

Your Trust, Our Commitment.

Introduction

This document sets out our risk appetite for compliance and financial crime, and reflects our stance on how much risk we are willing to accept in pursuit of our business objectives, without compromising our integrity, regulatory obligations, or the trust of our customers, partners, and regulators.

Our Commitment

At Yousend, we recognise that innovation in the fintech space demands agility, but not at the cost of compliance. We embed compliance in every layer of our operations, seeing it not as a constraint, but as a competitive advantage. We aspire to lead in the global fight against financial crime by proactively identifying threats, setting high internal standards, and maintaining transparency across all jurisdictions we operate in.

Scope of this Statement

This Risk Appetite Statement applies to:

  1. All business units, products, and services offered by Yousend.
  2. All employees, contractors, and affiliates
  3. Our operations across Canada, United Kingdom, Europe, Africa, and any new market we enter as we grow in the remittance business.

Core Risk Appetite Statement

  1. At Yousend, we are deeply committed to maintaining the highest standards of compliance, security, and financial integrity. We recognize the critical importance of protecting our users, preventing financial crime, and ensuring regulatory adherence in every jurisdiction we operate within. Our risk appetite is guided by the following principles:
  2. We prioritize regulatory compliance above all else, ensuring that every aspect of our operations adheres to both local and international laws. Our policies are designed to meet or exceed the regulatory requirements of every country we serve.
  3. We maintain an unwavering commitment to safeguarding our platform from illicit activities, including money laundering, fraud, and terrorist financing. We take immediate action to prevent exposure to customers, transactions, or jurisdictions linked to high financial crime risks.
  4. We conduct thorough customer due diligence (CDD) and ongoing monitoring to ensure that each customer is vetted in line with our strict risk policies. We go beyond basic checks to verify identities, assess transaction behaviors, and ensure compliance with all anti-money laundering (AML) regulations.
  5. Yousend operates exclusively within specific corridors and has a zero-tolerance policy for engaging with jurisdictions that fall outside our internal compliance standards. These restrictions remain in effect even in the event of future expansion. Specifically, Yousend will not engage in any activities involving the following:
    1. Countries or territories subject to international sanctions, or flagged by global regulatory bodies such as FATF and OFAC as having strategic deficiencies in their anti-money
    2. Jurisdictions with systemic weaknesses in the oversight of financial institutions, particularly where local efforts to prevent financial crime are inadequate or ineffective.
  6. Our culture is built on accountability and transparency, with continuous training to ensure that every decision made reflects our high standards. We are dedicated to maintaining the integrity of our services and ensuring that our operations remain secure, compliant, and transparent.At Yousend, we are committed to keeping cross-border payments simple and secure, ensuring a safe experience for everyone.

Sanctions Compliance Statement

  1. Yousend enforces a strict zero-tolerance policy toward dealings with sanctioned individuals, entities, or jurisdictions. Our sanctions compliance program is designed to ensure full adherence to international sanctions regimes, including those issued by Canadian authorities, the United Nations Security Council, the U.S. Office of Foreign Assets Control (OFAC), the UK Treasury, the European Union, and any other relevant regimes in countries where we operate.
  2. All customers and transactions are subject to screening through robust, real-time systems at onboarding and throughout the business relationship. We implement geolocation controls and monitoring tools to prevent access from or within sanctioned regions, and we investigate and escalate any potential matches without delay. Where required, we report such cases to the appropriate regulatory or enforcement bodies.
  3. Yousend does not support or facilitate any activity that may directly or indirectly expose the company to sanctions risk. Even where an engagement may technically be permitted under applicable sanctions laws, Yousend reserves the right to decline business with any individual or entity linked—directly or indirectly—to sanctions exposure, reputational concerns, or elevated geopolitical risk.

Prohibited Countries

  1. Yousend currently provides cross-border payment services within specific corridors and will not engage in any activities involving jurisdictions deemed high-risk, subject to comprehensive sanctions, or otherwise unsuitable based on our internal risk appetite. Even in the event of future expansion, YouSend will not operate in countries or territories that are:
    1. subject to comprehensive international sanctions;
    2. considered high-risk for financial crime; or
    3. not formally sanctioned but present elevated risks due to regulatory uncertainty, geopolitical instability, or other financial crime concerns.
    We will not provide services in the following countries:

Belarus

Afghanistan

Bahamas (The)

Botswana

Cambodia

Congo (Republic)

Cuba

DR Congo

Eritrea

Guinea Bissau

Haiti

Iraq

Jamaica

Lebanon

Libya

Mali

Mongolia

Myanmar

Nicaragua

Pakistan

Panama

Zimbabwe

Somalia

South Sudan

Sudan

Uganda

Venezuela (RB)

Yemen (Republic)

Russian
Federation

Central African Republic

Iran (Islamic Republic)

Korea (Dem. People's Rep)

Syrian Arab Republic

Trinidad and Tobago

West Bank and Gaza (Palestine)

  1. This list is reviewed regularly and may be updated based on changes in global sanctions, emerging risks, or adjustments to our internal risk appetite. YouSend employs geolocation and monitoring tools to ensure compliance with these restrictions.

Prohibited Industries

  1. Yousend does not support or facilitate transactions involving industries, business models, or activities that pose an unacceptable risk of financial crime, regulatory non-compliance, or reputational harm. This includes businesses that are illegal, unregulated, or incompatible with our internal risk appetite regardless of their legal status in a given jurisdiction. We may also restrict services to industries that, while not necessarily illegal, present elevated risks due to lack of regulatory oversight, ethical concerns, or exposure to opaque ownership structures. We will not provide services to the following industries:

Agriculture and Forestry

  1. Animal Welfare. Animal testing unless this is required by law and done in the least harmful way
  2. Animal Welfare. Commercial events with animals where the Five Animal Freedoms are not respected
  3. Animal Welfare. Producing, processing and/or trading Angora wool
  4. Animal Welfare. Producing, processing and/or trading fur
  5. Animal Welfare. Using endangered species or great apes for testing and experimental purposes

Chemicals and Substance

Defence

Drugs and psychotropic substances

Energy

  1. Energy. New coal-fired power plants. Generation of electricity from thermal coal
  2. Energy. Stand-alone project finance of nuclear power plants

Entertainment

  1. Entertainment. Adult conten
  2. Entertainment. Dating

Finance

  1. Binary Options and/or speculation financial products platforms.

General Exclusions

  1. General exclusions. Activities causing adverse human rights impacts
  2. General exclusions. Activities causing adverse human rights impacts
  3. General exclusions. Sanctioned individuals
  4. General exclusions. Shell banks
  5. General exclusions.Transactions involving Human Organs

Mining

  1. Acquisition or building of thermal coal mines

Prohibited Goods and Services

  1. Sale, purchase, or distribution of weapons of mass destruction, including firearms, ammunition, explosives, and related accessories.
  2. Facilitating and supporting the distribution of illegal drugs, narcotics, steroids, controlled substances, or other drugs that are unsafe for consumer consumption, or other drugs that are unsafe for consumer consumption or prescription medication without the required licenses.
  3. Unlicensed gambling activities.
  4. Sale or purchase of stolen goods, including virtual assets, Items that infringe upon or violate any copyright, trademark, right of publicity or privacy, or any other proprietary rights.
  5. Activities causing adverse human rights impacts.
  6. Transactions involving Human organ mining.
  7. Producing, processing, and/or trading Angora wool or fur.
  8. Using endangered species or great apes for testing and experimental purposes.
  9. Chemicals and Substance
  10. Generation of electricity from thermal coal and acquisition or building of thermal coal mines.
  11. Stand-alone project finance of nuclear power plants
  12. Adult content production or distribution.
  13. 22 Scam dating website management.
  14. Binary Options and/or speculation financial products platforms.
  15. Activities that violate guidelines, rules, or regulations of SEC, EFCC, NFIU, or other Nigerian/International applicable laws.

Prohibited Jurisdictions

  1. Conducting business in or with countries identified as high-risk jurisdictions for money laundering or terrorist financing.
  2. Engaging in transactions with individuals or jurisdictions listed on international sanctions lists such as:
    1. Consolidated Canadian Autonomous Sanctions List;
    2. United Nations Consolidated Sanctions (UNCS) Lists;
    3. OFAC Consolidated Sanctions List;
    4. OFAC SDN List;
    5. Office of the Superintendent of Financial Institutions (OSFI) List;
    6. Special Economic Measures Act (SEMA) List etc.
  3. Using the platform for speculative trading in jurisdictions where crypto trading is restricted or illegal.
  4. Some of these jurisdictions include, but are not limited to, Afghanistan, Belarus, Burundi, Central African Republic (CAR), Cuba, Democratic Republic of the Congo (DRC), Guinea Bissau, Iran, Iraq, ISIL (Da'esh) and Al-Qaida, Lebanon, Libya, Mali, Myanmar (Burma), Nicaragua, North, Korea (DPRK), Russia, Somalia, South Sudan, Sudan, Syria, Ukraine (Crimea, Donetsk, and Luhansk regions specifically), Venezuela, Yemen, and Zimbabwe.
  5. Engaging in transactions with entities listed on international sanctions lists. Some of these entities include, but are not restricted to, the Iranian Revolutionary Guard Corps (IRGC), Russian Government Entities, North Korean entities, and Hezbollah.
  1. This policy applies to both individual and business customers, and we reserve the right to update our list of restricted sectors as risk factors evolve or as our internal standards are reassessed.

Statement Review Cycle

This statement is reviewed at least annually or upon any of the following events:

  1. A significant regulatory change in any jurisdiction we serve
  2. Launch of a new product or market
  3. A material compliance incident or breach

Closing Note

At Yousend, we don’t see compliance as a back-office function, we view it as the front line of trust. Our risk appetite reflects our ambition to grow responsibly, serve globally, and lead by example in the fintech space.