Complaints Procedure
A. Introduction
Omexi Pay Ltd (“Omexi Pay” or the “Company”) acknowledges that complaints, grievances, and expressions of dissatisfaction are an unavoidable feature of operating in the financial services sector. Rather than being treated as nuisances, complaints represent a critical source of feedback, allowing the Company to identify weaknesses, improve client experience, and strengthen regulatory compliance. Omexi Pay therefore maintains a structured Complaints Handling Policy and Procedure (the “Policy”), designed to make sure that every complaint is addressed promptly, fairly, and in accordance with applicable laws and regulatory expectations. The Policy reflects the Company’s obligations under Canadian legislation, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), as well as broader international best practices. It also supports Omexi Pay’s culture of integrity, accountability, and continuous improvement.
B. Objectives
The objectives of this Policy are to guarantee that all complaints received by the Company are dealt with in a transparent, consistent, and timely manner, to preserve the confidence of clients and stakeholders, and to protect the reputation and regulatory standing of Omexi Pay. Specifically, the Policy is intended to ensure that complainants are treated fairly, that the root causes of complaints are investigated, that remedial measures are applied where necessary, and that records of complaints are systematically maintained for monitoring and oversight purposes. Complaints handling is viewed as an integral part of Omexi Pay’s risk management framework and compliance program.
C. Scope
This Policy applies to all complaints received by Omexi Pay, irrespective of the service line involved, the medium of communication, or the nature of the complainant. It covers complaints raised by existing clients, prospective clients, counterparties, suppliers, and any other external stakeholders who engage with Omexi Pay. It applies to all services offered by the Company, including but not limited to foreign exchange, issuance of virtual IBANs, and ancillary payment services. The Policy applies to all employees, contractors, and authorised representatives of Omexi Pay who are involved in client interactions, complaint intake, or complaint resolution.
D. Definitions
For the purposes of this Policy, a “complaint” is defined as any expression of dissatisfaction made by a client or stakeholder with respect to Omexi Pay’s services, decisions, staff conduct, or business practices, which explicitly or implicitly expects a response. A “complainant” is the individual or organisation lodging the complaint. A “Complaint Handler” is a designated member of staff assigned to investigate and resolve the complaint. The “Compliance Officer” (“CO”) is the senior officer responsible for oversight of the complaints process, ensuring adherence to the Policy, escalating material complaints to senior management or regulators, and maintaining records and reports.
E. Policy Statement
Omexi Pay is committed to treating complaints seriously, investigating them impartially, and resolving them fairly. The Company will provide complainants with timely acknowledgement, clear communication, and reasoned decisions. Complaints will be documented in a centralised register, and confidentiality will be maintained at all stages. The Company will not penalise or disadvantage any person for raising a complaint in good faith. However, Omexi Pay reserves the right to reject complaints that are frivolous, vexatious, abusive, or clearly made in bad faith.
F. Complaints Procedure
All complaints should be submitted to Omexi Pay through the dedicated email address complaints@omexipay.com, by post to the registered office, or directly to an authorised staff member. Complaints should include the name and contact details of the complainant, a clear description of the issue, supporting documents if available, and the outcome sought. Upon receipt, Omexi Pay will acknowledge the complaint in writing within five business days, providing a case reference number and confirming the Complaint Handler assigned.
The Complaint Handler will conduct a thorough review, which may involve examining transaction records, communications, contractual documents, and internal system data, as well as seeking input from staff directly involved. Where a complaint raises regulatory or legal risks, the Compliance Officer will assume oversight. Investigations will be conducted impartially and objectively, with all relevant evidence considered. Omexi Pay aims to resolve complaints within thirty calendar days of receipt. If resolution requires additional time due to complexity, the complainant will be notified of the reason and the revised timeline. Once completed, the complainant will receive a written response outlining the findings, the decision, and any corrective or remedial steps taken.
G. Escalation
If the complainant is dissatisfied with the resolution, they may request an internal escalation. Escalated complaints will be reviewed by the Chief Executive Officer or a designated senior officer not previously involved in the matter. Where complaints raise material concerns regarding compliance with laws, regulations, or internal policies, the Compliance Officer will consider whether the matter should be reported to FINTRAC or other relevant authorities. Escalations will be addressed promptly and independently, and final decisions will be communicated in writing.
H. Record-Keeping
Omexi Pay will maintain a centralised complaints register capturing all relevant details of each complaint, including the complainant’s information, the nature of the complaint, the service line involved, the staff members implicated, the investigation conducted, the resolution outcome, and the closure date. All records will be retained for a minimum of five years and stored securely in accordance with the Company’s data protection framework. Records will be made available to regulators on request.
I. Monitoring and Oversight
The Compliance Officer will review the complaints register regularly to monitor volumes, categories, resolution times, and outcomes. A quarterly complaints report will be presented to senior management, highlighting key trends, systemic risks, and emerging issues. Where serious complaints or patterns are identified, remedial measures may include revisions to policies, amendments to operational procedures, or enhanced staff training. Serious incidents will be escalated immediately to the Board of Directors. Complaints analysis will form part of Omexi Pay’s overall compliance monitoring and continuous improvement program.
J. Confidentiality and Data Protection
All complaints will be treated as confidential. Information will be shared internally only with those directly involved in the investigation or resolution process. Personal data will be processed strictly in accordance with Omexi Pay’s Data Protection Policy and applicable legislation. Complainants retain their rights under privacy laws to request access to their personal information held by the Company.
A. Introduction
Omexi Pay Ltd (“Omexi Pay” or the “Company”) acknowledges that complaints, grievances, and expressions of dissatisfaction are an unavoidable feature of operating in the financial services sector. Rather than being treated as nuisances, complaints represent a critical source of feedback, allowing the Company to identify weaknesses, improve client experience, and strengthen regulatory compliance. Omexi Pay therefore maintains a structured Complaints Handling Policy and Procedure (the “Policy”), designed to make sure that every complaint is addressed promptly, fairly, and in accordance with applicable laws and regulatory expectations. The Policy reflects the Company’s obligations under Canadian legislation, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), as well as broader international best practices. It also supports Omexi Pay’s culture of integrity, accountability, and continuous improvement.
B. Objectives
The objectives of this Policy are to guarantee that all complaints received by the Company are dealt with in a transparent, consistent, and timely manner, to preserve the confidence of clients and stakeholders, and to protect the reputation and regulatory standing of Omexi Pay. Specifically, the Policy is intended to ensure that complainants are treated fairly, that the root causes of complaints are investigated, that remedial measures are applied where necessary, and that records of complaints are systematically maintained for monitoring and oversight purposes. Complaints handling is viewed as an integral part of Omexi Pay’s risk management framework and compliance program.
C. Scope
This Policy applies to all complaints received by Omexi Pay, irrespective of the service line involved, the medium of communication, or the nature of the complainant. It covers complaints raised by existing clients, prospective clients, counterparties, suppliers, and any other external stakeholders who engage with Omexi Pay. It applies to all services offered by the Company, including but not limited to foreign exchange, issuance of virtual IBANs, and ancillary payment services. The Policy applies to all employees, contractors, and authorised representatives of Omexi Pay who are involved in client interactions, complaint intake, or complaint resolution.
D. Definitions
For the purposes of this Policy, a “complaint” is defined as any expression of dissatisfaction made by a client or stakeholder with respect to Omexi Pay’s services, decisions, staff conduct, or business practices, which explicitly or implicitly expects a response. A “complainant” is the individual or organisation lodging the complaint. A “Complaint Handler” is a designated member of staff assigned to investigate and resolve the complaint. The “Compliance Officer” (“CO”) is the senior officer responsible for oversight of the complaints process, ensuring adherence to the Policy, escalating material complaints to senior management or regulators, and maintaining records and reports.
E. Policy Statement
Omexi Pay is committed to treating complaints seriously, investigating them impartially, and resolving them fairly. The Company will provide complainants with timely acknowledgement, clear communication, and reasoned decisions. Complaints will be documented in a centralised register, and confidentiality will be maintained at all stages. The Company will not penalise or disadvantage any person for raising a complaint in good faith. However, Omexi Pay reserves the right to reject complaints that are frivolous, vexatious, abusive, or clearly made in bad faith.
F. Complaints Procedure
All complaints should be submitted to Omexi Pay through the dedicated email address complaints@omexipay.com, by post to the registered office, or directly to an authorised staff member. Complaints should include the name and contact details of the complainant, a clear description of the issue, supporting documents if available, and the outcome sought. Upon receipt, Omexi Pay will acknowledge the complaint in writing within five business days, providing a case reference number and confirming the Complaint Handler assigned.
The Complaint Handler will conduct a thorough review, which may involve examining transaction records, communications, contractual documents, and internal system data, as well as seeking input from staff directly involved. Where a complaint raises regulatory or legal risks, the Compliance Officer will assume oversight. Investigations will be conducted impartially and objectively, with all relevant evidence considered. Omexi Pay aims to resolve complaints within thirty calendar days of receipt. If resolution requires additional time due to complexity, the complainant will be notified of the reason and the revised timeline. Once completed, the complainant will receive a written response outlining the findings, the decision, and any corrective or remedial steps taken.
G. Escalation
If the complainant is dissatisfied with the resolution, they may request an internal escalation. Escalated complaints will be reviewed by the Chief Executive Officer or a designated senior officer not previously involved in the matter. Where complaints raise material concerns regarding compliance with laws, regulations, or internal policies, the Compliance Officer will consider whether the matter should be reported to FINTRAC or other relevant authorities. Escalations will be addressed promptly and independently, and final decisions will be communicated in writing.
H. Record-Keeping
Omexi Pay will maintain a centralised complaints register capturing all relevant details of each complaint, including the complainant’s information, the nature of the complaint, the service line involved, the staff members implicated, the investigation conducted, the resolution outcome, and the closure date. All records will be retained for a minimum of five years and stored securely in accordance with the Company’s data protection framework. Records will be made available to regulators on request.
I. Monitoring and Oversight
The Compliance Officer will review the complaints register regularly to monitor volumes, categories, resolution times, and outcomes. A quarterly complaints report will be presented to senior management, highlighting key trends, systemic risks, and emerging issues. Where serious complaints or patterns are identified, remedial measures may include revisions to policies, amendments to operational procedures, or enhanced staff training. Serious incidents will be escalated immediately to the Board of Directors. Complaints analysis will form part of Omexi Pay’s overall compliance monitoring and continuous improvement program.
J. Confidentiality and Data Protection
All complaints will be treated as confidential. Information will be shared internally only with those directly involved in the investigation or resolution process. Personal data will be processed strictly in accordance with Omexi Pay’s Data Protection Policy and applicable legislation. Complainants retain their rights under privacy laws to request access to their personal information held by the Company.
A. Introduction
Omexi Pay Ltd (“Omexi Pay” or the “Company”) acknowledges that complaints, grievances, and expressions of dissatisfaction are an unavoidable feature of operating in the financial services sector. Rather than being treated as nuisances, complaints represent a critical source of feedback, allowing the Company to identify weaknesses, improve client experience, and strengthen regulatory compliance. Omexi Pay therefore maintains a structured Complaints Handling Policy and Procedure (the “Policy”), designed to make sure that every complaint is addressed promptly, fairly, and in accordance with applicable laws and regulatory expectations. The Policy reflects the Company’s obligations under Canadian legislation, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), as well as broader international best practices. It also supports Omexi Pay’s culture of integrity, accountability, and continuous improvement.
B. Objectives
The objectives of this Policy are to guarantee that all complaints received by the Company are dealt with in a transparent, consistent, and timely manner, to preserve the confidence of clients and stakeholders, and to protect the reputation and regulatory standing of Omexi Pay. Specifically, the Policy is intended to ensure that complainants are treated fairly, that the root causes of complaints are investigated, that remedial measures are applied where necessary, and that records of complaints are systematically maintained for monitoring and oversight purposes. Complaints handling is viewed as an integral part of Omexi Pay’s risk management framework and compliance program.
C. Scope
This Policy applies to all complaints received by Omexi Pay, irrespective of the service line involved, the medium of communication, or the nature of the complainant. It covers complaints raised by existing clients, prospective clients, counterparties, suppliers, and any other external stakeholders who engage with Omexi Pay. It applies to all services offered by the Company, including but not limited to foreign exchange, issuance of virtual IBANs, and ancillary payment services. The Policy applies to all employees, contractors, and authorised representatives of Omexi Pay who are involved in client interactions, complaint intake, or complaint resolution.
D. Definitions
For the purposes of this Policy, a “complaint” is defined as any expression of dissatisfaction made by a client or stakeholder with respect to Omexi Pay’s services, decisions, staff conduct, or business practices, which explicitly or implicitly expects a response. A “complainant” is the individual or organisation lodging the complaint. A “Complaint Handler” is a designated member of staff assigned to investigate and resolve the complaint. The “Compliance Officer” (“CO”) is the senior officer responsible for oversight of the complaints process, ensuring adherence to the Policy, escalating material complaints to senior management or regulators, and maintaining records and reports.
E. Policy Statement
Omexi Pay is committed to treating complaints seriously, investigating them impartially, and resolving them fairly. The Company will provide complainants with timely acknowledgement, clear communication, and reasoned decisions. Complaints will be documented in a centralised register, and confidentiality will be maintained at all stages. The Company will not penalise or disadvantage any person for raising a complaint in good faith. However, Omexi Pay reserves the right to reject complaints that are frivolous, vexatious, abusive, or clearly made in bad faith.
F. Complaints Procedure
All complaints should be submitted to Omexi Pay through the dedicated email address complaints@omexipay.com, by post to the registered office, or directly to an authorised staff member. Complaints should include the name and contact details of the complainant, a clear description of the issue, supporting documents if available, and the outcome sought. Upon receipt, Omexi Pay will acknowledge the complaint in writing within five business days, providing a case reference number and confirming the Complaint Handler assigned.
The Complaint Handler will conduct a thorough review, which may involve examining transaction records, communications, contractual documents, and internal system data, as well as seeking input from staff directly involved. Where a complaint raises regulatory or legal risks, the Compliance Officer will assume oversight. Investigations will be conducted impartially and objectively, with all relevant evidence considered. Omexi Pay aims to resolve complaints within thirty calendar days of receipt. If resolution requires additional time due to complexity, the complainant will be notified of the reason and the revised timeline. Once completed, the complainant will receive a written response outlining the findings, the decision, and any corrective or remedial steps taken.
G. Escalation
If the complainant is dissatisfied with the resolution, they may request an internal escalation. Escalated complaints will be reviewed by the Chief Executive Officer or a designated senior officer not previously involved in the matter. Where complaints raise material concerns regarding compliance with laws, regulations, or internal policies, the Compliance Officer will consider whether the matter should be reported to FINTRAC or other relevant authorities. Escalations will be addressed promptly and independently, and final decisions will be communicated in writing.
H. Record-Keeping
Omexi Pay will maintain a centralised complaints register capturing all relevant details of each complaint, including the complainant’s information, the nature of the complaint, the service line involved, the staff members implicated, the investigation conducted, the resolution outcome, and the closure date. All records will be retained for a minimum of five years and stored securely in accordance with the Company’s data protection framework. Records will be made available to regulators on request.
I. Monitoring and Oversight
The Compliance Officer will review the complaints register regularly to monitor volumes, categories, resolution times, and outcomes. A quarterly complaints report will be presented to senior management, highlighting key trends, systemic risks, and emerging issues. Where serious complaints or patterns are identified, remedial measures may include revisions to policies, amendments to operational procedures, or enhanced staff training. Serious incidents will be escalated immediately to the Board of Directors. Complaints analysis will form part of Omexi Pay’s overall compliance monitoring and continuous improvement program.
J. Confidentiality and Data Protection
All complaints will be treated as confidential. Information will be shared internally only with those directly involved in the investigation or resolution process. Personal data will be processed strictly in accordance with Omexi Pay’s Data Protection Policy and applicable legislation. Complainants retain their rights under privacy laws to request access to their personal information held by the Company.