In accordance with the stipulated in the mentioned regulation, Paylivre Brazil is always attentive to transactions that may constitute signs of money laundering. In this sense, signs of money laundering are understood as the following operations:
- To hide or conceal the true nature, origin, location, disposition, movement or ownership of goods, rights or values arising, directly or indirectly, from criminal activity.
- goods that appear to be objectively incompatible with the professional occupation and declared equity financial situation;
- carried out between the same parties or for the benefit of the same parties, in which there are followed gains or losses with respect to any of the parties involved;
- highlighting a significant fluctuation in relation to the volume and/or frequency of business of any of the parties involved;
- whose characteristics and/or outcomes highlight the action, on behalf of third parties;
- that emphasize a sudden and objectively unjustified change in relation to the operational modalities usually used by the involved (s);
- performed with the purpose of generating loss or gain for which, objectively, there is no economic basis; and
- which the degree of complexity and risk appear to be incompatible with the technical qualification of the customer or its representative.
The following practices may also be set as evidence of money laundering:
- To resist in facilitating the necessary information for the account
- Declare several bank accounts and/or modify them constantly: and
- open an account and authorize an attorney who has no apparent link.
Paylivre, committing itself to fight money laundering, will obligatorily report the cases of suspected money laundering to the competent authorities to ascertain any possible liability.
Identification and handling in case of money laundering evidence
Paylivre Brazil will continuously monitor the signs of money laundering. The routines aim to identify transactions with counterpart recurrence, unjustified or atypical transfers, operations with equity incompatibility, not restrictively.
The money laundering prevention system will generate events related to customers’ operations. A customer whose operations are atypical will be signaled by the system which will also inform other information of this customer such as:
- if you are a politically exposed person;
- if there was an unusual change of address or ownership of a bank account or an attorney;
- if you live / have an account / or an attorney in border areas.
Once the report is created, the client’s data and information will be further analyzed to confirm or not the suspicion of money laundering evidence. The analysis consists of checking documents, transactions and data faced by the corresponding system.
If after the other analyzes the suspicion is confirmed, Paylivre Brazil must register such analyzes in the customer’s history system and prepare the formal communication to COAF.
* The text above is a direct translation from the original document. In case of divergence the original Portuguese version should prevail.