Objective:
To establish a comprehensive system of controls and procedures to prevent, identify, monitor, and report suspicious transactions related to money laundering and terrorist financing, in compliance with Brazilian legislation (Law No. 9.613/1998, Law No. 13.260/2016, and regulations issued by the Central Bank and COAF), as well as international best practices.
Guidelines:
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Ensure compliance with laws and regulations on the prevention of money laundering and terrorist financing.
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Implement Know Your Customer (KYC), Know Your Partner (KYP), and Know Your Employee (KYE) processes to identify and validate clients, partners, and employees, with periodic updates to records.
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Classify clients and partners according to risk profiles (low, medium, high) and adopt proportional monitoring measures, including Enhanced Monitoring for PEPs and atypical transactions.
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Monitor transactions in real time, using technological tools to detect suspicious operations (e.g., inconsistent values, repetitive movements, abrupt fluctuations).
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Immediately block assets and terminate relationships with clients, suppliers, or partners included on restrictive or sanctions lists (OFAC, Interpol, UN Security Council, among others).
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Report suspicious money laundering or terrorist financing (ML/TF) activities to COAF within the legal deadline, maintaining absolute confidentiality of communications.
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Document and store transaction records, registration data, and communications for at least ten (10) years, as required by law.
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Train employees and managers through annual training sessions or whenever regulatory changes occur, ensuring understanding of risks and procedures.
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Integrate the AML/CFT policy into corporate governance, with clearly defined responsibilities for the Compliance Department and other areas (Legal, Operations, IT, HR).
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Assess risks of new products, services, and technologies before launch, incorporating specific controls to mitigate vulnerabilities.
BanPrime Payment Institution Ltd.
Marcus Assis