The Compliance department is responsible for monitoring operations routines to identify signs of Money Laundering and Terrorism Financing. The vision routines to identify, among others, operations with counterparty recurrence, unjustified transfers, operations with asset incompatibility and without economic foundation.

Monitoring is carried out through a system that has an interface with internal systems that daily collect registration, operational and financial information from customers. Information that is incompatible with the rules defined in the system will generate alerts. In addition to these occurrences, the circumstances listed below require special attention:

This is a Politically Exposed Person (PPE);
Made an unusual change of address or ownership of a bank account or attorney;
It has been identified in sanction lists;
Resides and / or has an account and / or attorney in border locations;
Operations in which it is not possible to identify the final beneficiary; and / or
Foreign exchange transactions in which the country of destination / origin is a tax haven.

After the issue is issued, it is up to Compliance to analyze the client and its operations to confirm or not the evidence of Money Laundering and Terrorism Financing. As part of the analysis procedures, searches are carried out on tools that verify the client's involvement with negative news, public sanctions lists and client operational information from public and private sources, and this process is carried out weekly.

After analysis, the following measures can be taken:

The registration update requirement;
Clarification requests to the client;
Analysis of the Risks department in view of movement inconsistencies;
If consistent evidence is identified, we make the necessary communication to the competent bodies.