Now, according to Law 2195 of 2022, the non-compliance with the guidelines that the superintendencies or supervisory authorities determine on ML/FT/AMFTPD may result in criminal proceedings or even administrative penalties of up to two hundred thousand (200,000) legal monthly minimum wages in force. For this reason, some relevant aspects that seek to complement the company's compliance program are presented below:

Organizational culture and tone of senior management: requires a degree of commitment and seriousness of senior management or associates and that their example is transmitted to all members of the entity, as considered by the Superintendence of Corporations in External Circular 100-000011 of 2021.

Corporate monitoring and auditing: means the periodic evaluation of the particular risks faced by the company.

Analysis and preparation of risk matrices: involves the delimitation of the activities developed by the company, in order to establish priorities that require greater management and care.

Creation of codes of conduct, policies, protocols and internal procedures: these documents are evidence of the company's commitments adopted, as well as of the duty to implement them.

Appointment of an independent, autonomous and trained compliance officer: this person is responsible for implementing and ensuring the effectiveness of the organization's compliance program.

Training and education: raising awareness of these issues to each member of the organization allows everyone to know the importance of effective ML/FT/AMLAP prevention, according to the sector in which they operate.

Whistleblower hotlines: they are an ideal tool to receive reports of conduct that may contravene the company's policies, thus allowing an earlier reaction.

Adequate incentive and sanction schemes: the ethical behavior of senior management must be accompanied by effective regulation of the procedures and sanctions applied for behaviors that are not in line with the company's wishes.

Improvement plans: no system is completely infallible, and everything is susceptible to improvement, which is why periodic reviews of the systems will make it possible to identify the shortcomings of the programs, the assignment of new duties and functions to compensate for these shortcomings, all subject to the fulfillment of the plans within specific and determinable deadlines.

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