Draft for legal review — not publishable
Complete draft, written from how the platform actually works. It must be reviewed and approved by counsel qualified in Canadian financial services and consumer law before it goes live. Three items still need a factual answer from you, marked in amber below:
- The registered office address
- The governing province
- Confirmation of the legal entity name after the Kunye rename
Terms of Use
Last updated: 21 September 2026
Effective: on publication
These terms are a contract between you and Kunye Financial Inc., trading as Five Four Financial. They govern your use of our website, our mobile applications, your wallet, and every payment you make through us.
Please read them. By opening an account or using the service you agree to them. If you do not agree, do not use the service.
Two things we want you to notice now, because they matter more than the rest: money in your wallet is not a bank deposit and is not insured by CDIC (section 5), and once we have begun processing a payment instruction you usually cannot cancel it (section 8).
1. Who we are
Kunye Financial Inc., trading as Five Four Financial, is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Services Business, registration number M21256121.
Registered office: [REGISTERED OFFICE ADDRESS]
In these terms, "we", "us" and "our" mean Kunye Financial Inc. "You" and "your" mean the person or business using the service.
Registration with FINTRAC is a registration, not a licence, and it is not an endorsement. We say so plainly here because presenting it as approval would be misleading. Counsel should confirm the wording FINTRAC expects.
2. Who may use the service
To open a personal account you must:
- Be at least 18 years old, or the age of majority where you live if that is higher
- Be resident in Canada and have a Canadian address
- Hold a Canadian bank account in your own name
- Be acting for yourself, not on behalf of someone else, unless we have agreed otherwise in writing
- Pass our identity verification
- Not appear on any sanctions list we are required to screen against
To register as a vendor you must additionally be a business or sole trader lawfully able to sell the goods or services you list, and provide the business information we ask for.
One person may hold one personal account. We may refuse an application, and we do not have to give a reason where telling you would compromise a compliance process.
3. Your account
You are responsible for your account. That means:
- Giving us information that is true, complete and current, and updating it when it changes — particularly your address, which our payments partner requires
- Keeping your password and security answer to yourself
- Not letting anyone else use your account
- Telling us immediately at support@fivefourfinancial.com if you think someone has got into your account
Payments made from your account before you tell us about a compromise are treated as authorised by you, unless section 12 applies.
4. Identity verification
Canadian anti-money-laundering law requires us to verify who you are before you can move money. We use Sumsub, a specialist verification provider, to do this. You will be asked for a government photo identity document and a photograph of yourself.
We may re-verify you at any time, and we may ask for further documents — proof of address, proof of the source of your funds, or an explanation of a particular payment. Where the law requires us to obtain this, we cannot process your payments until you provide it.
If verification fails, you may ask us to have the outcome reviewed by a person. Write to support@fivefourfinancial.com.
5. Your wallet
Your wallet holds a balance you can use to make payments through the service. Balances are held in sub-wallets at our regulated payments partner, separately from our own operating account.
Your wallet is not a bank account
Money in your wallet is not a deposit. It is not insured by the Canada Deposit Insurance Corporation or any equivalent scheme. It earns no interest. We are not a bank and we do not lend your balance out.
You may withdraw your balance to a bank account in your own name at any time, subject to any hold under section 11.
This section must describe the actual custody arrangement at the date of publication. The settlement model is under review, and how customer funds are segregated is a material disclosure — do not publish this paragraph until it is confirmed true.
6. Adding money
You can add money to your wallet by Interac e-Transfer from a Canadian bank account in your own name. We do not accept cash, cheques, credit cards, or transfers from an account belonging to someone else.
Funds normally appear in your wallet shortly after your bank releases them. Your own bank's limits and processing times apply to the transfer and are outside our control.
If a transfer arrives that we cannot match to your account, or that comes from a third party, we will return it to the sending account and may ask you about it.
7. Exchange rates and fees
Before you confirm any payment we show you the fee, the exchange rate, and the amount your recipient will receive. That is the full cost from us. Nothing is added afterwards.
Our current fees are published on our website. We charge 1.5% of the amount you send, with a minimum of CAD $5.00. Where currency is converted, we apply the mid-market rate plus a margin of 0.9%. There is no monthly fee and no charge for holding a balance.
The rate we quote is held for the short period shown on screen. If you do not confirm within that period, we will requote.
We may change our fees. We will give you at least 30 days' notice by email before an increase takes effect, and the change will not apply to a payment you have already confirmed.
Your own bank, or your recipient's bank, may charge you separately. We do not control those charges and cannot refund them.
The fee figures above are placeholders pending your pricing decision. They appear here and on the landing page, and both must be updated together.
8. Payment instructions
When you confirm a payment you are instructing us to send it. We act on that instruction. We do not check that the recipient details you gave us are correct, and we cannot verify that the name you typed matches the account number you typed.
Check the account details before you confirm
If you give us the wrong account number, the money may go to the wrong person and we may not be able to get it back. We will try, and we will tell you what we find, but we cannot promise recovery.
Once we have begun processing an instruction it usually cannot be cancelled. If you want to try, contact us immediately at support@fivefourfinancial.com with the transaction reference. We will stop the payment if it has not yet been released.
Most payments complete within minutes. Some take a few hours, depending on the banks involved and the compliance checks we are required to run. These are typical times, not a guarantee.
We may decline an instruction where we are required or entitled to under section 11, where your balance is insufficient, or where the recipient's country is not one we serve.
9. Paying vendors
The platform lets you order goods and services from vendors and pay for them from your wallet. When you do, the contract for those goods or services is between you and the vendor. We are not the seller.
This means the vendor, not us, is responsible for:
- Describing what they are selling accurately
- Delivering it, and delivering it on time
- Its quality, safety and fitness for purpose
- Any warranty, return or refund they offer
We do not verify the quality of what vendors sell, and listing a vendor is not a recommendation. Raise a problem with the vendor first. If you cannot resolve it, tell us — we hold the record of the payment and can help establish what happened, and we may remove a vendor who repeatedly fails their customers.
Where we can see that a payment was taken for an order the vendor never fulfilled, we will work with our payments partner to recover it, though we cannot guarantee recovery.
10. Cover planners
Our cover planners — starting with the family health cover planner — help you compare what a particular thing costs and set it up from Canada. They are planning and referral tools.
When you use a planner:
- What the planner shows you is guidance, not advice. It is not medical advice, insurance advice, financial advice, legal advice or tax advice.
- Any policy you take out is issued by a licensed provider in the destination country, through a licensed broker partner. We are not the insurer and we are not your broker.
- The provider's own terms, exclusions, waiting periods and claims process govern the cover. Read them. We will show you where to find them before you commit.
- Prices and availability shown are indicative until the provider confirms them.
- Claims are handled by the provider, not by us.
We may receive a commission or referral fee from a provider or broker when you take out cover through a planner. Where we do, we will tell you so on the planner before you proceed.
Referring Canadian residents to insurance products is a regulated activity in most provinces. Counsel must confirm what licensing, disclosure and referral-fee rules apply before the health planner goes beyond testing, and whether this section is sufficient.
11. Limits, holds and screening
We apply limits to how much you can hold and send. Your limits depend on the level of verification you have completed and are shown in your account. We may change them, and we may lower them where we have a compliance concern.
We screen every payment. We may delay, hold, decline or reverse a payment, and freeze a balance, where:
- The law requires it, or a regulator or court directs it
- A sanctions or politically-exposed-person screen returns a match
- We reasonably suspect fraud, money laundering, terrorist financing or other financial crime
- We need further information from you and have not received it
- There is a dispute over the money
We will tell you when we do this and why, unless the law forbids us from doing so — which, in the case of a suspicious transaction report, it does. We are not liable for loss caused by a hold we were required or reasonably entitled to apply.
12. Errors and unauthorised payments
Check your transaction history. If you see a payment you did not authorise, or an amount that looks wrong, tell us within 60 days of it appearing. Email support@fivefourfinancial.com with the transaction reference and what is wrong.
We will acknowledge you within two business days, investigate, and tell you the outcome in writing within 30 days, or explain why we need longer.
If we made the error — we processed an amount you did not instruct, took a fee we did not disclose, or applied a rate other than the one we quoted — we will put it right and refund what we took in error.
If the payment was unauthorised and you did not act fraudulently and did not fail to keep your credentials secure, we will restore your balance. Where you gave your password to someone else, or ignored a security warning, you may bear the loss.
13. Refunds and returned payments
If a payment cannot be delivered — the account is closed, the details are wrong, the receiving bank rejects it — the money is returned to your wallet. Where currency was converted, it is converted back at the rate applying when the return is processed, which may be worse than the rate you got. That difference is not something we can absorb.
Our transfer fee is refunded when a payment fails for a reason within our control or our partner's. It is not refunded where the payment failed because the details you gave were wrong.
Refunds for goods or services are a matter for the vendor, under section 9.
14. If you are a vendor
Vendors accept everything above, and additionally agree that:
- You will describe your goods and services accurately, including price, availability and delivery time
- You will only list what you are lawfully entitled to sell, and you hold any licence your business requires
- You will fulfil orders you accept, and tell the customer promptly if you cannot
- You will handle customer complaints and returns yourself, fairly and without delay
- You will give us the business and beneficial-ownership information we need to meet our obligations, and keep it current
- We may withhold settlement of a payment that is disputed, or that we have reason to believe is fraudulent, until the matter is resolved
- We may suspend or remove your listing where you breach these terms or repeatedly fail to deliver
Settlement timing and any vendor fees are set out in your vendor agreement with us. Where that agreement conflicts with these terms, the vendor agreement governs.
15. Things you must not do
You must not use the service:
- For anything unlawful, including money laundering, terrorist financing, sanctions evasion, tax evasion or fraud
- To move money for someone else, or to disguise where money came from or where it is going
- To pay for weapons, illegal drugs, stolen goods, counterfeits, or any illegal service
- To run a payment service, a currency exchange, or any money services business of your own on top of ours
- With false information, a false identity, or someone else's documents
- To gamble, where gambling is unlawful for you
- To attempt to break, probe, overload or reverse-engineer the platform, or to access an account that is not yours
- To scrape, copy or resell any part of the service
Doing any of these is a serious breach. We will close your account and, where the law requires, report you.
16. Suspension and closure
You may close your account at any time. Withdraw your balance first, or tell us where to send it. Closing your account does not end obligations either of us already owes.
We may suspend or close your account:
- Immediately, where you breach section 15, where we are legally required to, or where we reasonably suspect financial crime
- Immediately, where verification fails or you will not give us information the law requires us to hold
- On 30 days' notice, for any other reason, including a decision to stop serving a market
If we close your account we will return your balance to a bank account in your name, less anything you owe us, unless the law prevents us from releasing it.
We keep your records after closure for as long as anti-money-laundering law requires. See the Privacy Policy.
17. Our liability
We will provide the service with reasonable care and skill. We do not promise it will always be available or uninterrupted. We may take it down for maintenance and will give notice where we can.
We are not liable for:
- Loss caused by incorrect details you gave us
- The acts or omissions of a vendor, an insurer, a broker, your bank or your recipient's bank
- Delay or failure caused by something outside our reasonable control, including bank outages, network failures, and changes in law
- Loss caused by a hold or refusal we were required or reasonably entitled to apply
- Movements in exchange rates
- Indirect or consequential loss, or loss of profit, revenue, business or opportunity
Where we are liable, our total liability for any claim is limited to the greater of the fees you paid us in the 12 months before the claim arose, and the amount of the transaction the claim concerns.
Nothing in these terms limits liability for fraud, for our own wilful misconduct, or for anything that cannot lawfully be limited — including rights you have under consumer protection legislation that cannot be excluded.
18. Complaints
If something has gone wrong, tell us. Email support@fivefourfinancial.com and put "Complaint" in the subject line. Include your name, what happened, and the transaction reference if there is one.
What we will do:
- Acknowledge you within two business days
- Give you a written answer within 30 days, or explain why we need longer and when you will hear
- Tell you what we found, what we are doing about it, and what you can do next if you are not satisfied
Confirm with counsel whether an external complaints body applies to an MSB, and name it here if so. A complaints procedure that ends with us is weaker than one that names an escalation route.
19. Privacy
How we handle your personal information is set out in the Privacy Policy, which forms part of these terms. In short: we collect what the law and the service require, we share it with our verification provider, our payments partner and regulators, and we keep transaction and identity records for at least five years because we are required to.
20. Intellectual property
The platform, our name, our logo and everything we have written belong to us or our licensors. You may use the service as intended. You may not copy, adapt, resell or reverse-engineer it.
If you are a vendor, you keep ownership of the content you upload, and you give us permission to display it on the platform for as long as it is listed.
21. Changes to these terms
We may change these terms. Where a change is material — to fees, limits, your liability, or how the service works — we will give you at least 30 days' notice by email or in the app before it takes effect.
Changes required by law, and changes that are in your favour, may take effect sooner.
If you do not accept a change, close your account before it takes effect. Continuing to use the service afterwards means you accept it.
22. Governing law and disputes
These terms are governed by the laws of [PROVINCE] and the federal laws of Canada that apply there. The courts of [PROVINCE] have jurisdiction.
Before going to court, please raise the matter through our complaints procedure in section 18. Most problems are faster to fix that way.
Nothing here affects a right you have to bring a claim in the province where you live, where consumer protection law gives you that right.
23. General
These terms, together with the Privacy Policy and any vendor agreement, are the whole agreement between us.
If a court finds part of these terms unenforceable, the rest continues to apply.
If we do not enforce something straight away, we have not given up the right to enforce it later.
You may not transfer your rights under these terms. We may transfer ours to a company that takes over our business, and we will tell you if we do.
No one other than you and us has any right to enforce these terms.
24. Contact us
Support and complaints: support@fivefourfinancial.com
Privacy: privacy@fivefourfinancial.com
Post: Kunye Financial Inc., [REGISTERED OFFICE ADDRESS]