Money Laundering Prevention (PLD)

Compliance work to assess the risks involved in the acceptance and monitoring process is complex and requires seriousness, care, and respect. The engagement of all employees in this mindset is fundamental to follow legal rules and maintain the company's integrity.

Using the Data Engine service, we consult our customers' information (KYC), rely on data for AML, prevention of terrorism financing (FT) personal relationships, Politically Exposed Person (PEP), restrictive lists, negative media, lawsuits, embargoes, penalties at IBAMA, and many other information.

We conduct queries, unify data, instantly in an automated search across dozens of sources, receiving a structured report with all the information for an accurate decision-making.

We optimize our time by validating compliance information, thus better understanding our customer, checking reputational information and AML & background Check, minimizing the risk of fraud and money laundering.

To ensure that the Risk-Based Approach is done correctly and guarantees the best prevention of money laundering, terrorism financing, and the financing of the proliferation of weapons of mass destruction (AML/CFT), we adopt the following practices:

• Structuring an AML/CFT Policy;
• Periodic elaboration of an internal risk assessment;
• Reformulation of its rules, procedures, and internal controls.

Another issue is related to the definition of the steps linked to the conduct of the “Know Your Customer” or Know Your Client (KYC) Policy, including detailing the routines related to the full knowledge of the final beneficiary.

Also, greater detailing of the warning signs to be monitored and the points that should integrate the operation analysis, as well as the presentation of the minimum elements that should be part of a report to the Financial Activities Control Council – COAF.

Through the Data Engine, our company can comply with all CVM standards automatically and centrally. Through our risk classification process, SmartFastPay Technology and Services can perform the entire analysis, based on criteria, of what risk the client represents to the business. Moreover, with the Corporate Web, we get a complete view of all the final beneficiaries of the consulted client, with a Monitoring of Queries, where, automatically and in periods that the client makes a new request, the system will search for the client again, reporting for new information in their data

Another feature of the Data Engine that meets 100% of CVM is the Hierarchical Query. It returns the information of partners and administrators in relation to PEP - Politically Exposed Person. In this regard, we identify whether this investor is controlled by a PEP, or, alternatively, if it can be classified as a nonprofit organization, under current legislation.

Our data query platform, developed by Cedro Technologies, the Data Engine, allows SmartFastPay to validate the data of any individual or legal entity. The tool quickly accesses various different sources, unifying the processing of information.

• Credit score
• Credit bureau for negative analysis, bounced checks, and protests
• Boa Vista/SCPC (organization that carries out restrictions)
• CPF/CNPJ status at the Federal Revenue
• Judicial Actions
• Slave Labor
• PEP - Politically Exposed Person
• Basic Registration Data
• Addresses
• Phones
• Emails

• Validation of all personal data of individuals;
• Validation of all registration data of legal entities;
• Complete query of individual's data;
• Validation of CNH x CPF;
• Validation of RG x CPF;
• Information on QSA (Partners and Administrators);
• Money Laundering/PLD with public and private sources;
• Search for processes in courts of justice;
• Validation of Person included in the OFAC (Office of Foreign Assets Control) database for international crimes;
• Validation of CPF on slave labor lists;
• Validation of CPF classified as PEP (Politically Exposed Person) SISCOAF;
• Validation of Person included in the BNMP (National Bank of Arrest Warrants);
• Validation of Individual (CPF) and/or Legal Entity (CNPJ) with credit bureaus, such as SERASA;
• Negative media verification;
• Others available;

Additionally, SmartFastPay has a negative media service. In this sense, negative media, information extracted from Google's database and other sites, are important tools because they indicate the involvement of a certain person - whether physical or legal - in various crimes. With the automation of news research, which uses a set of disruptive technologies, such as artificial intelligence, machine learning, and Natural Language Processing (NLP), it is possible to obtain, in addition to information, an evaluation of the sentiment attached to each entity mentioned in the news, which can be classified as negative, positive, or neutral. This type of analysis helps to understand the impact of the content in the context and for the image of those involved. It indicates to whom the researchers are associated: the analysis of negative media not only allows to follow what is said about the researcher, but also indicates what type of content the person or company is associated with. That is, even if the researcher is not the protagonist of the material, his link with whoever is will be identified.

We combine advanced technology with innovative tools to combat and accurately identify customer risk and stay ahead of evolving financial crime compliance regulations. We simplify customer identification procedures with account opening, accelerate ongoing financial services transaction workflows and KYC processes without adding significant friction to the customer experience, leveraging specific Know Your Customer (KYC) and Customer Due Diligence (CDD) tools that allow SmartFastPay to isolate finances from criminal compliance risks and anti-money laundering (AML)