CryptoSimple SAS (hereinafterthe "CryptoSimple") is a french limited company « SAS » registered at 2 rue Henri Barbusse 13008 Marseille, France, registered under the number 897 452 306 R.C.S. Marseille.

CryptoSimple mission is to provide services on digital asset in the simplest and safest way to its customers.

1- Digital Asset Service Provider

In order to provide such services, CryptoSimple is registered with the french regulator « autorité des marchés financiers » (AMF) as a Digital Asset Service Provider (DASP) under the number E2021-024.

Such registration requires CryptoSimple to be compliant with the regulations on Anti-Money Laundering and Combating the Financing of Terrorism (AML/FT).

2- AML/FT policy

Indeed when acting as a counterparty in a transaction involving the acquisition or selling of crypto-assets, CryptoSimple is subject to the obligations contained in the Directive on the Fight Against Money Laundering and the Financing of Terrorism (hereinafter, “ AML/FT ”).

The AML/FT Directive is implemented in France by ordinance no. 2016-1635 of the 1st December 2016 (“Ordinance to strengthen France’s legal framework relating to the fight against money laundering and the financing of terrorism). Pursuant to Article L.561-2 of France’s Monetary and Financial Code, “all persons who, as part of their usual work, act as a counterparty or an intermediary for the purpose of acquiring or selling any digital instruments incorporating non-monetary units of value that can be held or transferred for acquiring goods or services, but do not represent a claim on the issuer” must comply with obligations contained in the regulation concerning the fight against money laundering and the financing of terrorism.

3- KYC procedure and tool

While CryptoSimple remains liable, the AML/FT requirements and the « Know your customers » (KYC) practices can be delegated to a third party. CryptoSimple works with a "KYC professionnal" third party. The third professionnal third party provides CryptoSimple an up to date KYC tool.

Such KYC procedure enables to identify CryptoSimple customer through liveness detection. The third party KYC procedure provides also a comprehensive audit against international regulations on sanctioned, wanted or convicted persons in association to economic & financial crimes (AML/CTF). Two steps are required first and identity proofing and second a risk screening.

Such external delegation and use of a KYC tool does not exclude CryptoSimple liability.  For this reason CryptoSimple implemented an internal procedure, in order to provide a high level duty of care. The duty of care includes, but is not limited to, compliance with provisions of articles L.561-5 and L.561-10 of the France’s Monetary and Financial Code and the KYC policy, by using reporting process and key performance indicators.

4- Internal measures

Trading products and goods, regardless of whether they are tangible or virtual, such as crypto-assets, involves significant risk. For this reasons, CryptoSimple has settled an internal procedure which is carried out by CryptoSimple team. CryptoSimple internal procedure includes a risk assessment policy, managed by legal and technical experts.

CryptoSimple risk assessment policy include, but is not limited to, the following risks :

CryptoSimple Internal measures are compatible with applicable European standards in the area of the fight against money laundering and the financing of terrorism.