1. Policy Purpose & Scope
Simplified Financial Frontier ("the Firm") is committed to the highest standards of legal and ethical conduct in all jurisdictions where it operates. This policy establishes the Firm's absolute and unwavering stance against money laundering, terrorist financing, and related predicate offences (collectively "Financial Crime").
This document outlines the foundational principles and framework of our Global AML Programme, which is designed to ensure compliance with all applicable international standards and local legal requirements in every jurisdiction of our business activities, excluding specifically the United States of America and the United Kingdom.
2. AML Governance & Authority
The Board of Directors of Simplified Financial Frontier bears ultimate responsibility for the approval, resourcing, and oversight of the Firm's Global AML Programme. The Board has appointed a qualified Global Chief Compliance Officer (GCCO) with the direct authority and independence to implement, enforce, and manage this policy across all business lines and subsidiaries.
The GCCO is empowered to establish all necessary procedures, require information from any employee or department, and halt any activity suspected of violating this policy.
3. Core Principles
The Firm's AML operations are built upon the following mandatory principles:
- Risk-Based Approach: The Firm will identify, assess, and understand its money laundering and terrorist financing risks, and will allocate resources and implement controls commensurate with those risks. This includes enhanced due diligence for higher-risk clients, jurisdictions, and products.
- Know Your Customer (KYC): The cornerstone of our controls is the unequivocal verification of client identity and the understanding of the nature of their business, the sources of their wealth and funds, and the purpose of their intended relationship with the Firm. This applies at onboarding and on an ongoing basis.
- Customer Due Diligence (CDD): Standardized procedures for collecting and verifying client identification data (including beneficial ownership for legal persons) are mandatory for all client relationships.
- Enhanced Due Diligence (EDD): For clients, transactions, or geographic areas presenting higher risks, the Firm will apply enhanced scrutiny, requiring additional information and approval from senior management.
- Ongoing Monitoring: All client relationships and transactions are subject to continuous monitoring for consistency with the client's known profile, business, and risk rating. Unusual or suspicious patterns will be investigated promptly.
- Record Keeping: The Firm will maintain complete and accurate records of all client identification data, account files, business correspondence, and transaction data for a minimum period as required by the local law of the relevant jurisdiction, but in any case, not less than seven years after the termination of the business relationship.
- Suspicious Activity Reporting: Any employee who knows, suspects, or has reasonable grounds to suspect that a transaction involves funds derived from illegal activity, is intended to conceal such funds, has no apparent lawful purpose, or is related to terrorist financing, MUST report such activity immediately to the GCCO or designated Money Laundering Reporting Officer (MLRO). The Firm is committed to reporting such activity to the appropriate national Financial Intelligence Unit (FIU) or competent authority in accordance with local legal mandates.
- Sanctions Compliance: The Firm prohibits transactions with individuals, entities, or countries subject to economic sanctions, embargoes, or restrictive measures enacted by the United Nations, the European Union, or other relevant national authorities in jurisdictions where the Firm operates. This policy is independent of, and in addition to, AML controls.
4. Prohibited Activities
Simplified Financial Frontier strictly prohibits:
- Knowingly engaging in any transaction that involves proceeds of unlawful activity.
- Conducting business with shell banks or entities that do not have a physical presence in a jurisdiction where they are authorized to conduct business.
- Maintaining anonymous accounts or accounts in fictitious names.
- Accepting cash payments above limits defined in internal procedures.
- Intentionally structuring transactions to avoid regulatory reporting thresholds.
- Doing business with any person or entity listed on relevant international or local sanctions lists.
5. Training & Awareness
All employees, contractors, and relevant third parties acting on behalf of the Firm are required to undergo regular, mandatory training on AML obligations, the Firm's specific policies and procedures, and the recognition of red flags indicative of money laundering or terrorist financing. Refusal to complete such training will result in disciplinary action.
6. Independent Audit
The Global AML Programme will be subject to periodic, independent internal audit review to assess its effectiveness and compliance with this policy and applicable law. Findings will be reported directly to the Board of Directors or its designated Audit Committee.
7. Enforcement & Discipline
Violation of this policy by any employee will result in severe disciplinary action, up to and including summary dismissal. The Firm will also pursue all available legal remedies and will cooperate fully with law enforcement and regulatory authorities in any investigation related to potential money laundering or terrorist financing.
8. Policy Review
This Global AML Policy will be reviewed and updated annually, or more frequently as required by significant changes in regulation, the Firm's risk profile, or the nature of its business.
This policy statement represents Simplified Financial Frontier' commitment to combating financial crime. For questions regarding this policy, please contact our Compliance Department.
