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AML

AML. Anty Money Laundering.

Common to all services below

✔      Financial Action Task Force (FATF) 40+9 Recommendations, as updated in June 2021.

According to Payments for US customers

✔      Bank Secrecy Act (BSA) of 1970 (“BSA”)

✔      FinCEN Customer Due Diligence Final Rule

✔      Anti-Money Laundering Act of 2020 (“AML Act”)

✔      Corporate Transparency Act of 2021 (“CTA Act”)

✔      State laws and federal laws, covered by our USA licensed provider

 

Payments Business for EU/UK customers

✔      EU Payment Services Directive (PSD 2) 2015/2366 exemption 3b

✔      European Union’s Money Laundering Directives (“MLD 4, 5 & 6”)

✔      Law on payments of Lithuania of 2014

✔      UK Payment Services Regulations 2017

✔      UK Proceeds of Crime Act (POCA) of 2017

 

 

Obligations of agreement Law 5/14 Prevention of Money Laundering.

 
  • Appointment of a representation committee - Internal Control Body - OCI - in front of SEPLAC.
  • Process "Know your customemer"
  • Creation of a criterion for identifying operations that may be considered money laundering.
  • Preparation of the Money Laundering manual.
  • AML and financial crime prevention training for all employees.
  • Management of specialized annual audit, and preparation of a manual for self-evaluation of the company's management in this matter.

What AML Obligations do I have as a lending company with the Bank of Spain?

Royal Decree 304/2014, of May 5, approving the Regulation of Law 10/2010, of April 28, on the prevention of money laundering and terrorist financing. The decree requires exhaustive control over the operations we process and the identity of the clients from whom transfers are received.

How can I carry out the "know your customer" control which is mandatory by law for All transactions?

First I will need to establish a DNI application process "in the hiring process", we must also make sure that we keep a copy of this documentation for 10 years. At the same time, we must make an automatic match of the identity of each applicant with the Gafi lists and antiterrorist lists to verify that we are not conducting financial transactions with terrorists.