Non Solicitation Policy

Effective Date: 16.04.2025

Entity Name: Xlentpay Corporation

Authorization Number: C100000337

Jurisdiction: Canada

Regulatory Body: Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)

1. Purpose

This Reverse Solicitation Policy outlines the principles and procedures adopted by Xlentpay Corporation (“the Company”) to ensure compliance with applicable laws and regulations in Canada and internationally. It is designed to demonstrate that the Company does not engage in active solicitation or marketing of its services outside the jurisdictions in which it is legally authorized to operate.

2. Scope

This policy applies to all services provided by the Company and governs the onboarding of clients residing outside of Canada. It is applicable to all staff, representatives, agents, affiliates, and any other third parties acting on behalf of the Company.

3. Regulatory Background

The Company is duly registered and authorized as a Money Services Business (MSB) in Canada and authorized by FINTRAC with authorization number C100000337. While the Company is authorized to offer services to clients worldwide, it does so strictly under the principle of reverse solicitation, meaning:

  • The client must initiate the contact with the Company.
  • The Company does not advertise, market, or otherwise promote its services to residents of jurisdictions outside Canada where it does not hold appropriate licenses or regulatory authorizations.

4. Definition of Reverse Solicitation

Reverse Solicitation refers to a situation where a potential client initiates contact with the Company, without any prior solicitation or marketing by the Company or its representatives in the client’s jurisdiction. This includes:

  • Visiting our website independently (not via geo-targeted ads).
  • Directly contacting the Company through email, phone, or online forms.
  • Engaging with the Company after being referred by another client, without inducement or advertising from the Company.

XlentPay is a brand of XlentPay Corporation, registered in Canada with number 1616307-6 and authorized by FINTRAC with number C100000337.

5. No Foreign Marketing or Solicitation

To ensure compliance:

  • The Company does not conduct or authorize marketing campaigns, promotional activities, or public relations efforts in jurisdictions where it does not have appropriate regulatory authorization.
  • The Company does not engage in direct solicitation of clients in foreign countries via email, phone calls, social media advertising, or local intermediaries.
  • No language, imagery, or content on our website, platforms, or documentation shall constitute an invitation to residents of jurisdictions outside Canada, unless otherwise licensed or exempted by local law.

6. Client Onboarding Outside Canada

Clients residing outside Canada may be onboarded under the following conditions:

  • The client independently and voluntarily reaches out to the Company.
  • The client, by accepting our Terms and Conditions, acknowledges that they initiated contact with the Company without any prior solicitation.
  • The client understands that the Company operates under the laws and regulations of Canada, and that their relationship will be governed accordingly.

7. Documentation and Recordkeeping

The Company maintains appropriate records of:

  • The method by which each non-Canadian client made first contact.
  • The signed reverse solicitation declaration confirming the client’s voluntary initiation.
  • All communications evidencing the absence of Company-initiated solicitation.

These records are retained in accordance with FINTRAC compliance and anti-money laundering (AML) requirements.

8. Compliance and Training

All employees and agents are trained on the principles of this policy. Breaches of this policy may result in disciplinary action, including termination of employment or partnership, and may also lead to regulatory penalties.

XlentPay is a brand of XlentPay Corporation, registered in Canada with number 1616307-6 and authorized by FINTRAC with number C100000337.

9. Review and Updates

This policy is reviewed annually and updated as necessary to reflect changes in regulatory requirements, business practices, and international developments.

Contact Information

For more information or questions related to this policy, please contact:

Compliance Department – Andreas Orphanides
Email: [email protected]
Phone: +1 416 800 0984