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Compliance Procedures


Last Updated: 15 September 2015

As a world leader in foreign tuition exchange services, NorthStar Currency is committed to ensuring that our practices and procedures comply with all anti-money laundering and anti-terrorism financing regulations. Our professional staff follow strict trading and settlement procedures. They are fully trained in the detection, prevention and reporting of suspicious illicit activity.

NorthStar Currency traders employ a strict “Know Your Customer” philosophy as the most effective means of monitoring client activity. Our compliance department continually consults jurisdictional legislation to ensure that our compliance program meets or exceeds international requirements. An ongoing internal audit process and regular professional training of our trading staff and administrative personnel ensure that NorthStar Currency maintains the highest standards of compliance.

Clients should assume all information provided to NorthStar Currency is available to regulatory authorities in both the country of origin of the funds, and the destination country of the funds.

NorthStar will not accept cash in payment for foreign exchange transfers. NorthStar Currency will only pay into a bank account at the receiving end. It will not pay out cash under any circumstances.

NorthStar Currency reserves the right to refuse to process a transfer at any stage, where it believes the transfer to be connected in any way to money laundering or criminal activity. NorthStar Currency is prohibited from informing a client that they have been reported for suspicious activity.

NorthStar Currency is obliged to report all suspicious transactions. By misusing the service, you may face criminal prosecution as we are bound to automatically report such behaviour to the authorities. Examples of misuse include, but are not limited to:

Breaking a large transaction into smaller transactions to avoid reporting
Providing false or misleading contact details
Providing false identification documents

Links:
FINTRAC

Privacy Policy

Responsibility

1. NorthStar Currency is responsible for all personal information you provide to it and will deal with that information in accordance with the following Privacy Principles.

2. NorthStar Currency has implemented procedures to implement its Privacy Principles and to deal with complaints and enquiries. Our Compliance Officer has overall responsibility for ensuring that NorthStar Currency and its employees and agents comply with our Privacy Principles. Our Compliance Officer may be contacted in relation to any enquiry or complaint at: info@northstarcurrency.com

3. NorthStar Currency will not disclose any of your personal information to a third party, or a foreign country, unless the recipient is subject to legislation, or a contract, that safeguards your personal information in a manner that is substantially similar to our Privacy Principles.

4. The Privacy Principles should be read in conjunction with NorthStar Currency’s Client Agreement.

Privacy Principles

Purpose

1. NorthStar Currency will collect personal information only for the purpose of providing its services to you or for any purpose that is directly incidental to the provision of those services. In the event that NorthStar Currency wishes to use your personal information for any other purpose, it will identify such purpose and obtain your consent before doing so, unless the new purpose is required by law.

2. NorthStar Currency is always willing to explain to you the purposes for which your information is being collected.

Consent

1. NorthStar Currency will seek your consent to the use of your personal information either expressly or impliedly, depending on the circumstances and the type of information collected. For example, NorthStar Currency will rely on your implied consent when you give us your name, address, telephone number and other details necessary for us to verify your identity in accordance with the provisions of the Client Agreement.

2. Your consent may also be given by an authorized representative or a person having Power of Attorney.

3. You may withdraw your consent at any time, subject to any legal restrictions and subject to any contractual restrictions you have already entered into with us, and provided that you give us reasonable notice in writing. We will explain to you the implications of such withdrawal.

4. If you are registered with NorthStar Currency, we may from time to time send you information that is relevant to the provision of our services. If, at any time, you do not wish to receive that information, you may by sending us an email opt-out and request that you are not included in any future mail-outs.

5. There may be circumstances in which NorthStar Currency is obliged to collect, use, or disclose certain personal information without your consent. Such circumstances include:

a serious and imminent threat to someone’s life, health or safety;
a serious threat to public health or public safety;
unlawful activity has been, is being or may be engaged in;
disclosure is required or authorized by law;

5. NorthStar Currency reasonably believes that the use or disclosure is necessary for the prevention, detection, investigation, prosecution or punishment of:
criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;
the enforcement of laws relating to the confiscation of the proceeds of crime;
the protection of the public revenue;
the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or
the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.

6. If NorthStar Currency is obliged to use or disclose your personal information under paragraph 5, it will create a written report of the use or disclosure.

Limiting Collection and Retention of Information

1. The amount and type of information collected by NorthStar Currency will be limited to that which is necessary to provide our services.

2. NorthStar Currency will make reasonable efforts to inform you if we have collected personal information about you from someone else.

3. Personal information shall be retained only for as long as may be necessary for the fulfilment of the purpose for which the information is collected. However, you should be aware that NorthStar Currency is obliged under relevant anti-money laundering and counter-terrorism legislation to retain information relating to personal identity for 7 years.

4. Subject to any legislative requirements, NorthStar Currency will destroy, erase, or make anonymous your personal information when it is no longer required to fulfil the purpose for which it has been collected.

Accuracy

1. NorthStar Currency will make reasonable efforts to ensure that your personal information is sufficiently accurate, complete, and up-to-date to minimise the possibility that inappropriate information may be used to make a decision about you.

2. NorthStar Currency will not routinely update your personal information, unless such a process is necessary to fulfil the purposes for which the information was collected. In accordance with the Client Agreement, you must notify us as soon as possible if any of the information you have provided to us has changed.