COMPLIANCE

First Global Money Inc.’s activities are closely regulated and monitored by state and federal agencies. Federal regulations classify money transmitters such as the First Global Money Inc. as an MSB and thereby impose certain obligations. First Global Money Inc. must be compliant with the relative legislative guidelines in each country within which it operates.

First Global Money Inc is registered with FinCEN in the U.S. and FINTRAC in Canada. First Global Data Corporation is registered with FINTRAC in Canada. Both First Global Data Corporation/First Global Money Inc. ensure that it is fully compliant with the legislative requirements in each of these countries.

Compliance in Canada and the United States

Noemi Pesina

Compliance Officer

5733 Rickenbacker Road,

Commerce, CA, 90040

Compliance within Canada

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) is Canada's financial intelligence unit. Its mandate is to facilitate the detection, prevention and deterrence of money laundering and the financing of terrorist activities, while ensuring the protection of personal information under its control.

Money Laundering: http://www.fintrac.gc.ca/fintrac-canafe/definitions/money-argent-eng.asp
Financing of Terrorist Activities: http://www.fintrac.gc.ca/fintrac-canafe/definitions/terrorist-terroriste-eng.asp

Proceeds of Crime (Money Laundering) and Terrorist Financing Act

The Proceeds of Crime (Money Laundering) Act was amended in December 2001 to become the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

The object of the PCMLTFA is:

  • to implement specific measures to detect and deter money laundering and the financing of terrorist activities to facilitate the investigation or prosecution of money laundering and terrorist financing offences, including
    • establishing record keeping and client identification requirements for financial services providers and other persons that engage in businesses, professions or activities that are susceptible to being used for money laundering, and the financing of terrorist activities,)
    • requiring the reporting of suspicious financial transactions and of cross-border movements of currency and monetary instruments, and
    • establishing an agency that is responsible for dealing with reported and other information;
  • to respond to the threat posed by organized crime by providing law enforcement officials with the information they need to investigate and prosecute money laundering or terrorist financing offences, while ensuring that appropriate safeguards are put in place to protect the privacy of persons with respect to personal information about themselves; and
  • to assist in fulfilling Canada's international commitments to participate in the fight against transnational crime, particularly money laundering and the fight against terrorist activities.

First Global Data Corporation/First Global Money Inc has a full compliance team and compliance regime which incorporates compliance checks and balances into its system with the intent of automating and thus minimizing the human error component which should serve to maintain the highest level of compliance.

Terrorist Property Reporting and Terrorist List Scanning

In 2001, Canada passed the United Nations Suppression of Terrorism Regulations under the United Nations Act. These provide for a list of individuals or entities believed to be involved in or associated with terrorist activity. They make it an offence for anyone in Canada, or any Canadian outside Canada, to provide or collect funds if they know these would be for use by anyone on the list. These Regulations also make it an offence for anyone in Canada, or any Canadian outside Canada, to deal in any way with property if they know it is owned or controlled by anyone on the list. This includes any financial service or transaction relating to such property. It also includes making property available to anyone on the list.

Compliance within United States

At First Global Money Inc. we are highly committed to strict compliance with state and federal laws for the prevention and control of money laundering and terrorist financing, it is very important that you note the following:

United States Transactions

Financial Crimes Enforcement Network www.fincen.gov FinCEN is part of United States national initiative to combat money laundering and terrorist activity financing.

Important Information for Consumers - What you need to know – The Financial Crimes Enforcement Network, or FinCEN was created to safeguard the financial system from illicit use and combat money laundering and promote national security through the collection, analysis, and dissemination of financial intelligence and strategic use of financial authorities as part of a US government initiative to fight money laundering and terrorist financing, both domestically and internationally. Businesses and industries who must report to FinCEN are required to know their clients and asking for ID is one way to do that. Can I see some ID please? The Bank Secrecy Act “BSA” and the USA PATRIOT Act. The BSA is sometimes referred to as an "anti-money laundering" law ("AML") or jointly as "BSA/AML." Several AML acts, including provisions in Title III of the USA PATRIOT Act of 2001, have been enacted up to the present to amend the BSA. (See 31 USC 5311-5330 and 31 CFR Chapter X [formerly 31 CFR Part 103]) requires financial institutions and others covered by the legislation to identify customers who conduct financial transactions such as: depositing funds, purchasing a life insurance policy or buying a money order. The Act also requires them to keep records and identify their clients.

Under the BSA/AML, you are required to provide Government issued valid identification such as a driver’s license, or similar type of document. There are other requirements and that we might prompt to ask you for more information about the transaction you are conducting.

To find out more about the BSA/AML, FinCEN, and the fight against money laundering and terrorist financing, visit FinCEN's Web site at: www.fincen.gov.

You agree to comply with applicable laws and regulations. You may not use your account or related services for any illegal transactions or activity, e.g. those prohibited by the Unlawful Internet Gambling Enforcement Act, 31 U.S.CF. Section 5361 et. Seq. You agree to indemnify us from every action, proceeding, claim, loss, cost and expense (including attorney’s fees) suffered or incurred by us due to any U.S. or foreign government entity seizing, freezing or otherwise asserting or causing us to assert control over any funds of yours (or ours) when purportedly caused by, or arising out of, your action or inaction. This will apply whether or not such action is ultimately determined to be authorized under the laws of the U.S. or its territories, or any foreign jurisdiction. We are not required to inquire or determine the authority of any action taken by the U.S. or foreign government entity prior to acceding to any legal process initiated by it. Please note that your agreement to comply with applicable laws and regulations includes United States economic sanctions laws and regulations, including regulations issued by the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury, and Executive Orders issued by the President of the Unites States.

First Global Money Inc. is a Licensed Money Transmitter

First Global Money Inc. (NMLS ID 1149715)

First Global Money Inc. is licensed as a Money Transmitter by The Georgia Department of Banking & Finance

First Global Money Inc. is licensed as a Money Transmitter by The New York Department of Financial Services

United States Transactions

Right to Refund: The following provision applies only for customer originating in Canada (except in the province of Quebec): "You, the customer, are entitled to a refund of the money to be transmitted as the result of this agreement if First Global Money Inc. does not forward the money received from you within 10 days of the date of its receipt, or does not give instructions committing an equivalent amount of money to the person designated by you within 10 days of the date of the receipt of the funds from you unless otherwise instructed by you. If your instructions as to when the moneys shall be forwarded or transmitted are not complied with and the money has not yet been forwarded or transmitted, you have a right to a refund of your money. If you want a refund, you must mail or deliver your written request to First Global Money Inc. at 555 Richmond St. W., Suite 604, Toronto, Ontario, M5V 3B1. For inquiries please email us at customerservice@firstglobalmoney.com / For customer service please call us at 1 (877) 793-7171.

Right to Refund: The following provision applies only for customer originating in USA (service is not available in all states):You, the customer, are entitled to a refund of the money to be transmitted as the result of this agreement if First Global Money Inc., does not forward the money received from you within 10 days of the date of its receipt, or does not give instructions committing an equivalent amount of money to the person designated by you within 10 days of the date of receipt of funds from you unless otherwise instructed by you. If your instructions as to when the moneys shall be forwarded or transmitted are not complied with and the money has not yet been forwarded or transmitted, you have a right to a refund of your money. If you want a refund, you must mail or deliver your writing request to First Global Money Inc., ATTN: Customer Service, 5733 Rickenbacker Road, Commerce, CA 90040. Note: This is a general policy please refer to your receipt for specific details of the right to refund as per your state of residence provided at the time of your registration. It is the Client’s responsibility to verify the information in this receipt is correct, in case of Cancellation the money will be reimbursed after confirmation that the transaction was not paid, at the same exchange rate specified in this receipt, minus the corresponding cancellation expenses. First Global Money Inc. is not responsible for transactions paid erroneously as a consequence of incorrect information provided and contained in this receipt.

Errors and Complaints

You have a right to dispute errors in your Transaction. If you think there is an error, contact us within 180 days of the Transaction at 1-877-793-7171 or online. You can also contact us for a written explanation of your rights.

You can cancel for a full refund within 30 minutes of authorizing your Transaction, unless the funds have already been deposited into the account of your Recipient.

We will make every effort not to debit your Payment Instrument after we have received your request for cancellation. However, in some cases, we may have initiated an irreversible request for funds from your financial institution prior to receiving your request for cancellation. In such cases, your Payment Instrument may be debited even if you have cancelled your Transaction but we will refund your money usually within four (4) business days after we have received the funds from your financial institution. Refunds will be credited to the same Payment Instrument used to pay for the Transaction. Refunds are only made in U.S. Dollars. Refund amounts will not be adjusted to account for changes in the value of the U.S. Dollar or foreign currency from the time your Transaction was submitted.

For questions or complaints about the Service, contact us online; by telephone at 1-877-793-7171 or by mail at First Global Money Inc. Customer Service, 5733 Rickenbacker Road, Commerce, CA 90040, USA.

Please let us know if you have any problems with the Service. You can contact us using the contact information below.

ALL consumer complaints must be submitted in writing.

If you have complaints or other concerns with respect to any aspect of the money transmission activities conducted with First Global Money Inc., You may contact us by email at customerservice@firstglobalmoney.com or by telephone at 1(877) 793-7171. You can direct unresolved complaints to regulatory authorities listed under Customer Complaints link.

Fraud Prevention

Help protect yourself from fraud. You should never use the Service to send money to strangers. Be careful if you are asked to send a money transfer to claim a prize and/or lottery ticket. Send money only to someone you know, or whose identity you can verify. Never provide information about your money transfer over the phone if you are not able to confirm who is the person calling you.If you have sent a money transfer and suspect fraud, please call First Global at (877) 793-7171 immediately to stop your transaction if the transfer has not yet been paid your money will be refunded.

Contact Information

Questions, notifications, and requests for refunds or further information can be sent to the Company, as follows: by telephone at 1(877) 793-7171 by email at customerservice@firstglobalmoney.com or by mail at First Global Money Inc., Attn: Customer Service, 5733 Rickenbacker Road, Commerce, CA 90040, USA.

NEED OUR HELP? Email us or call us anytime customerservice@firstglobalmoney.com (toll free) or 1(877) 793-7171