Anti-Money Laundering (AML) and Due Diligence (KYC) Policy
Money laundering involves hiding an illegal source of funds by converting it into cash or seemingly legitimate investments.
General Provisions
Our Anti-Money Laundering Policy ("AML Policy" hereinafter) is based on the following essential principles:
• Do not establish business relations with criminals and/or terrorists.
• Do not process transactions that arise from criminal and/or terrorist activities.
• Do not facilitate any transaction related to criminal and/or terrorist activities.
Verification procedures
The Store has its own procedures to determine compliance with the standards of the AML policy and the Due Diligence policy (KYC, Know Your Customer).
Store Customers complete a verification procedure (they must provide a state-issued identification document: Passport or ID card). The Store reserves the right to use Customers' identification information for the purpose of adhering to the AML Policy. The information is processed and stored strictly and in accordance with the Store's Privacy Policy. The Store will verify the authenticity of the documents and information provided by the Customers and reserves the right to request additional information from Customers who have been identified as potential risk.
If the Customer's identification information has changed or if his/her activity becomes suspicious, The Store has the right to request updated documents from the Customer, even if these have been authenticated in the past.
Compliance Officer AML - KYC Policy
The Store has an Agent for Compliance with the Anti-Money Laundering Policy, responsible for ensuring compliance with the AML Policy and the execution of KYC procedures such as:
• Collection of Client Identity Information.
• Updating and monitoring internal policies and procedures to create, review, submit and process all necessary reports in accordance with existing laws and regulations.
• Monitoring and tracking transactions to carry out an analysis of any significant deviation within the normal activities of the Clients.
• Creating a Records Management System for AML to Store and Retrieve Documents, Files, Forms and Records.
• Regular analysis of risk assessments.
Transaction Monitoring
Monitoring the Client's transactions and analysing the data obtained is a tool that allows the risk level of these transactions to be assessed and suspicious transactions to be detected. In the event of any suspicion of money laundering, the Store will monitor all transactions of the corresponding client and reserves the right to:
• Request the Client to provide additional information and documents.
• Suspend or close the Customer Account.
Record retention and reporting of information
As part of our AML program, we maintain relevant documentation regarding the identity of the client and the electronic transmission of funds that the client carries out. The retention period for the records is updated in accordance with the regulations in force. The current period established for the retention of said records is ten years. The file must be completed in such a way that it is available to all employees who must have access to the client in question.
We will respond to written, reasoned and legally binding requests issued and motivated by official authorities within the legal framework with respect to accounts and transactions, searching our records to determine whether we maintain or have maintained any information, or have conducted any transactions with each person, Entity or organization appropriately defined and named in the request.
If no information is found, we will provide the relevant response, maintain documentation of the search conducted, and keep a record of the name of the individual or company in the application for our risk-based procedures.
Customer identification and source of funds
We store certain identifying information about each of our customers before they perform any transaction:
For individuals
• Name and any other names used.
• DNI, Passport Number or National Identity Card, or Residence Card or other identification number or Driver's License Number.
• Residence information (address and/or utility company customer number, data, etc.).
• Biometric Verification.
• Other additional client information if necessary to meet the requirements of the risk-based approach.
For companies or legal entities
• Company Name.
• Main place of activity information.
• Contact information.
• Incorporation data (number in the corresponding registry, date of incorporation, etc.).
• Payment details and/or bank details.
• Relevant information about the place of residence (address data or utility customer data).
• Data of the persons authorized to operate on behalf of the company and the details of the authorization.
• Biometric Verification of the Administrator and/or Administrators of the entity.
•Other additional client information if necessary to meet the requirements of our risk-based approach.
We will apply relevant risk-based measures to verify the identity of each customer and maintain the necessary records.
Risk assessment
In accordance with international requirements, La Tienda applies a risk-based approach to combating criminal acts. Measures aimed at preventing money laundering and terrorist financing are therefore proportional to the risks identified, allowing resources to be allocated effectively. Resources are used on a priority basis; the higher the risk, the more attention is required.