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Financial Crime Compliance (FCC) Corporate Framework for Banco Santander, S.A.

Scope

The FCC corporate framework applies to all Santander Group entities and is designed to ensure compliance with financial crime regulations.

Key Principles

• Risk Management: Identify, assess, and mitigate financial crime risks.
• Compliance: Ensure compliance with financial crime regulations, laws, and industry standards.
• Transparency: Maintain transparency in business activities and transactions.
• Proportionality: Implement proportionate measures to manage financial crime risks.

FCC Programme Components

1. Sanctions Compliance

Ensure compliance with international sanctions programs and restricted goods/merchandise regulations.

2. Anti-Bribery and Corruption (ABC)

Establish controls to prevent bribery and corruption in third-party relationships, sponsorships, charitable contributions, and political contributions.

3. Customer Lifecycle Due Diligence

Verify customer identity, assess risk, and monitor business relationships.

4. FCC Risk and Control Programme

Assess and manage financial crime risks, including country risk, product risk, and transaction risk.

Governance

The Board of Banco Santander, S.A. is responsible for decision-making and monitoring FCC matters. Boards of subsidiaries are also responsible for FCC matters at their level. Governance bodies must promote clear decision-making, accountability, and transparency.

Note

This summary is not exhaustive, and the original document provides more detailed information on each topic. If you have any specific questions or need further clarification, please don’t hesitate to ask.