Financial Crime World

High-Ranking Position Holders and Real Risks: A New Era in Financial Regulation

In an effort to strengthen financial regulations and combat money laundering and terrorist financing, the Securities Commission has issued new instructions aimed at identifying high-ranking position holders who pose real risks to the financial system.

Key Takeaways


  • High-ranking position holders with real risks will be identified through a thorough assessment of their wealth sources.
  • Financial institutions must obtain senior management approval before establishing relationships with these individuals.
  • Continuous monitoring of transactions is crucial to prevent illicit activities.
  • A reporting officer will be appointed to ensure compliance with anti-money laundering and terrorist financing regulations.

The Role of Reporting Officers


  • Reporting officers will be responsible for investigating suspicious transactions linked to money laundering or terrorist financing.
  • They must have a high functional level, relevant experience, competence, and educational qualifications.
  • The Commission has emphasized the importance of confidentiality in reporting procedures.

Internal Regulations


  • Financial institutions must establish internal regulations that include policies, procedures, and controls to combat money laundering and terrorist financing.
  • These regulations will be subject to regular assessments and audits to ensure compliance.

Record Keeping


  • Institutions must maintain records and documents related to their operations for at least five years.
  • Files on suspected transactions linked to money laundering or terrorist financing must be kept for a minimum of five years.

Auditor’s Role


  • Auditors must commit to ensuring that institutions comply with anti-money laundering and terrorist financing regulations.
  • Annual reports will be submitted to the Commission, including the auditor’s opinion on compliance.

Penalties for Non-Compliance


  • Institutions found guilty of non-compliance will face penalties under the Securities Law No. 74/2004 or the Anti-Money Laundering Act, whichever is stronger.

The new instructions aim to enhance financial regulations and prevent illicit activities in the sector. By identifying high-risk individuals and implementing robust monitoring systems, the Commission seeks to ensure a safer and more transparent financial environment for all stakeholders.