In order to comply with the Republic of Lithuania Law “On the Prevention of Money Laundering and Terrorist Financing”, other legislative acts of the Republic of Lithuania, together with the requirements established by the EU AML Directives, the Simple Europe UAB (hereinafter referred to as “Simple”, “we” and/or “us”) has developed the following AML/KYC Policy in order to prevent and mitigate the risk of illegal financial activity on its Website/mobile app.
In this document, Simple explains how we provide the risk assessment, verification process and monitoring of transactions of our users (hereinafter referred to as “you”
) at the Simple Website
(hereinafter referred to as the “Website”
) and/or its mobile app. This document also forms an integral part of the Terms & Conditions
(hereinafter referred to as “T&C”) for using the Website.
1. IDENTITY VERIFICATION (KYC)
1.1. Simple’s identity verification procedure requires you to provide us with a valid document that helps us identify you, together with your selfie, before establishing a business relationship with Simple. Simple will require Users to provide valid government-issued proof of identity documents and may ask for proof of address documents. Such documents include:
1.1.1. For natural persons (proof of identity):
- international passport or governmental ID;
- driving license (only for EEA residents);
- residence permit (only for EEA residents).
1.1.2. For natural persons (proof of address):
- bank statement (issued within the last 3 months);
- utility bill for gas, electricity, water, internet, etc. linked to the property (issued within the last 3 months);
- letters from a recognized public authority or public servant/any government-issued correspondence;
- current lease agreement with signatures of the landlord and the tenant;
- credit card statement;
- employer’s certificate for proof of residence;
- house purchase deed.
1.2. For legal entities:
- legal form, head office (address), address of actual operation;
- registration number;
- an extract of registration and its date of issue;
- PoA for authorized person (in case of need). An authorized person shall also be verified with Simple as a natural person.
1.3.However, Simple is also entitled to request additional documents from you whether there are reasonable doubts regarding your activity at the Website and/or its mobile app and due to your domicile country, or in any other cases, including, but not limited to:
- Belonging to a Politically exposed person (PEP status);
- Abnormal activity on the account within a short period of time (linked transactions);
- Belonging to the sanction list of countries, determined below.
1.4. Simple also reserves its right to verify your identity on an ongoing basis, especially when your identification information has been changed. In addition, we are entitled to request up-to-date documents from you, even though you have passed identity verification in the past
1.6. Simple shall keep your documents at its disposal within the whole timeframe of the relationship between you and us and at least within 8 (eight) years upon its termination, irrespective of nature of such termination. However, please kindly note that this timeframe may be prolonged due to regulatory requirements. Additional information related to how we collect, process and store your Personal Data you may find here
2. AML/CFT MEASURES
2.1. Simple uses a risk-based approach while monitoring the transactional activity on the Website and/or mobile app, which encompasses the following:
- the risk assessment of your business activities using certain factors;
- the risk mitigation to implement controls to handle identified risks;
- keeping your identification and, if required for your sector, beneficial ownership information up to date; and
- the ongoing monitoring of financial transactions that pose higher risks.
2.2.All transactions on the platform are also automatically analyzed for suspicious patterns by the AML system. If a transaction or your activity, in general, raises suspicion, the case is then investigated by Simple’s Compliance Department. You hereby accept and agree that your transactions may be suspended within the investigation.
2.3. In accordance with our policies Simple does not open accounts and does not process transactions for citizens and residents of countries, where transactions are prohibited by international sanctions or internal law regulations, or countries based on various criteria selected by Simple’s Compliance Department. Currently, these countries are: Afghanistan, Australia, Belarus, Bosnia and Herzegovina, Burundi, Central African Republic, China, the Democratic Republic of the Congo, Eritrea, Guinea, Guinea-Bissau, Haiti, Iran, Iraq, Japan, Lebanon, Libya, Mali, Myanmar (Burma), Nicaragua, North Korea (DPRK), Russian Federation, South Sudan, Somalia, Sudan, Syria, Tunisia, United Kingdom, Venezuela, Yemen, Zimbabwe, Abkhazia, Cambodia, Federal Republic of Ambazonia, Gabon, Honduras, Kosovo, Niger, Pakistan, South Ossetia, Tajikistan, Transnistria, Turkmenistan, USA.
3. COMPLIANCE OFFICER
3.1. Simple’s AML/KYC policy implementation is examined by our Compliance department. Additionally, we appointed an AML Officer, who acts as a contact person of the FCIS (Financial Crime Investigation Service of Lithuania) and performs AML/CTF duties and obligations of Simple. Our AML Officer holds relevant education, professional suitability, abilities, personal qualities, experience and impeccable reputation required for performance of the duties listed below. Our AML Officer has been coordinated with the regulatory body of the Republic of Lithuania.
Last update of this AML/KYC Policy: November 03.11.2023.