Policy against money Laundering and Terrorist Financing
Aware of the existence and the increase in illicit activities intended to legalize money generated by them or finance terrorist acts, we consider as a need for action to prevent our operation is used to enter and transfer money from these illegal activities such as washing assets and the financing of terrorism, so we have implemented the following POLICY AGAINST MONEY LAUNDERING AND TERRORIST FINANCING.
Objective: This policy is intended to describe the general concepts and actions to be taken to prevent risk of money laundering and terrorist financing by all managers, partners, collaborators PROVIDENCE TRAVEL to extend it to our clients (agencies travel), suppliers and third parties involved in the operation.
Definitions: Money Laundering: Corresponds to the conduct referred to in Article 323 of the Penal Code, added by Article 8 of Law 747 of 2002 and amended by section 16 of Act 1121 of 2006. “Article 323. Money Laundering. Who acquires, Safeguard, invest, transport, transform, safekeeping or manages assets have indirectly from or immediate activities of migrant smuggling, human trafficking, extortion, illicit enrichment, kidnapping, rebellion, arms trafficking, financing terrorism, trafficking in drugs, narcotics or psychotropic substances, crimes against the financial system, crimes against public administration or related to the proceeds of offenses carried out under conspiracy,
Money laundering seeks to give the appearance of legality to property or money from crimes such as drug trafficking, kidnapping, extortion, corruption, human trafficking, migrants and weapons, crimes against the financial system, among others, and is an offense under the Colombian Penal Code.
Be included in laundering operations is very easy because it is a broad offense is about to acquire, protect, invest, transform, transport, preserve or administer property and illicit money.
money laundering is called because it is money and goods. Criminals seek to “wash” their profits through properties such as houses, apartments, cars, merchandise con- locking, businesses, stocks, among others.
Management resources related to terrorist activities: Corresponds to the conduct referred to in Article 345 of the Penal Code, as amended by Article 16 of Law 1121 of 2006. “Article 345. Management of resources related to terrorist activities. Which directly or indirectly provide, collect, deliver, receive, administer, contribution, custody or save funds, assets or resources, or perform any other act that promotes, organizes, supports, maintains, finances or economically sustains armed groups outside the law or its members, or national terrorist groups or foreign or terrorist activities liable to imprisonment of thirteen (13) to twenty (22) years and a fine of one thousand three hundred (1,300) to fifteen thousand (15,000) statutory minimum wages. “
International lists: List of people and companies according to the public body that are linked to criminal activity list object, such as OFAC (list known as Clinton), Interpol and FBI.
Associated risks: To become aware of the importance of risk prevention of money laundering and terrorist financing, as described below risks associated with uncontrolled business practices and / or ignorance of the subject:
- Loss of reputation.
- Be part of rumors.
- Be blacklisted.
- Loss of access to the services and products of the financial system.
- Loss of trade relations with other countries.
- Fines and penalties.
- legal issues in judicial proceedings. The general aspects described in this policy should be integrated into all procedures related to cash (payments, collections and other related transactions), shopping (negotiations with suppliers of goods and services) and sales.
Suspicious transaction report (STR): They are suspicious transactions carried out by the natural or legal persons who by their number, quantity or characteristics, do not fall within the systems and normal business practices of an industry or sector, and according to the customs of the activity concerned, they have not been reasonably justified. Thus shall be construed as suspicious, refusal to fill, process, underwrite, provide, formats or documentation that requires you to justify the origin of the money in cash intending to acquire our products
With the disclosure of this policy to our customers (travel agencies), suppliers, contractors and third parties involved in our operation, we declare we are against these illegal activities, which reject and report any suspicious transaction.
With the signing of this policy, we declare under oath:
- Resources, income and money of our business come from legal activities.
- Our company nor its partners, officers, directors, employees and subcontractors, we find negative records in listings prevention of money laundering or financing of terrorism, national or international.
- Our behavior conform to the law and ethics, and consequently we force ourselves to implement measures to prevent our operations can be used with or without your consent and knowledge as tools for concealment, management, investment or development in any form of money or other property from illicit activities such as money laundering, drug trafficking, human trafficking, pimping, child pornography, embezzlement, extortion, kidnapping, extortion, membership and / or dealings with illegal armed organizations or criminal organizations of any kind, arms trafficking, terrorism, crimes against humanity or crimes against freedom, integrity and sexual education.
- We checked and left written legal source of funds we receive from our customers constancy.
- We avoid our bank accounts to be used by third parties unknown, to make appropriations or transfers of money that the certainty of its legal origin can not be.
- It is written that we support any transaction with cash (pesos or currencies) that allows us to support traceability in case of any investigation.