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Know Your Customer and Anti-Money Laundering Policy


At Totally Simple LTD, we are committed to ensuring the integrity of our services and preventing any illicit activities, including money laundering and terrorist financing. This Know Your Customer and Anti-Money Laundering Policy (hereinafter, the AML/KYC Policy) outlines the procedures and measures we have in place to uphold these standards.

By using our services and entering into an agreement with Totally Simple LTD, you acknowledge and agree to adhere to this AML/KYC Policy. We are dedicated to safeguarding our reputation and ensuring the safety of our partners, which necessitates these stringent policies.

AML Officer

To oversee the implementation of our AML/KYC Policy, we have appointed an Anti-Money Laundering Officer (AML Officer). The AML Officer’s responsibilities include:

(a) Identifying the responsibilities of senior managers and providing them with regular updates on money laundering risks.

(b) Conducting training sessions for relevant employees to ensure they understand and fulfill their anti-money laundering responsibilities, including reporting any suspicious activity.

(c) Documenting and regularly updating our anti-money laundering policies, controls, and procedures.

(d) Introducing measures to ensure that the risk of money laundering is considered in our daily business activities.

Know Your Customer Procedures

To mitigate the risks associated with money laundering, terrorist financing, and other illicit financial activities, we have implemented Know Your Customer (KYC) procedures. KYC requirements are designed to verify the identity of our customers and confirm their authenticity.

KYC involves obtaining and verifying the following customer information:

– Full name

– Residential address

– Date of birth

Verification is performed through identity documents, such as passports or driving licenses, and proof of current residential address, which may include utility bills or bank account statements.

Anti-Money Laundering

Our Anti-Money Laundering (AML) program is comprehensive and designed to prevent the concealment of funds derived from illegal activities. It also encompasses measures to identify and counter financing terrorism (CFT).

Key components of our AML program include AML screening and monitoring. We conduct checks on both legal entities and individuals to ensure they are not on sanctions lists or have questionable backgrounds that may indicate previous criminal, civil, or regulatory violations.

Ongoing monitoring of existing customers involves transaction monitoring to ensure that transactions align with our knowledge of the customer. We also periodically review and update customer information obtained through KYC to keep it current.

Our AML procedures adhere to a risk-based approach, which means that some customers may undergo more thorough AML scrutiny. This includes residents of high-risk regions and Politically Exposed Persons (PEP) who hold prominent public positions.

Sanctioned Countries

As part of our AML efforts, we maintain a list of sanctioned countries where our services are restricted. These countries include:

Afghanistan, American Samoa, Angola, Bahamas, Botswana, Belarus, Burundi, Cambodia, Central African Republic, Chad, Congo, Cuba, Democratic Republic of Congo, Equatorial Guinea, Eritrea, Ethiopia, Ghana, Guam, Guinea Bissau, Iran, Iraq, North Korea, Lebanon, Libya, Mali, Nigeria, Pakistan, Panama, Puerto Rico, Samoa, Saudi Arabia, Sierra Leone, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Venezuela, Yemen, Zimbabwe, some states of the USA.


To comply with regulatory requirements, we maintain records of customer identification documents, risk assessments, transaction records, receipts, and customer correspondence for a period of five years after the termination of a business relationship.

We are committed to upholding the highest standards of integrity and preventing any misuse of our services for illicit purposes. By using our services, you acknowledge and agree to comply with this AML/KYC Policy and its provisions. We reserve the right to update and modify this policy as necessary to ensure ongoing compliance with applicable laws and regulations.

If you have any questions or concerns about this policy or our AML/KYC procedures, please do not hesitate to contact us at Your cooperation and adherence to these policies are vital in maintaining the security and integrity of our services.