The Corporative Policy of Anti-Money Laundering and Countering the Financing of Terrorism and Concealment of Assets, Rights and Values in Operations (“Policy”) of Neon Pagamentos S.A. - Instituição de Pagamento (“Neon”), aims to define guidelines and rules that need to be observed by all, purposing the alignment of operations with legal and regulatory requirements, as well as best practices pertaining to Money Laundering, Financing of Terrorism, and Concealment of Assets, Rights and Values crimes.
Every employee, partner, supplier and third party has the responsibility to know and comprehend the terms of this Policy terms and seek prevention and detection of operations or transactions that have atypical characteristics to combat Money Laundering, Financing of Terrorism, and Concealment of Assets, Rights and Values crimes.
After approval by directors, this Policy should be widely disseminated internally. All employees are obligated to review the concepts of this Policy when annually attending the AML/CFT training (see item II.8).
Money Laundering: Criminal activities that aim to convert illegal money into legal money, in other words, it is the process by which the criminal transforms illicit resources into apparently legal resources by hiding the nature, origin, localization, disposition, movement or ownership of assets, rights or values derived, directly or indirectly, of a criminal offence.
Financing of Terrorism: It consists in collecting funds/capital to carry out a terrorist activity. This capital can be donated or obtained in legal or illegal activities, such as drug trafficking, prostitution, organized crime, smuggling, extorsion, kidnap, fraud etc.
Corruption: Suggest, offer, submit, request, accept or receive, directly or indirectly, undue advantages for public agents or third sector organizations.
Politically Exposed Person (PEP): Public agents who occupy or have occupied in the past 5 years, in Brazil or other countries, a public position or function in relevant public entities, as well as their representatives, family or other people with a close relationship. Furthermore, there are some situations that characterize a close relationship, and consequently the client can be considered a Politically Exposed Person, as direct or indirect company control of a client.
Final Beneficiary: Person that, directly or indirectly, owns, controls or has significant influence over the company structure. Exceptions to this rule are listed companies or non-profit organizations and the cooperatives, for which the information collected should encompass private individuals authorized to represent them, , as well as the controllers, administrators, executive directors, if applicable.
Shell Bank: Bank established in a jurisdiction in which there is no physical company and it is not integrated in a regulated financial group.
Institution: Neon Pagamentos S.A.
Controlled Company: Third Party Asset Manager (Neon Investimentos S.A.).
COAF: The Financial Activities Control Counsel, with the mission to produce financial intelligence and promote the financial sector’s protection against money laundering and financing of terrorism. COAF receives, examines and identifies suspicious occurrences of illegal activities and communicates the competent authorities to initiate procedures.
INCREDIBLE AND HIGH PERFORMANCE
We deliver solutions for our clients with innovation, simplicity, and that extra something that makes all the difference. We are result-oriented to ensure the best experience for our clients.
TALENTED AND COLLABORATIVE
We are protagonists of our development, always seeking to improve our knowledge and abilities to deliver the best work to our clients. We spare no efforts to share information and help our colleagues. Here, we go by the motto one for all and all for one!
FUNNY AND RESPONSIBLE
We work in a light and relaxed way, but also with a lot of responsibility and focus on our commitments and results. We take responsibility for our work and company, after all, Neon is ours!
Honesty - We act according to what is fair, honest and upright.
Responsibility - We act seriously, know our obligations and are accountable for our actions.
Respect - We act considering customers, suppliers, employees, facilities and means of work, the community where we operate and the environment.
Our principles of conduct are detailed in the Neon Code of Conduct.
Neon will evaluate the products and services offered considering the risk of improper use of the products and services for Money Laundering, Financing of Terrorism, and Concealment of Assets, Rights and Values in Operations, taking the necessary precautions to mitigate such risks. This Policy will identify the Money Laundering and Financing of Terrorism concepts, steps and characteristics of people and products susceptible of this crime.
This Policy strengthens the commitment of the whole organizational structure, business departments being the first line of defense or the Risk and Compliance department being the second line of defense.
The entire organizational structure has specific attributions in combating Money Laundering and Terrorism Financing, as described below.
2.1. RISK AND COMPLIANCE COMMITTEE
Deliberative and control committee, with deliberative powers, composed of Neon professionals, with the following responsibilities:
2.2. AML/CFT RESPONSIBLE DIRECTOR
2.3. ANTI-MONEY LAUNDERING
2.4. INTERNAL CONTROLS AND OPERATIONAL RISK
2.5. CUSTOMER REGISTRATION
It is the responsibility of the Customer Registration department to comply with all the precepts contained in this Policy, with special attention to:
It is the responsibility of all employees, even in the position of intern or third party, and partners:
The process of laundering money typically involves three steps: placement, layering, and integration.
Neon adopts a risk-based approach stipulated by the verification of categories and variables. This action ensures that the measures adopted to prevent or reduce the money laundering and financing of terrorism crimes are proportional to risks identified during the relationship acceptance, monitoring or maintenance processes.
In order to mitigate subjectivity, the methodology stipulates that the customer will have a risk rating defined by an algorithmic model according to categories: Customer, Transaction and Product.
Our Internal Risk Assessment considers all costumers whose account was approved, excluding only those costumers that the opening account was disapproved, therefore, without any relationship with Neon.
For socio-environmental crimes, the risk classification logic is based on the repercussion of the image risk.
The Internal Risk Assessment and the reviews need to be approved by the Statutory Director responsible for AML/FT and forwarded to the Risk Committee and the Board of Director.
5.1. CUSTOMER IDENTIFICATION- KNOW YOUR CLIENT
It is a set of actions to establish mechanisms to ensure the identification, economic activity, origin and constitution of assets and financial resources of clients, encompassing collection, update and storage of registry data, including specifics procedures to identify the final beneficiary and Politically Exposed Persons.
Neon adopts, as the main way of registering the client, the electronic costumer identification form. The Customer Registration department is responsible for the analysis, registry of information and identification documents of costumers with whom the institution maintains a relationship.
In case the client is classified as a high risk, a more detailed diligence is made in the process. This diligence aims to identify the institution’s costumers and verify the relevant information to keep business and transactions, reducing the risk of digital financial crimes.
5.2. KNOW YOUR EMPLOYEE
It is a group of rules, procedures and controls that must be adopted for selection and monitoring of the reputation, to avoid relationships with people involved in illegal acts.
5.3. KNOW YOUR SUPPLIER
It is a set of rules, procedures and controls that should be adopted for supplier identification and acceptance, aiming to prevent the hiring of disreputable companies or those suspected of involvement in illegal activities. For those that represent a bigger risk, complementary procedures and specific approval levels must be adopted, according to the criticality of the notes or exceptions.
5.4. KNOW YOUR PARTNER
It is a group of rules, procedures, and controls that should be adopted for identification and acceptance of commercial partners, aiming to prevent business with disreputable parties or those suspected of involvement in illegal activities, as well as ensuring that they have adequate AML/CFT procedures, when applicable.
The Compliance department participates in the Products Committee to evaluate AML/CFT aspects of the new products and services with the main goal to reduce regulatory risk and the risk of these products being used for money laundering or financing of terrorism crimes.
5.5. NEW PRODUCTS AND SERVICES EVALUATION
AML/CFT department participate of Products Committee to previously evaluate from a AML/CTF perspective the new products and services with the objective of mitigating regulatory risks and the risk of these products being used to commit laundering money crimes and/or terrorist financing.
The AML department is responsible for operation-monitoring routines and identification of signs of Money Laundering and Financing of Terrorism. Monitoring is carried out through a system that has an interface with internal systems that collect registration, operational and financial information from customers, through parameterization of rules. Once the occurrence is generated, the AML department should analyze the client profile and operations to confirm if they are evidences of Money Laundering and Financing of Terrorism.
As a result of any identification of suspicions of Money Laundering or Financing of Terrorism by clients, Neon can choose to end the commercial relationship.
The operations, situations or proposals with signs of Money Laundering or Financing of Terrorism must be reported to regulatory entities, when applicable, as per legal and regulatory determinations.
Reports made in good faith do not entail civil or administrative liability to Neon, its managers or employees. The report information is confidential and cannot be disclosed to clients or third parties.
The report deadline is one business day after its approval.
Through an online system, all the employees and shareholders have access to training that aims to review the concepts of this Policy and encourage the adoption of applicable measures in face of suspicions of Money Laundering and Financing of Terrorism.
Annually, the AML department reviews the materials, and all are required to undergo a new training. In addition, during the onboarding, new employees need to finish this online training.
As a result of any evidence of Money Laundering or Financing of Terrorism by the clients is identified, Neon can choose to terminate the relationship, as well as report the evidences to Regulatory Entities, according to competence for deliberation.
Documents referring to transactions must be stored for a minimum period of 10 years from the closure of the account or the conclusion of the last transaction carried out by the customer.
All the information related to suspicion of Money Laundering and Financing of Terrorism are confidential, and should not be, in any case, made available to the involved parties.
The reports of suspicious cases regulated by Central Bank Rule No. 4001/20 (Circular BCB 4001/20) are for the exclusive use of the Regulatory Entities, for analysis and investigation.
For cases of exception to the rules of this Policy, the applicant should present the exception request with respective grounds to the Board, and its approval should be carried out by, at least, two directors of this Policy.
The breach of the legislation and regulatory rules submits employees and shareholders to sanctions, which could be administrative penalties or criminal penalties, for Money Laundering, Financing of Terrorism and Fraud.
Negligence or voluntary failure are considered a breach of this Policy and the Ethics and Conduct Codes, leading to application of disciplinary measures provided for in internal regulations.