This statement most recently updated May 2024; this information is based on periodically revised regulatory guidance and requirements and as such should not be taken as a comprehensive list of compliance requirements.
Transactions Prohibited by Central 1
Payments facilitated by Central 1 must not involve the countries, or the types of entities, industries, and accounts listed in this section. If Central 1 detects any such transaction, it will be frozen, returned, or cancelled, as applicable and as may be required by law, and the responsible financial institution will be notified.
Prohibited Countries
- Crimean Region of Ukraine
- Democratic People’s Republic of Korea (i.e. North Korea)
- Iran
- South Sudan
- Sudan
- Syria
Prohibited Types of Entities/Industries
- Shell bank (a financial institution that does not have a physical presence in Canada or any other country)
- Corporate bearers share entities and similar anonymous-owner entities whose shares or certificates are issued in bearer form, enabling ownership to change hands instantaneously.
- Illegal narcotics
- Payments involving unlawful internet gambling.
- Illegal pornography / illegal adult entertainment
- Human trafficking
- Offshore banks
- Illegal distribution of arms & munitions
- Terrorism & terrorist related financing
Prohibited Types of Accounts
- Special name account (Any account using a pseudonym or a number rather than the actual name of the client.)
- Payable-through account (where the account holder (client), is a foreign financial institution)
- Any other account for a business whose activities are prohibited by applicable law or regulation.
Non-CAD Wire Restrictions
In addition to the prohibitions above, Central 1 will not facilitate the sending or receiving of non-CAD wire transfers that is operating in one of the following high-risk industries:
- Money services businesses, including currency exchanges, money transmitters, casas de cambios
- Casinos and gambling establishments
- Internet gambling/gaming associated businesses and websites
- Cannabis providers and/or distributors
- Payment services providers
- Virtual currency exchanges, providers, administrators, miners and NFT and blockchain related transactions
Transactions restricted under this Section will be frozen, returned, or cancelled, as applicable and as may be required by law, and the responsible financial institution will be notified. Restrictions apply even if the Client is operating in accordance with all applicable laws, although exceptions may be granted on a case-by-case basis. Clients that wish to apply for an exception determination should engage Central 1 to conduct enhanced due diligence before submitting a wire transfer involving a client in one of the restricted industries.
Clients, Counterparties and Countries Deemed High-Risk by Central 1 and its International Wire Transfer Providers
Central 1 and its international wire transfer providers treat the clients, counterparties and countries listed in this section as high-risk, and will conduct enhanced due diligence (“EDD”) dependent on the results of ongoing monitoring. As part of this EDD process, Central 1 may request information from its clients.
Clients and Counterparties Deemed High Risk by Central 1
- Certain entities subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act:
- Agents of the Crown that sell or redeem money orders.
- Accountants and accounting firms when acting on behalf of their clients.
- Real estate brokers, sales representatives, and developers involved in the purchase or sale of real estate.
- Dealers in precious metals and stones
- Public notaries and notary corporations of British Columbia when acting on behalf of their clients
- Payments involving arms and munition dealers.
- Payments related to crowdfunding platforms.
- Payments related to transactions in penny stocks or microcap securities.
- Payments involving auctions including online auctions.
- Payments related to transactions in penny stocks or microcap securities.
- Payments involving adult oriented services (where such services are permitted by law)
- Gatekeepers (e.g. lawyers)
- Charities and Non-Governmental Organisations (NGOs), whether registered or not
- Money services businesses, including currency exchanges, money transmitters and casas de cambios
- Casinos and gambling establishments
- Internet gambling/gaming associated businesses and websites
- Cannabis providers and/or distributors
- Payment services providers
- Travel and tour companies.
- General trading companies
- Embassy/consulate/military attaché
- Used vehicle dealers.
- Virtual currency exchanges, providers, administrators, miners and NFT and blockchain related transactions
Countries with Additional Risk Classifications
Central 1 and its international wire transfer providers refer to Canadian and international sanctions lists and other resources to determine which countries are prohibited or high-risk.