Enfoque Basado en Riesgo en KYC

Enfoque Basado en Riesgo

• KYC (Conozca a su Cliente) is a continuous process for identifying, profiling, and updating client information.
• It begins when a client initiates a transaction requiring identification and continues throughout all client interactions.
• The aim is to verify client identity and create/update client profiles using all available information.
• KYC ensures client information is accurately documented, validated, and registered to verify the legitimate origin of funds.
• This prevents using clients to conceal or facilitate money laundering and terrorism financing.
• Market actors must gather sufficient information to confirm client identity and transaction nature truthfully and satisfy their due diligence requirements.
• Information need differs based on Client Risk Class (Low, Medium, High), Nationality (Local, Foreign), Account Type (Local, International), and other relevant factors.

Personas Expuestas Políticamente (PEP)

• Enhanced due diligence for PEP clients (individuals with political exposure).
• This category is defined by the relevant national laws (e.g., Article 4 of Law 23 of 27 April 2015).
• Verification includes checking if the client or their relative is a PEP, including close collaborators.
• This enhanced process requires approval from Senior Management.
• Individuals in subordinate public office positions are not considered PEPs, and high-risk categories require additional verification to remain compliant.

Enfoque Basado en Riesgo

• Entities should identify potential risks in their operations, considering risk type and customer typology.
• Establish controls and procedures to mitigate or prevent identified risks.
• Risks include policies, procedures, technology, staff training, and regular review.
• Evaluate and update risk assessments continuously to adapt to evolving operating environments and emerging threats.
• Regularly evaluate effectiveness of implemented controls to ensure they are suitable for current challenges.

Identificación de Clientes

• Clients must present valid identification documents at the start of a business relationship.
• Acceptance or rejection of a new client depends on complete documentation and due diligence.
• Clients who appear on sanctions lists or have questionable activities will be rejected.

Aceptación de Clientes

• Client acceptance is based on thorough information gathering and analysis.
• Refusal to allow client access to services is subject to justifiable justification based on due diligence review.

Matriz de Riesgo

• A risk matrix helps manage and assess risks relevant to a business.
• It assesses factors impacting risk (regulatory, internal, customer, external) by weighing their impact potential.
• An effective risk matrix analysis allows for proactive risk management and mitigating potential operational disruptions.

Documentación Requerida

• Customers must provide identification documents to verify identity per corresponding regulations and requirements.
• The documentation includes necessary details for accurate record keeping of client information.
• These details include name, address, date of birth, nationality, and other details tailored to the applicable laws.