Prevention of Money Laundering, Corruption and Financing of Terrorism


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CCB Brazil’s Prevention of Money Laundering, Corruption and Terrorism Financing Policy reinforces the commitment to guide all managers and employees on the risks of misuse of their products and services as well as the duty to adopt specific procedures, to reduce the image, Compliance (legal compliance) and operational risks, among others.

The observance and compliance with our policy has its indistinct application for all hierarchical levels of CCB Brazil (administrators, employees, and outsourced workers).

• Money laundry

It is a practice used to cover up illegal origin of a financial resource. In this process, in which “dirty” earnings, originated from illegal activities, become “clean” or legalized, after several operations that theoretically involve four independent phases, which often occur simultaneously: Placement, Concealment, Integration or Reintegration, and Recycling.

Placement: It is the entry into the financial system of resources from illicit activities, through deposits, purchase of financial instruments (eg, CDBs, shares of funds, etc.), or purchase of goods or assets.

Concealment: It is the execution of multiple financial operations with the resources already entered in the financial system, aiming at the concealment of illegal resources, which effectively mix with those of lawful origin.

Integration or Reintegration: it is the return to the economic system of illicit resources arising lawfully, through investment in the capital market (eg: stocks, bonds, and securities), real estate, jewelry, productive companies, tourism, works of art, mutual funds, etc.

Recycling: it is the complete cleaning of the crime tracks, closing bank accounts, withdrawing values, simulating the sale of goods. Combating this practice is extremely important since the social consequences of this crime are destructive, as they damage the formal economy, causing damage to the financial system, the reduction of public investments for the benefit of society, such as health, safety, education, among others.

• Corruption

Corruption can be active or passive, internal or external, and the most common types are: Bribery; nepotism; extortion; trafficking in influence; use of privileged information for personal purposes or of friends or relatives; buying and selling judicial judgments; receiving gifts or services of high value; improbity; embezzlement; fraud; collusion; and malfeasance.

Corruption penetrates various sectors of society, compromises an important portion of state resources, and threatens a nation's political stability and sustainable development. Corruption affects transparency and is a threat to the stability and security of societies, by weakening the institutions and values of democracy, ethics, and justice and by undermining sustainable development.

 

• Financing of Terrorism

Terrorism is the systematic use of terror or unpredictable violence against political regimes, people, or persons to achieve a political, ideological, or religious goal. The resources used to finance terrorism do not necessarily originate from criminal activities, which is the prerogative of most money laundering crimes. The organization, maintenance, and operational development of terrorist networks presuppose an activity in continuous evolution. At the same time, the constant search for new and interchangeable methods of obtaining funds and their movement through legal and illegal channels, which include international commercial companies, trusts, and offshore companies, stockbrokers, the transfer of funds through the “hawala” system (through money changers) or the use of charitable associations.

Financial institutions play a fundamental role in preventing and combating illegal acts. The great challenge is to identify and repress increasingly sophisticated operations, the policy of Prevention of Money Laundering, Corruption and Financing of Terrorism, adopted by the conglomerate of CCB Brazil, comply with the current complementary laws, rules, and regulations.


Click here to access Federal Law 12.846 / 2013 (Anticorruption Law).

Click here to access Central Bank Circular 3,978.