TRANSFER OF ASSETS POLICY
Effective Date: April 2026
1. General Provisions
This Transfer of Assets Policy (the “Policy”) governs the handling, processing, and execution of client asset transfers conducted through Geloro Pay Ltd (the “Company”), a Money Services Business registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), operating under registration number BC1538819 and headquartered at 1055 West Georgia Street, Suite 2100, Vancouver, British Columbia, V6E 3P3, Canada.
The Company operates exclusively as a non-custodial crypto-asset exchange service provider. It facilitates fiat-to-crypto, crypto-to-fiat, and crypto-to-crypto exchange transactions solely for execution purposes. At no point does the Company take custody, control, or possession of client digital assets, nor does it provide wallet hosting, safekeeping, or asset storage services.
This Policy is designed to ensure that all asset transfer processes are conducted in a secure, transparent, and fully compliant manner in accordance with applicable Canadian regulatory requirements, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), associated regulations, and applicable FINTRAC guidance.
The Company is subject to regulatory oversight by FINTRAC and complies with all applicable reporting obligations, including electronic funds transfer reporting, virtual currency reporting thresholds, and Travel Rule requirements under FATF Recommendation 16.
Clients are entitled, upon request, to access this Policy and any contractual documentation governing their use of the Company’s services. All relevant information relating to fees, procedures, security standards, and service conditions is made available in a durable electronic format through the Company’s website or client communication channels.
The Company may amend this Policy from time to time. Where changes are made, the updated version will be published on the Company’s website and will become effective in accordance with applicable notice requirements.
2. Nature of the Transfer Service
The Company provides a technology-driven execution service that enables clients to initiate and complete digital asset exchange transactions. These services are limited strictly to the facilitation of transfers between fiat currencies and digital assets, or between supported digital assets, for settlement purposes.
The Company does not operate a trading venue, order book, brokerage service, investment platform, or advisory service. All transactions are executed strictly on a client-directed basis.
Clients are required to use externally controlled wallets for all crypto-asset transfers. The Company does not hold private keys, manage wallets, or exercise control over blockchain addresses used by clients.
The execution of each transaction is subject to availability of liquidity, compliance screening, and regulatory requirements. The Company reserves the right to decline, suspend, or delay transactions where required for compliance, risk management, or legal obligations.
3. Fees and Charges
The Company applies a fixed and transparent service fee of 2.5% per transaction on all executed exchange services. This fee is charged on a permanent basis and is incorporated into the final execution price displayed to the client prior to transaction confirmation.
The fee applies uniformly across supported services, including fiat-to-crypto and crypto-to-fiat exchange operations, unless otherwise explicitly disclosed to the client in advance.
In addition to the Company’s service fee, certain transactions may involve external network or blockchain fees. These fees are independent of the Company, are determined by the relevant blockchain network, and are not retained by the Company.
No account maintenance fees, inactivity fees, or hidden charges are applied.
All applicable fees are clearly disclosed to the client before execution of a transaction, and acceptance of the transaction quote constitutes acknowledgment and agreement to the applicable fee structure.
4. Risks Associated with Digital Asset Transfers
Clients acknowledge that digital asset transactions involve inherent risks, including but not limited to market volatility, liquidity constraints, technological disruptions, regulatory changes, and cybersecurity risks.
Blockchain networks are decentralized systems that may experience congestion, delays, forks, or technical failures that can affect transaction timing or execution outcomes.
Clients are solely responsible for maintaining the security of their wallets and private keys. Any loss resulting from compromised credentials, incorrect wallet details, or unauthorized access falls entirely under the client’s responsibility.
The Company does not guarantee market performance, asset valuation, transaction finality timing, or uninterrupted availability of services.
5. Transaction Execution Framework
Each transaction begins when a client submits an instruction through the Company’s platform. Prior to execution, the Company provides a binding quote reflecting prevailing market conditions and liquidity availability. Clients must explicitly confirm acceptance of the quote before execution proceeds.
Once confirmed, transactions are processed through regulated liquidity providers and settlement partners, and where applicable, blockchain networks.
Due to the nature of distributed ledger technology, once a transaction is confirmed on-chain, it is irreversible and final.
The Company ensures that clients are informed of all material transaction details prior to confirmation, including pricing, fees, and applicable execution conditions.
6. Compliance, AML Controls, and Regulatory Monitoring
The Company operates a comprehensive compliance framework aligned with FINTRAC requirements and applicable anti-money laundering and counter-terrorist financing obligations.
All clients are subject to identity verification, sanctions screening, and ongoing risk-based monitoring. Enhanced due diligence measures may be applied where higher-risk indicators are identified.
The Company employs blockchain analytics tools and regulatory screening systems to detect exposure to sanctioned entities, illicit activity, or high-risk jurisdictions.
Where required by law, the Company will report transactions to competent authorities, including FINTRAC, in accordance with applicable reporting thresholds and obligations.
The Company reserves the right to decline or suspend transactions where compliance concerns arise.
7. Transaction Information and Transparency
Clients receive clear pre-transaction disclosures prior to execution, including applicable fees, exchange rates, and execution conditions.
Upon completion of a transaction, clients are provided with full post-execution details, including transaction references, asset amounts, involved addresses (where applicable), and confirmation of settlement status.
All transaction records are retained in accordance with applicable regulatory requirements and are accessible to clients through their account dashboard.
8. Rejection, Suspension, and Risk-Based Controls
The Company may reject, suspend, or return transactions where required under applicable law, compliance obligations, or internal risk policies.
This includes situations involving incomplete information, sanctions exposure, suspicious activity indicators, or regulatory reporting obligations.
Where a transaction is affected, clients are notified through the registered communication channel with sufficient information to understand the reason for the decision and any corrective steps that may be required.
9. Security, Fraud Prevention, and Incident Response
The Company implements industry-standard security measures designed to protect client transactions and platform integrity. These include encryption, authentication controls, monitoring systems, and fraud detection mechanisms.
In the event of suspected fraud, unauthorized access, or security threats, the Company will notify affected clients promptly and take appropriate mitigation measures.
Certain incidents may also be reported to regulatory authorities where required by law.
10. Liability and Error Handling
The Company is responsible only for losses directly resulting from its proven technical or operational errors in the execution of transactions.
Clients must report any suspected unauthorized or incorrect transaction within a reasonable timeframe. Upon receipt of such reports, the Company will investigate and respond within a commercially reasonable period.
The Company is not liable for losses arising from client-side errors, incorrect wallet addresses, third-party service failures, blockchain network conditions, or events beyond its reasonable control.
11. Termination of Services
Clients may terminate their relationship with the Company at any time in accordance with applicable account closure procedures.
The Company may suspend or terminate access to services where required due to legal obligations, compliance concerns, or breach of applicable terms.
Regulatory record-keeping obligations may require the Company to retain certain transaction and identification data for legally mandated retention periods even after termination.
12. Governing Law and Final Provisions
This Policy is governed by the laws of the Province of British Columbia and applicable federal laws of Canada.
Where conflicts arise between this Policy and applicable regulatory requirements, regulatory requirements shall prevail.
The Company reviews and updates this Policy periodically to ensure ongoing compliance with evolving legal, regulatory, and operational standards.
Contact
For questions relating to this Policy, clients may contact:
support@octapex.com