Selva Investment Banking actively rejects and prevents money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction (ML/TF/PWMD). Selva IB undertakes to act with due diligence and to comply with applicable Colombian and international regulations, as well as the recommendations of the Financial Action Task Force (FATF).
As of today, Selva IB is not subject to the SAGRILAFT regime of the Superintendence of Companies nor to the SARLAFT regime of the Financial Superintendence. Accordingly, the measures in this policy are adopted voluntarily, as good practice, and will be reassessed if the company grows or changes its activity.
1. Reference regulatory framework
This policy takes as reference Law 526 of 1999 (which creates the UIAF), Law 1121 of 2006, the Criminal Code (articles 323 et seq. and 345), the SAGRILAFT regime of the Superintendence of Companies (External Circular 100-000016 of 2020) and the FATF recommendations.
2. Due diligence and know your customer (KYC)
- Identify and verify the identity of clients, counterparties and, where applicable, the ultimate beneficial owner.
- Understand the economic activity, the profile and the purpose of the business relationship.
- Screen counterparties against national and international restrictive and sanctions lists.
- Apply enhanced due diligence to politically exposed persons (PEPs) and to higher-risk transactions.
3. Knowledge of the source of funds
Selva IB may request the documentation and information necessary to evidence the lawful origin of the funds involved in each transaction, and may decline to begin or continue a relationship where there is reasonable doubt as to that origin.
4. Red flags and reporting
Selva IB will pay attention to unusual transactions and, if it detects transactions it considers suspicious, may bring them to the attention of the competent authorities. As it is not a regulated obligated entity, it is not required to file reports with the Financial Information and Analysis Unit (UIAF); should it become so, it will file them through the Suspicious Transaction Report (ROS). Reporting in good faith does not constitute a breach of confidentiality nor give rise to liability for the reporting party.
5. Responsibility and appointment of a Compliance Officer
As it is not a regulated obligated entity, Selva IB is not required to appoint a Compliance Officer. Oversight of this voluntary policy rests with the company's management. Should Selva IB become covered by the SAGRILAFT regime or another applicable regime, whether through growth or a change of activity, it will appoint a Compliance Officer, register them with the relevant authority and comply with the resulting obligations.
6. Consequences of non-compliance
Failure to comply with this policy may result in the termination of business relationships, the corresponding internal disciplinary action and any applicable legal sanctions. In force from its publication on the website. Version 1.0.