Money Laundering Prevention

Last updated: August 1, 2021.

 

1. Purpose

 

1.1. The Money Laundering Prevention Policy aims to establish guidelines, guidelines and procedures for detecting and combating money laundering crimes and other crimes involving concealment of financial resources.

 

2. Scope

​

2.1. All shareholders, administrators, employees of any hierarchical level, service providers, suppliers and business partners.

​

3. Definitions

​

3.1. For the purposes of this Policy, the terms are understood as follows:

​

(a) Financing of Terrorism: It is the financial support, by any means, to terrorism or to those who encourage, plan or commit acts of terrorism. Terrorist financing aims to provide funds or capital for terrorist activities. This fundraising or capital can happen in different ways, including legal sources, such as membership contributions, donations or profits from various commercial activities, as well as from criminal sources such as drug trafficking, weapons smuggling, prostitution and services improperly taken on the basis of force, organized crime, fraud, kidnapping, extortion, etc.

​

(b) Politically Exposed Persons (PEP): are those people who in the last 05 (five) years have performed activities, positions, public functions, relevant jobs in Brazil or in other countries, as well as their family members, representatives or other people of your close relationship.

​

(c) Money laundering: characterized by a set of commercial or financial operations that seek to incorporate into the economy, in a transitory or permanent way, resources, goods and values of illicit origin and that are developed through a dynamic process which theoretically involves three independent steps that often occur simultaneously (placement, concealment, and integration).

 

4. Guidelines

​

For the purposes of this Policy, the following must be observed:

​

4.1. Commitment. SELETOBANK repudiates any act of money laundering or criminal activities involving simulation or concealment of financial resources;

​

4.2. Evaluation of products and services. Permanent evaluation of products and services offered by SELETOBANK from the perspective of the risks of improper use of such products and services for the practice of terrorist financing, laundering or concealment of goods, rights and values, taking the necessary measures to mitigate such risks, in line with national legislation and taking into account the risk profiles of customers, geographic, operations, transactions, new technologies.

 

4.3. Monitoring Processes. Develops and maintains robust monitoring processes for the detection of atypical and/or suspicious transactions that may constitute evidence of the practice of terrorist financing or money laundering or concealment of assets, rights and values, carrying out, whenever applicable, the communication of such transactions to Organs competent bodies, pursuant to the laws and regulations in force.

 

4.4. Culture of preventing and combating money laundering. It permanently develops and disseminates to its employees and managers the knowledge and culture of preventing and combating the financing of terrorism, the laundering and concealment of assets, rights and values.

 

4.5. Due diligence in hiring processes. SELETOBANK adopts internal procedures of “Know your client”, “Know your partner” and “Know your employee”, with the aim of mitigating the risks of laundering money, as well as the practice of any criminal action involving the simulation or concealment of financial resources, according to the activity, jurisdiction and parties involved, which may involve the collection, validation and updating of registration information.

 

4.6. Operations Record. SELETOBANK will maintain the record of financial transactions carried out on its platform for a period of 05 (five) years, in order to comply with current legislation and the competent authorities.

 

4.7. Politically Exposed Persons (PEP). Adoption of procedures for identifying customers, partners and service providers that may eventually appear on PEP lists to assess the maintenance of business or measures to mitigate internal risks that may be necessary.

 

4.8. Detection of suspicious signs or activities. When SELETOBANK detects signs or suspicious activities related to money laundering or related to the criminal practice of simulating or hiding financial resources, it will investigate the situation in a confidential manner, the processes, analyzes and communications, in accordance with current legislation, and informing the competent authorities. and the Financial Activities Control Council (COAF). SELETOBANK will also collaborate, whenever necessary, with public authorities in investigations related to harmful acts to the public administration and arising from its activity, in accordance with current legislation.

 

5. Responsibilities

 

5.1. It is the responsibility of all shareholders, administrators, employees, service providers, suppliers and partners to comply with this Money Laundering Prevention Policy.

​

5.2. Adhesion to SELETOBANK employees is mandatory and will be carried out by signing the term of commitment with the Money Laundering Prevention Policy.

​

6. Control and Monitoring

​

6.1. Internal investigations must be carried out permanently in order to verify compliance by all shareholders, administrators, employees and service providers with the rules established in the organization, as well as periodic training in order to reiterate and update the terms of this Policy .

​

6.2. If the internal investigation identifies any alleged irregularity, the matter must be brought to the attention of the Compliance Area so that the necessary measures can be taken, including reporting to the competent authorities or application of internal sanctions such as: written warning, suspension, dismissal, termination of the contract with a supplier, partner or third party.

 

7. Reporting Suspicious Situations

 

7.1. Everyone must report to their leaders or directly to the Compliance Area, suspected situations of money laundering or criminal practices that involve simulation or concealment of financial resources, or that deserve special attention, ensuring the confidentiality of the information provided.

 

8.   Communication Channel

 

8.1. Any situations with indications of being in disagreement with this Policy must be immediately registered and informed to the Compliance Area, through the electronic address: antifraude@seletobank.com.br.

 

9. Legal Basis

• Law 9,613/1998

• Circular Bacen no. 3,461/09

• Circular Bacen no. 3,978/20

• SeletoBank's Code of Ethics and Conduct

• Regulations issued by COAF

 

10. General Provisions

 

10.1. This will be continuously reviewed, in order to keep improving procedures related to the prevention of money laundering and terrorism, and also to combat criminal activities that involve the simulation or concealment of financial resources, and will be approved by the Board of Directors or administrators. .

​

10.2. The review of this Policy will take place at least annually and will be disclosed to its shareholders, employees, third parties, business partners and service providers, in addition to being also available on the SELETOBANK website.

​

​

​

​

​