- SARLAFT
CERTIFICATION ON THE SYSTEM TO MANAGE THE RISK OF MONEY LAUNDERING AND FINANCING OF TERRORISM – SARLAFT (in Spanish)
- SARLAFT
CERTIFICATION ON THE SYSTEM TO MANAGE THE RISK OF MONEY LAUNDERING AND FINANCING OF TERRORISM – SARLAFT (in Spanish)
Almacenes Generales de Depósito de Café – ALMACAFÉ S.A., holder of Tax Identification Registry (NIT, in Spanish) No. 860,010,973-4, hereinafter referred to as “ALMACAFÉ”, is a Company duly incorporated in Colombia and which has as its main domicile in the following address: Calle 73 No. 8-13 – Bogotá – Capital District. In order to pursue its operations, ALMACAFÉ is supervised by the Financial Superintendence of Colombia, hereinafter referred to as SFC, and has implemented a System for Managing the Risk of Money Laundering and the Financing of Terrorism (SARLAFT), as provided by the Basic Legal Memorandum (C.E. 029/14) – Part I – Title IV – Chapter IV of the SFC, pursuant to what is provided for in the Organic By – Laws of Colombian Financial System (“E.O.S.F.”) (Decree 663 of 1993), as well as in the international recommendations and best practices on this subject.
This risk management system fulfills with the stages, elements, mechanisms and instruments defined in the valid regulation and implemented through policies and procedures stated in the SARLAFT Manual and in the Code of Conduct approved by the Board of Directors, which are of mandatory compliance by all company executives and employees.
Almacenes Generales de Depósito de Café – ALMACAFÉ S.A., holder of Tax Identification Registry (NIT, in Spanish) No. 860,010,973-4, hereinafter referred to as “ALMACAFÉ”, is a Company duly incorporated in Colombia and which has as its main domicile in the following address: Calle 73 No. 8-13 – Bogotá – Capital District. In order to pursue its operations, ALMACAFÉ is supervised by the Financial Superintendence of Colombia, hereinafter referred to as SFC, and has implemented a System for Managing the Risk of Money Laundering and the Financing of Terrorism (SARLAFT), as provided by the Basic Legal Memorandum (C.E. 029/14) – Part I – Title IV – Chapter IV of the SFC, pursuant to what is provided for in the Organic By – Laws of Colombian Financial System (“E.O.S.F.”) (Decree 663 of 1993), as well as in the international recommendations and best practices on this subject.
This risk management system fulfills with the stages, elements, mechanisms and instruments defined in the valid regulation and implemented through policies and procedures stated in the SARLAFT Manual and in the Code of Conduct approved by the Board of Directors, which are of mandatory compliance by all company executives and employees.
CUSTOMER KNOWLEDGE:
Our CK policy aims to ensure that all our customers are duly identified and that their financial profile can be determined. On account of the high – risk profile of some customers, more demanding processes must be established to obtain information about them.
Customers’ information is verified and different actions to keep their information fully up to date are carried out. This is further supplemented with the knowledge of the market segments we serve, which in turn enables us to make comparisons vis-à-vis the customers we render services to.
Customers’ information is maintained during the period of time set forth in the law and it is fully at the disposal of the authorities for purposes related to an investigation.
CUSTOMER KNOWLEDGE:
Our CK policy aims to ensure that all our customers are duly identified and that their financial profile can be determined. On account of the high – risk profile of some customers, more demanding processes must be established to obtain information about them.
Customers’ information is verified and different actions to keep their information fully up to date are carried out. This is further supplemented with the knowledge of the market segments we serve, which in turn enables us to make comparisons vis-à-vis the customers we render services to.
Customers’ information is maintained during the period of time set forth in the law and it is fully at the disposal of the authorities for purposes related to an investigation.
MONITORING SYSTEM:
In general terms, monitoring aims to identify unusual operations based on alert signals. In case of certain types of customers who have a high-risk profile, a more detailed monitoring scheme has been put in place.
In keeping with these policies, whenever the analysis determines that operations or transactions are suspicious, they are reported to the competent authorities (Financial Information and Analysis Unit – UIAF) as provided by current regulation.
MONITORING SYSTEM:
In general terms, monitoring aims to identify unusual operations based on alert signals. In case of certain types of customers who have a high-risk profile, a more detailed monitoring scheme has been put in place.
In keeping with these policies, whenever the analysis determines that operations or transactions are suspicious, they are reported to the competent authorities (Financial Information and Analysis Unit – UIAF) as provided by current regulation.
PERSONNEL TRAINING:
Our company’s top management acknowledges the significance of training and understands that employees are basic pillars in the struggle against money laundering and the financing of terrorism. Thus, training programs for all our collaborators have been designed to disseminate, maintain and update the SARLAFT culture in ALMACAFÉ.
PERSONNEL TRAINING:
Our company’s top management acknowledges the significance of training and understands that employees are basic pillars in the struggle against money laundering and the financing of terrorism. Thus, training programs for all our collaborators have been designed to disseminate, maintain and update the SARLAFT culture in ALMACAFÉ.
COMPLIANCE OFFICERS:
The Board of Directors of ALMACAFÉ has appointed a Compliance Officer (Main and Alternate) to execute the duties set forth by current regulation. They are to be duly registered with the Financial Superintendence of Colombia. The compliance officer is a high – level employee with decision – making capacity who counts on the support of a human and technical working team that enables him to cover the different management areas and receives the effective support of the Company’s boards of directors.
COMPLIANCE OFFICERS:
The Board of Directors of ALMACAFÉ has appointed a Compliance Officer (Main and Alternate) to execute the duties set forth by current regulation. They are to be duly registered with the Financial Superintendence of Colombia. The compliance officer is a high – level employee with decision – making capacity who counts on the support of a human and technical working team that enables him to cover the different management areas and receives the effective support of the Company’s boards of directors.
AUDITING AND CONTROL:
The procedure to determine the compliance with the control mechanisms designed and implemented through ALMACAFÉ’s SARLAFT Manual has been included as part of the internal audit processes as a specific program based on audit procedures.
To comply with the instructions issued by the Financial Superintendence of Colombia on this matter, the Statutory Auditor of the Institution has implemented quarterly validations applied to the adequate execution of the controls, which has enabled the company to detect opportunities for improvement regarding the instructions on the prevention of money laundering and the financing of terrorism provided for in the currently valid legal standards.
All the foregoing aspects are documented in a SARLAFT Procedures Manual, which is kept in the company for all its employees and executives for consult.
AUDITING AND CONTROL:
The procedure to determine the compliance with the control mechanisms designed and implemented through ALMACAFÉ’s SARLAFT Manual has been included as part of the internal audit processes as a specific program based on audit procedures.
To comply with the instructions issued by the Financial Superintendence of Colombia on this matter, the Statutory Auditor of the Institution has implemented quarterly validations applied to the adequate execution of the controls, which has enabled the company to detect opportunities for improvement regarding the instructions on the prevention of money laundering and the financing of terrorism provided for in the currently valid legal standards.
All the foregoing aspects are documented in a SARLAFT Procedures Manual, which is kept in the company for all its employees and executives for consult.
