Anti-Money Laundering Policy

Preventing financial crimes and maintaining the integrity of our operations

Our Commitment

Pivot Airlines is committed to preventing our business from being used for money laundering, terrorist financing, or other financial crimes. We comply with all applicable anti-money laundering laws and regulations, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

Money laundering is the process of concealing the origins of illegally obtained money. As a business that handles financial transactions, we have a responsibility to ensure our services are not used to facilitate these crimes.

Red Flags to Watch For

  • Unusual or unexplained payment methods or requests
  • Requests to structure transactions to avoid reporting requirements
  • Customers or transactions involving high-risk jurisdictions
  • Reluctance to provide required identification or documentation
  • Transactions that appear inconsistent with normal business activities
  • Complex or unusual payment arrangements without clear business purpose

Employee Obligations

  • Know Your Customer (KYC): Verify the identity of customers and business partners
  • Report suspicious activities to the appropriate authorities
  • Maintain accurate records of all financial transactions
  • Complete required anti-money laundering training
  • Cooperate with internal and external audits and investigations

Insider Trading & Securities

Employees who have access to material non-public information about Pivot Airlines or our business partners are prohibited from trading securities based on that information or sharing it with others who might trade. Violations of insider trading laws can result in severe criminal and civil penalties.

Reporting Suspicious Activity

If you suspect money laundering or other financial crimes, report it immediately to your supervisor or through our confidential reporting channels. Do not attempt to investigate or confront suspects yourself. All reports will be handled confidentially and investigated thoroughly.