1. Introduction
NUEVOBANCO is committed to the highest anti-money laundering (AML) standards and requires all employees to adhere to these standards to prevent the use of our products and services for money laundering or terrorist financing purposes.
2. What is money laundering?
Money laundering is the process by which criminals conceal original ownership and control of criminal proceeds by making those proceeds appear to come from a legitimate source.
The processes are:
- Placement - introduction of illegal funds into the financial system
- Dispersion - complex transactions to conceal the source
- Integration - funds re-enter the economy appearing legitimate
3. Our AML obligations
As a regulated financial institution, NUEVOBANCO must:
- Implement risk-based policies and procedures
- Perform customer due diligence (CDD)
- Monitor transactions and report suspicious activity
- Retain records for the required period
- Provide AML training to all staff
- Cooperate with law enforcement agencies
4. Customer Due Diligence (CDD)
We perform thorough due diligence for all clients, which includes:
DDC Standard
- Customer identity verification
- Understanding the nature of the client's business
- Money laundering risk assessment
Enhanced Diligence (RD)
Applied to higher risk clients including:
- Politically Exposed Persons (PEP)
- Customers from high-risk jurisdictions
- Complex ownership structures
- Unusual trading patterns
5. Transaction Monitoring
We use sophisticated systems to monitor transactions for suspicious patterns, including:
- Large cash transactions
- Rapid movement of funds
- Transactions with high-risk jurisdictions
- Models incompatible with customer profile
6. Reporting obligations
Suspicious activity reports (DAS)
We are legally required to file SARs with the relevant authorities when we detect potentially suspicious activity. This is done without informing the client (disclosure is a criminal offense).
7. Keeping records
We keep complete records of:
- Customer identification documents
- Transaction records
- Account records and business correspondence
- Results of any analysis undertaken
Records are kept for at least 5 years after the end of the customer relationship or transaction.
8. Staff training
All NUEVOBANCO employees receive regular AML training covering:
- Legal and regulatory requirements
- Money laundering techniques and trends
- Warning signs and suspicious indicators
- Internal reporting procedures
- Consequences of non-compliance
9. Prohibited activities
The following activities are strictly prohibited:
- Opening anonymous accounts or accounts under fictitious names
- Maintaining relationships with shell banks
- Processing transactions when red flags cannot be resolved
- Disclosure to Customers Regarding Surveys
10. Compliance and consequences
Failure to comply with AML regulations may result in:
- Severe financial sanctions
- Criminal prosecutions
- Damage to reputation
- Loss of banking license
11. Contact details
For any questions regarding our AML policy or to report suspicious activities:
AML Compliance Manager
Email: compliance@nuevobnks.online
Phone: +33 1 XX XX XX XX
Confidential line: +33 800 XXX XXX
