The Due Diligence Procedure Manual is a key component of the system, owing to the fact that it allows Obligated Entities to adapt their individual activities and operations to the measures stipulated in the Law.
In order to prepare the Due Diligence Procedure Manual, Soluciones Confirma studies the individual characteristics of every company, as well as its specific activity and operations.
Under these criteria, the information is used to create a tailor-made document for the Obligated Entity according to current law, in order to reach optimum compliance with maximum efficiency, providing sectoral customized standards, based on services and level of customer risk.
Our team of experts elaborates the Due Diligence Procedure Manual backed by the extensive experience, which boasts the implementation of more than 150 guidelines for different business sectors.
Procedures and measures which the Due Diligence Manual would include
- Standardized, simplified and reinforced measures for Due Diligence.
- Individuals with public responsibilities.
- Special inspection of operations.
- Suspicion of money laundering communications.
- Abstention from carrying out operations.
- Systematic communication.
- Collaboration with the Commission and its Support Network.
- Exemption from responsibility.
- Oath of secrecy.
- Keep appropriate records.
- Periodic system checks.
One of the amendments to the 10/2010 Act is the freedom of self-regulation given to Obligated Entities, which requires in-depth knowledge of the current law. Additionally, at an operational level the Due Diligence Procedure Manual, as a living document, it should be reviewed and updated regularly in order to keep in line with the Obligated Entity's activity and the current law.
The Consultancy Service offered via Soluciones Confirma's team of experts, reaches optimum compliance with maximum efficiency, providing sectoral customized standards based on services and level of customer risk, while minimizing both costs and efforts for the Obligated Entity.
- Due Diligence Procedure Manual implementation and updating, in order to adapt the contents to the 10/2010 Act and any future amendments to the current law.
- Assistance to specific issues regarding practical application of the prevention system.
- Technical assistance in responding to SEPBLAC's requirements.
- Defence, where appropriate, of sanctioned dossiers, until exhausting all administrative channels.
Soluciones Confirma has the know-how and the expertise of its partner, Abogados Rubí Blanc, to help Obligated Entities to meet the mandatory subject of auditioning their internal control measures to yearly external revision at the hands of individuals who satisfy the appropriate academic qualifications and professional experience required to carry out such specialized task.
Our experience, backed by more than 400 External Experts Reports for different sectors, makes us the suitable supplier of this service for every Obligated Entity's sector of activity.
Audit results are recorded in a written Report which details the current internal control measures, rates their operative competence and proposes possible amendments and improvements where applicable.
- Annual Revision of Internal Control Measures.
- Elaboration of the Written Report: operative competence rating, detected deficiencies and rectifications and improvement proposals.