How the firm is regulated.
Titan Exchange Group is a money services business under Canadian law. This page sets out what that means, what we ask of clients, how client funds are held, and what to do if something goes wrong.
I. Registration
Titan Exchange Group Inc. is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business. Registration can be verified in FINTRAC's public registry of money services businesses.
Registration means the firm is subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations, and to examination by FINTRAC. It is not an endorsement of the firm or its services by FINTRAC or by the Government of Canada.
II. Our compliance program
The Act requires every money services business to maintain a compliance program with five elements: an appointed compliance officer; written policies and procedures; a documented assessment of the money-laundering and terrorist-financing risks in the business; ongoing training; and a review of the program's effectiveness at least every two years. Titan maintains each of them, and the first effectiveness review falls due two years after registration.
Our compliance officer is [name to be confirmed], who can be reached at steven@titanfx.ca.
III. Knowing our clients
Every client is identified before a first trade. For a company, that means confirming its existence and its directors, and obtaining and confirming beneficial-ownership information for every individual who owns or controls twenty-five percent or more of it. For an individual, it means identification by one of the methods the regulations permit. We determine whether a client is a politically exposed person where the law requires it, and we monitor client activity on an ongoing basis. Where we cannot complete identification, we do not trade.
These are the same checks a bank performs. They apply to every client equally, and they are done once.
IV. Reporting and record keeping
Like every money services business, we report to FINTRAC international electronic funds transfers of C$10,000 or more, and any transaction we have reasonable grounds to suspect is related to money laundering or terrorist financing. We do not accept cash. We keep client identification and transaction records for at least five years. These obligations are set by law and are not discretionary.
V. Client funds
Client funds are held separately from the firm's own funds, [in segregated client accounts at a Canadian financial institution to be named], and only for as long as settlement requires. They are not used for the firm's own purposes. Titan is not a bank, and funds held with it are not insured by the Canada Deposit Insurance Corporation. The client agreement sets out the mechanics of settlement in full, and we explain them before onboarding.
VI. Market commentary
The Desk Notes, and the exchange rates shown on this site, are exactly what the note pages say: General market commentary from the desk, not investment advice and not an offer to trade. Rates shown are the Bank of Canada daily average for the date and are indicative only; ask the desk for a dealable quote.
VII. Complaints
If something goes wrong, write to our compliance officer at steven@titanfx.ca or at the email address below. We acknowledge every complaint within [five] business days and respond in full within [thirty] days. [Escalation route, if any, to be confirmed with counsel.]
VIII. Privacy
How we handle personal information, including the records the Act requires us to keep, is set out in our Privacy Policy.
IX. Contact
Titan Exchange Group Inc.
365 Bay St., 7th Floor
Toronto, ON M5H 2R2
steven@titanfx.ca