AML Policy

Last Updated: May 19th, 2023

1. Our Commitment

Simply Digital Technologies (SDT) is committed to preventing, detecting and deterring persons engaged in fraud, money laundering and terrorist financing from using SDT products and services. SDT is equally committed to compliance with economic sanctions laws and regulations.

SDT has a no-tolerance fraud, money laundering and terrorist financing policy and actively engages the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), the Royal-Canadian Mounted Police (RCMP) and other Global law enforcement agencies when users engage in activities contrary to this policy and to support our obligations in meeting compliance with AMLTF laws and regulations .

SDT is a reporting entity under current Canadian anti-money laundering (AML) and anti terrorist financing (ATF) legislation and is registered as a Money Service Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). SDT is also registered as an MSB with the Financial Crime Enforcement Network (FinCEN) in the United States and the Estonian Financial Intelligence Unit (FIU) of the Ministry of Finance in Europe.

2. Compliance Program

SDT has established a Global AML program to manage risks associated with Anti-Money Laundering (“AML) & Anti-terrorist Financing (“ATF”) and to comply with applicable law:

  1. Written policies and procedures: these list our responsibilities under applicable law, and the controls in place to ensure our obligations are met;
  2. A documented Risk Assessment: a document that describes and assesses the risks that are applicable to our business, including the risks poses to us by the client;
  3. The appointment of a Compliance Officer: the person who is ultimately responsible to develop and maintain our AML and CTF compliance program;
  4. AML Compliance Effectiveness Reviews: ongoing assessment of the Compliance Program and an independent assessment is completed no later than every 2 years which produces an evaluation of how SDT is meeting its obligations for AMLTF;
  5. Training: conducted at least annually to ensure that everyone understands his or her roles and responsibilities in supporting the firm in meeting our compliance obligations; and
  6. Travel Rule: a formal process in place to screen all transactions so as to apply rule-based settings for  exchanging travel rule data with other applicable stakeholders.

3. Operational Compliance

In addition to our documented program that consists of the six elements, SDT also operates in a FINTRAC compliant manner. This includes:

  • To accept as clients only those individuals and legal entities whose identity and ownership can be adequately ascertained and whose activities can reasonably be established to be legitimate,
  • To not knowingly provide any form of financial services to clients who money is believed to be derived from the proceeds of crime of activity that violate sanctions, or whose money is believed to be intended for use for illegal activities,
  • To cooperate with regulators, law enforcement agencies and financial intelligence units in accordance with applicable law,
  • To review new product and services and delivery channels and associated systems, acquisitions, mergers, joint ventures, policies and procedures, as well as significant changes to any of them, to ensure that the associated AML/CTF risk is within SDT’s risk appetite and that appropriate internal controls are in place to mitigate identified risks.
  • Collecting and recording client identification and know your customer (KYC) information, in accordance with legal requirements, prior to granting users access to our platform,
  • Reporting certain types of transactions to regulators and government agencies including, but not limited to, transactions suspect to be originating from or connected to terrorist, money laundering, tax evasion, fraud or other illegal activities,
  • Maintaining appropriate registration and licensing,
  • Keeping all user and transaction records and sanction related documents in a manner required by applicable law,
  • Utilizing industry approved third party solutions to provide a service and to meet our AMLTF obligations (Example: KYC, travel rule and reporting), and
  • Maintaining proactive measures to comply with changes to applicable AMLTF regulations.