ba - banco amambay s.a., su banco

MONEY LAUNDERING PREVENTION SYSTEM
Banks and other financial institutions might be used, unintentionally, as intermediaries in transferences or deposit of criminal activities money. The purpose of these operations is, frequently, to hide the real fund property. This kind of financial system utilization must be the observance object of the Banks responsible, as the confidence of the public might be harmed on account of the criminal people relationship.

In this context, Banco Amambay S.A. have developed and implemented the "MANUAL OF CONDUCT FOR PREVENTION AND IDENTIFICATION OF ASSETS LAUNDERING AND OTHER CRIMES AND FAULT OF FINANCIAL SYSTEM" which has procedures that allow to select and to know its customers, whether they are established or occasional, to identify their principal and secondary activities, to know their money origins and to monitor the kind and volume of their transactions during their relationship with the Bank.

The procedures were developed from the following perspectives:

a.	Customers: identification, segmentation, knowledge of their activities, origin of the money, customer's identification records and customer's business activities records.
b.	Monitoring and control: monitoring of the volume and kind of transactions, classifications, and registration.
c.	Knowing the employees: background information, aptitude, attitude, financial and patrimonial situation and psychological profile.
d.	Training: knowledge, training, and bank staff responsabilities.
e.	Structure of Compliance area: formations and functions.
f.	Compliance officer: position in the organization structure, functions and responsibilities.
g.	Compliance committee: formations and functions.
h.	Compliance audit programs: internal and external.

The procedures enclosed on the "MANUAL OF CONDUCT FOR PREVENTION AND IDENTIFICATION OF ASSETS LAUNDERING AND OTHER CRIMES AND FAULT OF FINANCIAL SYSTEM" are:

Banco Amambay S.A. policies for the prevention and identification of assets laundering and other crimes and fault of financial system.

Controls and performance of procedure's manual's norms.

Established or occasional customers.

Reports of unusual operations and references about preventive activities.

Unusual Operations Report Form, fulfillment requirements (CU-10).

Control of customer economic activities.

Control of foreign customers.

Control of customer's financial transactions.

Reports to SEPRELAD - U.I.F

Internal training.

Control of customer's information profile.

Compliance Officer functions.

Branches Compliance Officer functions.

Compliance committee.

Internal and External Audit.

Employee's training.

Responsibilities of each employee in unusual operations detection and internal reports.

Sanctions and correctives for Manual's procedures non compliance.

P.E.P. (Pollitically Exposed Persons).

High risk countries and territories.

Customer's control with "OFAC" and "WORLDCHECK" lists.

Risks map:


°	Automatic customer classification considering their performance in: high, middle and low risk.

Due diligence:


°	Consignment of due diligence notes to customers.
°	Identity and activity customer's information.
°	Lawful origin customer's funds determination.
°	Evidence of customers supporting their business transactions.
°	Unusual transaction monitors.

Due diligence form fulfillment requirements (CU-20).

Shell Banks and Correspondents Banks.