Financial Crime World

Santander Group’s Financial Crime Compliance (FCC) Corporate Framework

Introduction

The Santander Group’s FCC Corporate Framework is a comprehensive document outlining the policies, procedures, and governance structure designed to prevent financial crime across the organization.

Key Components of the FCC Corporate Framework

Risk Assessment and Control

  • Identifying, assessing, and mitigating financial crime risks associated with various business lines and products.
  • Emphasizing the importance of effective risk management in preventing financial crime.

Compliance Obligations

  • Outlining specific compliance obligations related to:
    • Anti-money laundering (AML)
    • Combating the financing of terrorism (CFT)
    • Sanctions
    • Other relevant regulations

Customer Due Diligence

  • Stressing the need for thorough customer due diligence, including:
    • Verification of customer identity
    • Ongoing monitoring to prevent money laundering and terrorist financing

Suspicious Transaction Reporting

  • Requiring prompt reporting of suspicious transactions to:
    • Relevant authorities
    • Internal escalation procedures

Whistleblowing Policy

  • Including an anonymous whistleblowing policy to encourage employees to report any suspected financial crime without fear of retaliation.

Training and Awareness

  • Implementing regular training programs to ensure all employees understand their role in preventing financial crime and comply with the framework’s requirements.

Record Keeping

  • Maintaining accurate and accessible records for relevant FCC-related information.

Governance Structure

The FCC Corporate Framework emphasizes the importance of a robust governance structure, including:

Board Oversight

  • The Board of Banco Santander, S.A., its committees, and subsidiary boards are responsible for implementing and overseeing the FCC Corporate Framework.
  • Ensuring that the Board is informed about financial crime risks and compliance obligations.

Risk Supervision Body

  • A dedicated risk supervision body (Board Risk Committee) is established to assist and advise the Board on:
    • Risk management
    • Regulatory compliance
    • Internal control

Conclusion

The Santander Group’s FCC Corporate Framework demonstrates a strong commitment to maintaining a robust financial crime compliance program that aligns with international standards and best practices.