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Compliance Audit Checklist for Banks in Colombia

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In an effort to ensure the implementation of effective Anti-Money Laundering and Terrorism Financing (AML/TF) controls in Colombia’s banking sector, regulatory bodies have mandated a comprehensive audit checklist. This article provides an overview of the key areas covered by this checklist.

I. General Information

The following information is required for the compliance audit:

• Name of the bank: Banco Davivienda S.A. Colombia
• Web page: www.davivienda.com
• Main office address: Avenida El Dorado # 68 C - 61 piso 10, Bogotá D.C., Colombia
• Number of offices in the country: 597 (Colombia)
• Affiliates abroad: Panamá, Costa Rica, El Salvador, Honduras, and Miami (Branch)

II. AML/TF Policies and Procedures

The checklist assesses the bank’s ability to prevent and control Money Laundering and Terrorism Financing risk through its policies and procedures.

1. AML/TF System or Policy Manual

• Does the bank have a system in place for preventing and controlling Money Laundering and Terrorism Financing risk?
  • Yes / No
• Is the AML/TF System or Policy Manual approved by the Board of Directors?
  • Yes / No
• Does the manual describe the duties and responsibilities of the Board of Directors, Legal Representative, and Compliance Officer in preventing Money Laundering and Terrorism Financing?
  • Yes / No

III. Knowledge of Customer

The checklist evaluates the bank’s procedures for customer identification and knowledge.

1. Customer Identification and Know Your Customer (KYC) Data

• Does the System or Compliance Manual include policies for identifying and knowing customers?
  • Yes / No
• Does the organization have procedures to create a record for each customer, including identification information and KYC data?
  • Yes / No

IV. Monitoring of Operations and Report of Suspicious Transactions

The checklist assesses the bank’s ability to monitor transactions and report suspicious activities.

1. Electronic Consolidation of Customer Operations

• Does the organization have procedures for electronically consolidating all customers’ operations?
  • Yes / No
• Does the organization have a procedure for identifying and reporting suspicious activities or transactions to the respective authorities?
  • Yes / No

V. Training

The checklist evaluates the bank’s training program on AML/TF prevention and control.

1. Employee Training Program

• Does the organization have a training program for employees on customer knowledge and preventing Money Laundering and Terrorism Financing?
  • Yes / No
• Does the organization keep records of training sessions, including attendance and relevant materials used?
  • Yes / No

VI. Compliance Certification

The checklist requires certification from the Compliance Officer that the information provided is accurate and complete.

1. Compliance Officer’s Certificate

Name: Liliana Alvis Cruz Title: Compliance VP Date: February 14, 2017