Having policies and controls for the prevention of money laundering is of vital importance for organizations (whether supervised or not) to avoid incurring administrative or criminal liabilities, taking into consideration that the Criminal Codes regulate this crime in its intentional and reckless modalities. Legal persons are obliged to implement policies and controls when they are going to carry out a commercial transaction, the provision of a service with a client, with their suppliers, collaborators, or when they intend to associate with other natural or legal persons in the provision of services or any other commercial activity.
In the case of clients, it is important to design a Know your client policy, which implies carrying out due diligence to identify the client before initiating the commercial relationship or the provision of a service. For this purpose, the respective documentation or information on the client will be necessary, to accredit its real existence, partners, shareholders, final beneficiaries, legal representative, its line of business, address, place of operation, whether there are any civil or criminal lawsuits against it, verification in international lists, among others. Then, it is necessary to carry out an evaluation process to verify the information provided.
Once the information has been evaluated and the customer has been categorized depending on the risk (normal, simplified or increased), it is determined…
