Implementación de un sistema general para la administración del riesgo de lavado de activos y la financiación del terrorismo (SARLAFT) para las comercializadoras internacionales

Abstract

International Trading Companies have chosen by the implementation of an effective system, whose object is to prevent the uses of those to legalize the product of activities predetermined like crimes. The Risk Administration System to Prevent Money Laundry and Terrorism Financing – SARLAFT (for its abbreviation in Spanish), is the integrated set of elements referred to politics, procedures, documentation, organizational structure, control organs, technological infrastructure, divulgation, information and training related with the theme, through which the institutions monitored by the Superintendents, answer to threats to be used by practice of crime conducts for such concepts, with the final objective of reduce or disappear the possibilities losses or damage by the risk exposition of Money Laundry and Terrorism Financing. The SARLAFT STAGES, refer to the next steps through which the institutions manage the Money Laundry and Terrorism Financing Risk: 1) Risk identification 2) Measuring and Evaluation 3) Control 4) Monitoring The procedure used to SARLAFT application, must contain the steps that follow:  Customer knowledge and classification of financial profile  Monitoring of the customer transactions  Auditing and control: the review of instructions and procedures fulfillment implemented in SARLAFT. These procedures must be documented and registered, which must guarantee integrity, opportunity, reliability and availability of information. These Stages only can be consulted by the institution authorized personal, they must be supported physically, count with management criteria and process, information security and conservation. For these effects, International Trading Companies must design and adopt client entailment request forms that contain indicated information in the form designed above in the graduate work. This form must be filled too by all people empowered and authorized for dispose of resources or contract good, case in which the company must verify the document that accredits this faculty or authorization, the form must contain the signature and the fingerprint of the potential customer. In case of International Trading Companies, transfers of funding realized inside of the national territory, such as International transferences, in other words, those operations under which leave or enter foreign exchange, must be identified both the payer as the beneficiary; also they must be considered like operations that must be subjected to a greater control by the Companies. International Trading Companies like integral part of the foreign commercial logistic are very exposed by the exercise of their social object and to be watched by those that are dedicated to illegal activity of money laundry like a pillbox for permeate. This the importance for those who practice this activity to implement defense mechanisms that allow to realize their business with better quietness and avoid to be victims of unusual or suspicious operations for constitute money laundry. Money laundry is a latent risk in the world economy, so is everybody’s responsibility.