1. WHY AN IMPORTER / EXPORTER
COMPANY MUST CARRY OUT
PREVENTION PROGRAMS AGAINST
ASSET LAUNDERING?
ALFREDO MORENO DAVILA
www.customstrade.com
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2. JUSTIFICATION
• THERE EXIST SOME REPORTS ISSUED BY THE FINANCIAL ACTION
TASK FORCE (FATF) AND THE UNITED NATIONS (U.N) INDICATING THAT
IMPORT AND EXPORT COMPANIES ARE VERY EXPOSED TO ASSET
LAUNDERING OPERATIONS AND TERRORISM FINANCING.
• IN COUNTRIES LIKE MEXICO, PERU, COLOMBIA AND BRAZIL, IT IS
INCREASING THE AMOUNT OF ASSET LAUNDERING INVESTIGATIONS
ON IMPORT/EXPORT COMPANIES THAT ARE USED EITHER DIRECTLY OR
INDIRECTLY IN THESE WHITE COLLAR CRIMES. THIS CIRCUMSTANCE
ADDED TO NEWS REPORTED BY SENSATIONALISTIC MEDIA MAY IMPAIR
REPUTATION OF COMPANIES SPECIALLY THOSE LISTED IN
INTERNATIONAL STOCK MARKETS.
• THERE EXISTS SUBSTANTIAL AMOUNT OF INTERNATIONAL AND LOCAL
REGULATION ON PREVENTION AND PENALTY AGAINST ASSET
LAUNDERING, TERRORISM FINANCING AND RELATED CRIMES WHICH
ARE UNKNOWN BY THE MANAGEMENT COMMUNITY AND
UNFORTUNATELY BY MANY CORPORATE LAWYERS.

3. SCOPE OF THESE PREVENTION
PROGRAMS
• ELABORATION OF A MANUAL TAKING INTO ACCOUNT
BOTH "INTEGRAL SYSTEM FOR ASSET LAUNDERING
PREVENTION" (SPANISH ABBREVIATION : SIPLA) AND THE
"ASSET LAUNDERING RISK ADMINISTRATION SYSTEM
AND TERRORISM FINANCING" (SPANISH ABBREVIATION:
SARLAFT). APPLICATION OF ONE OR ANOTHER SYSTEM
WILL DEPEND ON THE LOCAL REGULATION OF EACH
COUNTRY AND THE TYPE OF COMPANY.
• TRAINING
• CLOSE ASSISTANCE WITH THE COMPLIANCE OFFICER
DESIGNATED BY THE COMPANY OF EACH COUNTRY TO
COORDINATE ANTI-ASSET LAUNDERING ACTIVITIES.

4. OUR EXPERIENCE
• THE ABOVE MENTIONED PROGRAMS HAVE BEEN CARRIED OUT
WITH SUCESS IN COMPANIES PERTAINING TO THE FOLLOWING
SECTORS : CONSUMER PRODUCTS, SERVICES AND LARGE
IMPORTERS.
• WE HAVE TRAINED A WIDE VARIETY OF PEOPLE OF THE BUSINESS
COMMUNITY, LEGAL FIRMS, AND EVEN, ADMINISTRATIVE STAFF OF
NON-PROFIT ORGANIZATIONS (CHRISTIAN CHURCHES).
• ON THE OTHER HAND, WE HAVE ALSO ADVISED PERSONS AND
ENTITIES THAT HAVE BEEN VICTIMS OF ASSET
LAUNDERING
OPERATIONS . WE HAVE ADVISED THEM IN CRIMINAL LAW (LOCAL
AND INTERNATIONAL) INCLUDING INTERNATIONAL LAW FOR
RESTORATION OF BUSINESS CATEGORIES AND/OR VISAS IN THE
UNITED STATES AND CANADA.

5. ALFREDO MORENO DÁVILA
Abogado LL.M
U. Andes - U. Ottawa - U Carleton
Aduanas y Comercio Internacional
Calle 90 No. 12-28 Piso 2
Bogotá D.C Colombia
Tel. (57)(1)7047163 Cel (57) 310-8778915
alfredomorenodavila@customs-trade.com
www.customs-trade.com
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