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ALFREDO MORENO DAVILA www.customstrade.com

WHY AN IMPORTER / EXPORTER COMPANY MUST CARRY OUT

PREVENTION PROGRAMS AGAINST ASSET LAUNDERING?

JUSTIFICATION •  THERE EXIST SOME REPORTS ISSUED BY THE FINANCIAL ACTION TASK FORCE (FATF) AND THE UNITED NATIONS (U.N) INDICATING THAT IMPORT AND EXPORT COMPANIES ARE VERY EXPOSED TO ASSET LAUNDERING OPERATIONS AND TERRORISM FINANCING.

• IN COUNTRIES LIKE MEXICO, PERU, COLOMBIA AND BRAZIL, IT IS INCREASING THE AMOUNT OF ASSET LAUNDERING INVESTIGATIONS ON IMPORT/EXPORT COMPANIES THAT ARE USED EITHER DIRECTLY OR INDIRECTLY IN THESE WHITE COLLAR CRIMES. THIS CIRCUMSTANCE ADDED TO NEWS REPORTED BY SENSATIONALISTIC MEDIA MAY IMPAIR REPUTATION OF COMPANIES SPECIALLY THOSE LISTED IN INTERNATIONAL STOCK MARKETS.

• THERE EXISTS SUBSTANTIAL AMOUNT OF INTERNATIONAL AND LOCAL REGULATION ON PREVENTION AND PENALTY AGAINST ASSET LAUNDERING, TERRORISM FINANCING AND RELATED CRIMES WHICH ARE UNKNOWN BY THE MANAGEMENT COMMUNITY AND UNFORTUNATELY BY MANY CORPORATE LAWYERS.

SCOPE OF THESE PREVENTION PROGRAMS

• ELABORATION OF A MANUAL TAKING INTO ACCOUNT BOTH "INTEGRAL SYSTEM FOR ASSET LAUNDERING PREVENTION" (SPANISH ABBREVIATION : SIPLA) AND THE "ASSET LAUNDERING RISK ADMINISTRATION SYSTEM AND TERRORISM FINANCING" (SPANISH ABBREVIATION: SARLAFT). APPLICATION OF ONE OR ANOTHER SYSTEM WILL DEPEND ON THE LOCAL REGULATION OF EACH COUNTRY AND THE TYPE OF COMPANY. • TRAINING • CLOSE ASSISTANCE WITH THE COMPLIANCE OFFICER DESIGNATED BY THE COMPANY OF EACH COUNTRY TO COORDINATE ANTI-ASSET LAUNDERING ACTIVITIES.

OUR EXPERIENCE

•  THE ABOVE MENTIONED PROGRAMS HAVE BEEN CARRIED OUT WITH SUCESS IN COMPANIES PERTAINING TO THE FOLLOWING SECTORS : CONSUMER PRODUCTS, SERVICES AND LARGE IMPORTERS.

• WE HAVE TRAINED A WIDE VARIETY OF PEOPLE OF THE BUSINESS COMMUNITY, LEGAL FIRMS, AND EVEN, ADMINISTRATIVE STAFF OF NON-PROFIT ORGANIZATIONS (CHRISTIAN CHURCHES).

• ON THE OTHER HAND, WE HAVE ALSO ADVISED PERSONS AND ENTITIES THAT HAVE BEEN VICTIMS OF ASSET LAUNDERING OPERATIONS . WE HAVE ADVISED THEM IN CRIMINAL LAW (LOCAL AND INTERNATIONAL) INCLUDING INTERNATIONAL LAW FOR RESTORATION OF BUSINESS CATEGORIES AND/OR VISAS IN THE UNITED STATES AND CANADA.

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ALFREDO MORENO DÁVILA Abogado LL.M

U. Andes - U. Ottawa - U Carleton Aduanas y Comercio Internacional

Calle 90 No. 12-28 Piso 2 Bogotá D.C Colombia

Tel. (57)(1)7047163 Cel (57) 310-8778915 alfredomorenodavila@customs-trade.com

www.customs-trade.com