This Money Laundering and Terrorism Financing Prevention Policy aims to establish guidelines related to preventing and combating money laundering and terrorist financing crimes, in addition to other crimes involving simulation or concealment of financial resources, as provided for in the BSA laws by FDIC, and guidelines from Videy's Code of Ethical Conduct.
All shareholders, administrators, collaborators, subscribers and content producers, called creators.
1. The Company:
1.1. Rejects money laundering, terrorist financing, corruption and any other illegal acts.
1.2. It has senior management committed to the effectiveness and continuous improvement of the Policy, procedures and internal controls related to the prevention of money laundering and the financing of terrorism, as well as periodically forwarding reports related to this to the Board of Directors. process.
1.3. It adopts internal assessment procedures, with the objective of identifying and measuring the risk of using its products and services and carrying out business in the practice of money laundering and terrorist financing, in line with national legislation, according to attributions defined in regulations internal.
1.4. Submits, for knowledge, the internal risk assessment, referred to in item 1.3 of this Policy, approved by the Director responsible for the process of preventing money laundering and financing of terrorism, as well as revises it every 1 (one) year .
1.5. It adopts procedures in the development of new products and services, as well as the use of new technologies, in order to assess the risk and prevent money laundering and terrorist financing, in accordance with the guidelines of the Corporate Risk Management Policy and Internal Controls and attributions defined in internal regulations.
1.6. Annually assesses the compliance and effectiveness of this Policy, procedures and internal controls, with regard to the prevention of money laundering and terrorist financing, in order to identify possible deficiencies, following the guidelines of the Corporate Risk Management and Controls Policy Internal and assignments defined in internal regulations.
1.7. Issues an annual report containing the results of the evaluation of the effectiveness of controls, dealt with in item 1.6 of this Policy, as well as submits it, for knowledge, to the Executive Board.
1.8. It adopts action plans to mitigate risks and correct deficiencies identified by the Internal Audit, aimed at investigating procedures aimed at preventing money laundering and terrorist financing.
1.9. It adopts practices to promote the organizational culture of preventing money laundering and terrorist financing, through continuous training and specific communications on the subject.
1.10. Holds annual updated training for employees on preventing and combating money laundering and terrorist financing in the Company's Regulatory Training Trail.
1.11. It adopts Know Your Customer (Know Your Customer), Know Your Supplier (Know Your Supplier), Know Your Partner (Know Your Partner) and Know Your Employee (Know Your Employee) due diligence procedures to mitigate the risks of money laundering and financing of the terrorism, according to activity, jurisdiction and parties involved. Such procedures include the collection, verification, validation and updating of registration information, as defined in internal regulations, using a database check specialized in preventing and combating money laundering and terrorist financing.
1.12. Adopts restrictive measures regarding the conduct of business and the maintenance of relationships with customers, suppliers, partners and employees, when circumstances indicate evidence of involvement in crimes of money laundering and financing of terrorism, corruption or any other illegal acts, observed in current legislation.
1.13. It adopts procedures for identifying customers, partners and outsourced service providers that, by chance, may be present in restrictive lists, such as OFAC (“US Foreign Assets Control Agency”) and CSNU (“United Nations Security Council ”), among other lists of administrative and socio-environmental, national and international sanctions.
1.14. It immediately communicates to the competent authorities the identification of customers mentioned in the OFAC and CSNU lists, among other lists of administrative and socio-environmental, national and international sanctions.
1.15. adopt provisions for identifying and approving the maintenance of the business relationship with customers, partners and service providers who, by chance, may be classified as Politically Exposed Persons (“PEP”) or related to them, respecting the due governance, as established in internal regulations.
1.16. Pays special attention to operations or proposed operations involving PEP, whether directly or related (representative, family member or close collaborator of these people).
1.17. It adopts controls to certify that the settlement of transactions and movements of financial values are carried out for current accounts, savings accounts, prepaid cards and payment accounts owned by customers affiliated with the Company, whose identity and veracity have been confirmed in advance.
1.18. It makes use of internal systems for recording and monitoring transactions, which, through parameterizable rules, identify cases with evidence of money laundering, terrorist financing and corruption, among other illicit activities.
1.19. Evaluates, in the analysis of transactions, the capture solution used, the payment method, the periodicity, the parties and amounts involved, the transaction pattern, the economic activity and any additional indication of irregularity or illegality, involving the client or its operations , in order to detect signs of money laundering, terrorist financing and corruption, among other illicit activities.
1.20. It maintains specific channels for receiving complaints, including anonymous ones, as well as repudiates any acts of reprisal or retaliation intended against whistleblowers in good faith who choose to identify themselves.
1.21. Investigates signs and complaints of practices related to suspected money laundering and terrorist financing, by direct agents or third parties, against the Company's assets, pursuant to current legislation.
1.22. Communicates to the competent authorities the operations or proposed operations that, under current legislation, characterize evidence of money laundering, financing of terrorism and corruption, among other illicit acts.
1.23. Collaborates with public authorities in investigations related to money laundering, financing of terrorism and corruption, among other illegal acts, arising from its activities, in compliance with current legislation.
1.24. Conducts, confidentially, the processes of recording, analyzing and communicating operations with evidence of money laundering and terrorist financing to the competent authorities.
1.25. Defines that any suspicious fact or indication of a direct or indirect relationship with a criminal offense, regardless of having been the subject of the situations described above, must be reported to the Compliance and Money Laundering Prevention areas.
1.26. It is committed to the continuous improvement of monitoring, selection, analysis and communication activities, promoting the review and updating of its processes, with a focus on intelligence and technology.
1.27. Review the guidelines defined in this Policy annually or whenever changes occur in the process that impact or justify their review.