SAGRILAFT
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System for Self-Control and Management of the Integral Risks of Money Laundering, Terrorism Financing and Financing of the Proliferation of mass-destruction weapons (“SAGRILAFT”)
In order to prevent and to mitigate global Risks of Money Laundering, Terrorism Financing and Financing of the Proliferation of mass-destruction weapons we have implemented a set of measures to control, monitor and report operations with third parties (clients, suppliers, employees and associates) based on those required by the Colombian Superintendence of Companies as instructed in External Circular No. 100-00005 (November 22, 2017), Chapter X, and subsequent modifications. Such measures are commonly known in Colombia as “Minimal Measures Regime” of the System for Self-Control and Management of the Integral Risks of Money Laundering, Terrorism Financing and Financing of the Proliferation of mass-destruction weapons (“SAGRILAFT”) regulation.
Such measures include:
- Reasonable identification of counterparts based on information requested and independent sources.
- Reasonable identification of property structure of counterparts and final beneficiary(ies) of our operations with third parties.
- Gathering Information about the purpose and nature of our operations with third parties.
- Constant analysis of our commercial dealings and transactions to ensure consistency with known activities, risk profile and known source of funds of our counterparts.
- Keeping records and files of all of the above.
- Whenever required, to report to national authorities about any potential good, asset, gain, fund or right held or managed by flagged entities/persons according with international and national risk lists.
- To periodically report unusual or suspicious operations to Colombian authorities (operations are considered unusual or suspicious when its number, quantity or characteristics are not within normal practices of business of a given industry or business and/or not reasonably justified).
It is paramount for José Lloreda Camacho & Cía SAS y Lloreda & Cia SAS to contribute to international action against ML/TF/WMDP risks and to preserve from them our clients and operations.
If you are our client or supplier you are welcome to ask for more information about the Mandatory Minimal Measures Regime-SAGRILAFT in José Lloreda Camacho & Cía SAS or Lloreda & Cía SAS writing to [email protected] o a [email protected].*
*(E-mail addresses exclusive for general information about Mandatory Minimal Measures Regime-SAGRILAFT in José Lloreda Camacho & Cía SAS or Lloreda & Cía SAS. Not valid for notifications, petitions, ordinary communications or any other purpose).