AML Policy

Last Updated: November 3rd, 2022

  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 law enforcement agencies when users engage in activities contrary to this policy. 

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).

  1. Compliance Program

Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations, SDT has an Anti-Money Laundering (“AML) & Anti-terrorist Financing (“ATF”) program that consists of these five elements.

  1. Written policies and procedures: these list our responsibilities under the law, and what we are doing to meet them;
  2. A documented Risk Assessment: a document that describes and assesses the risk that our business could be used to launder money or finance terrorism;
  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: testing and reporting completed either annually or every two years that assesses how well our compliance program is working; and
  5. Training: conducted at least annually to ensure that everyone understands his or her roles and responsibilities.
  1. Operational Compliance

In addition to our documented program that consists of the five 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, and
  • Keeping all user and transaction records and sanction related documents in a manner required by applicable law.