Disclosures · risk & regulatory— effective · 15 Apr 2026

The risks you
take, stated plainly.

Zemoon is regulated, but regulation is not insurance. This page sets out the regulatory status of the Company, the protections that do and do not apply to funds we hold on your behalf, and the risks inherent to the services we provide.

Effective
15 Apr 2026
Version
v2.1
Scope
corporate
Review
annual
01
Regulatory disclosures

Two registrations, publicly verifiable.

Both registrations are listed on the respective supervisor's public registry. Verification is encouraged before engagement.

Registry · public
Verify · with supervisor
FINTRAC
MSB registration · N300000349

Money Services Business Registration

Framework
Proceeds of Crime (Money Laundering) and Terrorist Financing Act
Supervisor
Financial Transactions and Reports Analysis Centre of Canada
Issued
12 Jun 2023
Verify
via public register
Bank of Canada
PSP · active

Payment Service Provider Registration

Framework
Retail Payment Activities Act
Supervisor
Bank of Canada · Retail Payment Supervision
Issued
01 Nov 2024
Verify
via public register
02
Deposit & insurance status

Funds are not deposit-insured.

Zemoon is not a bank. Funds held with us are not Canada Deposit Insurance Corporation (CDIC) insured deposits. They are safeguarded — which is different from insured — under the framework below.

CDIC · not insured
Safeguarding · Schedule I banks
§ 01 · Not a bank
Funds held with Zemoon are not insured by CDIC.
Zemoon is a registered payment service provider and money services business — not a Canadian deposit-taking institution. CDIC deposit insurance does not apply to balances held with us. The protection you have is provided by the safeguarding framework described to the right.
Safeguarding framework
Segregated safeguarding accounts
Client funds held at Schedule I Canadian banks in accounts separate from the Company's operating balances.
Operational capital segregated
The Company's working capital is held in a distinct set of accounts and never commingled with client funds.
Daily reconciliation
Daily reconciliation of safeguarded balances against client liabilities, with monthly independent attestation.
Insolvency priority
In the event of insolvency, safeguarded client funds are pooled and distributed to clients on a pro-rata basis, ahead of general creditors.
03
Sanctions & jurisdictional limits

Screening is real-time, not point-in-time.

Lists below are updated continuously and re-applied on every transaction. Hits are blocked at runtime and escalated to the Compliance Office for review.

Cadence · real-time
Lists · 4 primary + FATF
§ 01

OFAC

Office of Foreign Assets Control · United States Treasury. SDN, sectoral and jurisdiction-based lists are screened on every transaction.

§ 02

UN

United Nations Security Council sanctions lists · screened continuously against identity and counterparty data.

§ 03

EU

European Union consolidated sanctions list · applied per EU restrictive-measures framework.

§ 04

HMT

His Majesty's Treasury (United Kingdom) consolidated list · screened on onboarding and transaction.

§ 05

FATF grey-list

Enhanced due diligence applies on a case-by-case basis for jurisdictions on the FATF "jurisdictions under increased monitoring" list.

§ 06

Excluded jurisdictions

Iran, North Korea, Syria, Cuba, Crimea, Donetsk, Luhansk and other comprehensively sanctioned regions are excluded at onboarding.

04
Complaints & dispute resolution

Complaints are handled formally.

Every complaint is logged, acknowledged in writing within two business days, and addressed by a named officer. If you are not satisfied with the internal outcome, external escalation paths are listed below.

Acknowledge · ≤ 2 business days
Resolve · ≤ 30 days
Internal process
Start with the Compliance Office.
Written complaint to ceo@zemoon.pro · acknowledge within 2 business days
Investigation by a named officer independent of the matter
Written response within 30 days with reasoned outcome
Reopening available on presentation of new information
External escalation
If we do not resolve it, these paths are available.
Bank of Canada · for complaints regarding retail payment activities under RPAA
FINTRAC · for matters concerning MSB obligations and record-keeping
Office of the Privacy Commissioner of Canada · for privacy-related complaints
Courts of British Columbia · for matters of contractual dispute under these Terms
05
Conflicts of interest

Conflicts are disclosed, managed, or avoided.

The Company maintains a conflicts register. Matters that cannot be avoided are managed through information barriers, segregation of duties, or escalation to the Chief Compliance Officer.

Register · maintained
Review · quarterly
§ 01
Execution neutrality
The Company does not proprietarily trade against Client instructions. FX liquidity is aggregated from multiple external venues and best-execution principles apply.
§ 02
Staff dealing
Personal account dealing by staff is governed by a written policy requiring pre-clearance and is monitored by Compliance. Trading in virtual assets is restricted for relevant staff.
§ 03
Remuneration
Staff remuneration is not structured to incentivise sales of a specific product, venue or counterparty. Compliance functions report into governance, not into commercial.
Compliance contact

Write to the
Chief Compliance Officer.

Risk questions, supervisor enquiries, complaints, and any material not addressed above should be directed to the Compliance Office. A named officer will respond within two business days.

Email
ceo@zemoon.pro