Customer Anti-Financial Crime Policy

First published:  September 9, 2024

Last updated: September 9, 2024


 

At SimplePro, we are deeply committed to protecting our customers and the financial system from the risks of financial crime. Our anti-financial crime policy is designed to ensure that all transactions on our platform are safe, secure, and fully compliant with the law. We believe that maintaining a secure environment is crucial not only for our business but also for the trust and confidence of our customers. For our Financial Crime Risk Appetite Statement please address here.

 

This policy is a key part of our efforts to safeguard you and other users from illegal activities such as money laundering, fraud, and terrorist financing. By following strict guidelines that align with global standards and regulations, including those set by the Financial Action Task Force (‘FATF’), we aim to create a platform that is both transparent and secure.

 

1. Understanding Financial Crime
 

1.1 What is financial crime? Financial crime encompasses a range of illicit activities, including money laundering, terrorist financing, fraud, bribery, corruption, tax evasion, and sanctions violations. This understanding drives our commitment to implementing robust policies, controls, and monitoring systems to prevent such activities, thereby protecting our clients, stakeholders, and the broader public from the harmful impacts of financial crime. 
 

1.2 Why it matters? Financial crime has serious consequences for everyone involved. It can harm you as a customer by exposing you to risks such as identity theft, loss of funds, or being unknowingly involved in illegal activities. On a larger scale, financial crime can undermine the stability and integrity of the entire financial system, making it more difficult for everyone to conduct business safely and securely. By understanding and preventing financial crime, we help protect your assets, ensure a safer environment for all our customers, and contribute to the overall health of the global financial system. This is why we take financial crime seriously and have put in place strong measures to detect and prevent it.

 

2. Your Role in Preventing Financial Crime
 

At SimplePro, we are committed to maintaining a secure and compliant platform and we need your active participation to help us prevent financial crime. Your obligations as a customer play a critical role in this effort. Here’s what is expected from you:
 

2.1. As a SimplePro customer, you are obligated to:
 

2.1.1. Provide accurate and truthful information. When registering with SimplePro, you must provide accurate and complete information as part of the Know Your Customer process. This includes, but is not limited to, your full legal name, date of birth, address, and any other details we require. It is your responsibility to ensure that this information remains current and to update it promptly if there are any changes. 
 

2.1.2. Comply with verification checks. At any point, SimplePro may require additional verification of your identity or request further documentation as part of our continuous monitoring process. You are obligated to comply with these requests promptly. Failure to do so may result in the suspension or termination of your account.
 

2.1.3. Use the platform responsibly. You must use SimplePro’s services for lawful purposes only. Engaging in activities such as money laundering, fraud, terrorist financing, or any other illegal practices is strictly prohibited. SimplePro reserves the right to refuse or terminate services to any customer involved in such activities without prior notice or explanation.
 

2.2. As a SimplePro customer, you are required to fully cooperate with any investigations or client checks conducted by SimplePro or relevant authorities. This includes providing requested information, documentation, or clarification promptly and complying with any procedures necessary to complete the investigation.
 

2.3. SimplePro continuously monitors all transactions and account activities to detect and prevent financial crime. All transactions on our platform are subject to ongoing scrutiny. We may flag transactions for further investigation if they appear unusual or inconsistent with your typical behaviour.
 

2.4. To maintain the integrity of our platform and comply with legal requirements, SimplePro reserves the right to:
 

2.4.1. Refuse service. We may refuse to provide services or terminate your account at our discretion, particularly if we suspect involvement in financial crime. This decision can be made without prior notice or explanation.
 

2.4.2. Suspend or terminate transactions. If any transaction appears suspicious, SimplePro reserves the right to suspend or terminate it while further investigation is conducted. During this period, access to your account may be restricted.
 

2.4.3. Report suspicious activities. We are obligated to report any suspicious activities to relevant authorities. This includes providing necessary information about you and your transactions as required by law.
 

 

3. Know Your Customer Process
 

The Know Your Customer (‘KYC’) process is a critical part of SimplePro's commitment to preventing financial crime. This process helps us ensure that our platform is secure and that all users are who they claim to be. Here’s what you need to know:
 

3.1. To comply with KYC requirements, SimplePro collects the following types of information from customers:

  • personal identification that includes your full legal name, date of birth, and nationality;
  • your current residential address, email address, and phone number.
  • government-issued identification – a valid passport, national ID card, or driver’s licence.
  • proof of address, such as a recent utility bill, bank statement, or government-issued certificate that confirms your current address.
  • information about your source of funds, source of wealth, and in some cases, details about your employment and annual income.
  • a live selfie to verify that the individual submitting the identification documents is indeed the account holder.
     

3.2. At SimplePro, we take your privacy seriously. The information we collect during the KYC process is used strictly for compliance purposes:

Verification. We use your information to confirm your identity and ensure that you meet the legal requirements to use our platform.

Monitoring. Your information helps us monitor your transactions and account activities for any signs of suspicious behaviour.

Legal compliance. We are required to keep records of your information to comply with anti-financial crime regulations and may need to share it with relevant authorities if required by law.

Rest assured, your information is handled with the utmost care and stored securely in accordance with data protection laws. We do not use your personal data for marketing purposes or share it with third parties unless legally obligated to do so. For detailed information on how we collect, process and store personal information, please address to our Privacy Policy here.
 

3.3. KYC checks are a routine part of your interaction with SimplePro, and they are applied in the following circumstances:

Account registration. When you first sign up for an account, we will request KYC information to verify your identity before you can start using our services.

Periodic reviews. Even after your account is active, we may periodically ask you to update your information or provide additional documents to ensure everything is current.

Triggered by red flags. If any unusual or suspicious activity is detected in your account, we may initiate additional KYC checks. This could include requests for more information or enhanced due diligence procedures.

High-risk activities. Certain transactions or activities that involve higher risk may require additional KYC checks. This ensures that we maintain a secure platform for all users.


 

4. Transaction Monitoring
 

At SimplePro, we are dedicated to ensuring the safety and security of all transactions on our platform. Our transaction monitoring process is a key part of this commitment, allowing us to detect and prevent potential financial crimes.
 

4.1. We continuously monitor all transactions on our platform to detect any suspicious or unusual activities. Here’s how the process works:

  • we use cutting-edge technologies, including blockchain analytics and machine learning algorithms, to analyse transaction patterns. These tools help us identify any unusual behaviours that might indicate fraudulent activity, money laundering, or other financial crimes.
  • our systems operate in real time, which means we are able to detect and flag suspicious transactions as they happen. This allows us to take immediate action if something looks out of the ordinary.
  • even after a transaction is completed, it may be reviewed as part of our ongoing monitoring efforts. This helps us identify patterns over time that might not be apparent in a single transaction.
     

4.2. If our monitoring systems flag a transaction as potentially suspicious, we take several steps to ensure that your account and our platform remain secure:

Investigation. When a transaction is flagged, it enters an investigation process. Our compliance team reviews the transaction details to determine whether it poses a risk. 

Possible delays. During the investigation, the flagged transaction may be temporarily delayed or held. This is to ensure that any risks are thoroughly evaluated before the transaction is allowed to proceed.

Communication. If your transaction is flagged, you may be contacted by our team for additional information or clarification. This is to help us resolve any questions and ensure that your transaction can be completed safely.

Resolution. Once the investigation is complete, the transaction will either be cleared and processed, or it may be cancelled. In some cases, we may also be required to keep holding the transaction to report the transaction to the relevant authorities.
 

4.3. SimplePro may temporarily freeze a transaction if it is deemed necessary during an investigation or as part of client checks. This precautionary measure is taken to ensure the security of our platform and compliance with regulatory requirements. If your transaction is frozen, you will be notified promptly, and you can contact our security team at security@simplepro.io for further guidance. We will work diligently to resolve the issue and resume normal operations as quickly as possible.
 

4.4. SimplePro is committed to maintaining the confidentiality of all flagged transactions and the information associated with them. When a transaction is flagged as suspicious, the details are handled with the utmost confidentiality and in strict adherence to our internal policies and relevant regulations. This ensures that your personal and transactional information is protected throughout the investigation process, and only authorised personnel have access to it.


 

5. Dealing with High-Risk Customers and Transactions
 

5.1. While most transactions on SimplePro are straightforward, some may require additional scrutiny due to higher risk factors. For these situations, we apply Enhanced Due Diligence (‘EDD’) procedures to ensure the highest level of security and compliance.
 

5.2. If your account or transaction is subject to EDD, here’s what you might experience:

  • you may be asked to provide more detailed information, such as extra identification documents, proof of income, or details about the source of funds involved in the transaction.
  • because EDD is a more thorough process, it can take longer to complete than standard checks. This might result in delays in processing your transactions.
  • your account may be subject to more frequent or detailed monitoring to ensure ongoing compliance with our policies.
  • in some cases, if the risks cannot be adequately mitigated, we may place temporary restrictions on your account or transactions until the necessary information is provided and reviewed.
     

5.3. SimplePro applies additional scrutiny to customers identified as Politically Exposed Persons (PEPs) due to the higher risks associated with their positions. PEPs, including government officials and their close associates, must disclose their status during registration and throughout their relationship with SimplePro. For PEPs, we conduct EDD, gathering extra information and closely monitoring their transactions for any unusual activity. Any relationship with a PEP requires approval from senior management, and suspicious activities may be reported to relevant authorities. If the risks linked to a PEP cannot be adequately managed, SimplePro reserves the right to refuse or terminate services.


 

6. Staying Informed
 

6.1. At SimplePro, we are committed to keeping our policies up-to-date with the latest regulations and best practices. Our Anti-Financial Crime Policy may be revised periodically to reflect changes in laws, emerging risks, or enhancements to our procedures. You can always find the most current version of this policy on our website. We encourage you to review it regularly to stay informed about any updates that may affect your use of our platform.

6.2. As a customer, it is important that you stay informed about the latest changes to our policies. Keeping yourself updated ensures that you understand your role in helping us maintain a secure and compliant environment. By staying informed and adhering to the policy, you contribute to the safety and integrity of SimplePro’s services.


 

7. How to Contact Us
 

If you have any questions about this policy, need further clarification, or wish to report suspicious activities, we’re here to help. You can reach our customer support team at: support@simplepro.io

For reporting urgent or sensitive issues, such as suspected financial crime, please contact us immediately at: security@simplepro.io