Anti-Money Laundering and Terrorist Financing Prevention Policy (AML/CFT)
Version 1.0
Effective Date: 08/05/2025
Last Update: 08/05/2025
Confía Digital's Commitment to AML/CFT/WMD Proliferation Prevention
At Confía Digital S.A.S., We are committed to the prevention of illicit activities such as Money Laundering, Terrorism Financing, and the Proliferation of Weapons of Mass Destruction (ML/TF/WMD).
Although we are not currently subject to a specific legal regime in this matter, we voluntarily apply this policy as part of our corporate best practices, business ethics, and alignment with international standards such as those of the FATF. This preventive approach strengthens the integrity of our operations and business relationships.
As part of our commitment to ethics and compliance, we have implemented rigorous policies that guide our operations and business relationships. Below, we present the main principles that govern our prevention policy:
- Actively collaborate in the fight against Money Laundering, Terrorist Financing, and the Proliferation of Weapons of Mass Destruction, in accordance with current national and international legislation and the standards established by the FATF.
- Apply a Risk-Based Approach (RBA) to identify, assess, manage, and mitigate the risks of Money Laundering, Terrorist Financing, and the Proliferation of Weapons of Mass Destruction (ML/TF/PADM) in its operations, internal processes, and business relationships.
- Allocate and provide the necessary technical, human, and financial resources to implement effective controls in the prevention of ML/TF risks.
- Monitor and comply with the resolutions issued by the United Nations Security Council, especially those related to targeted financial sanctions.
- Refrain from establishing contractual, commercial, or institutional relationships with individuals or entities included in restrictive, binding, or sanction lists, such as those of the UN, OFAC, or the EU.
- Apply strict due diligence (CDD) mechanisms for the selection, onboarding, monitoring, and offboarding of clients, suppliers, strategic partners, employees, and third parties, in accordance with current internal procedures.
- Continuously monitor business relationships through transactional monitoring processes, periodic review of counterparties, and alert analysis.
- Include specific content on the prevention of ML/TF in mandatory training programs, promoting a culture of ethics, integrity, and compliance.
- Establish secure and confidential internal channels for receiving reports or alerts related to potential ML/TF risk indicators.
- Designate clear roles and responsibilities in the implementation, monitoring, and continuous improvement of the ML/TF Prevention System, including the role of the Compliance Officer (if applicable).
- Ensure that all employees, contractors, suppliers, clients, and other stakeholders comply with this policy and with the applicable legal provisions regarding the prevention of ML/TF.
- Review and periodically update this policy, adapting it to regulatory changes, new threats, international recommendations, or adjustments in the organization's risk map.
Applicability and Confidential Reporting Channels
This policy applies to all processes, areas, employees, contractors, suppliers, strategic partners, clients, and other stakeholders who have a commercial, contractual, or institutional relationship with Confía Digital S.A.S., without exception, within the framework of their operations in Colombia and abroad.
To strengthen the commitment to transparency and the prevention of ML/FT/PADM, Confía Digital provides the following secure and confidential channels to report warning signs, irregularities, or potential associated cases:
- Your e-mail: legal@confiadigital.com.co
- Ethics Line Form: Available on our website https://confiadigital.com.co
These mechanisms can be used anonymously or with identification, and will be managed with absolute confidentiality by the Compliance Officer. Responses will be provided within a maximum of five (5) business days, except in cases requiring further analysis.
The misuse of these channels may also lead to sanctions.
