The amendments introduced in the 10/2010 Act have increased the level of requirements regarding the measures and procedures to be implemented by the Obligated Entities, and encourages them to launch new strategies which will help them to generate intelligent monitoring systems and to share information.
The aim of SISO is to comply with this requirement in accordance with article 33.2 of the Spanish Anti-Money Laundering and Counter-Terrorism Financing Act which states:
"(...) the financial agencies cited in Article 33.2 of the Act, hereafter referred to as Reporting Entities, may exchange information relating to operations referred to in articles 18 and 19 with the sole purpose of preventing or avoiding operations relating to money laundering and terrorism financing (...)"
Soluciones Confirma creates SISO as a response to the demand of information exchange and common procedures among the Obligated Entities, with the aim of preventing and avoiding operations relating to money laundering and terrorism financing.
Main Principles of SISO Regulation
- It is a multi-sectoral information exchange bureau.
- It contains data – on both individuals and companies– regarding operations which are suspicious of money laundering, terrorism financing and/or which have been derived from SEPBLAC communications.
- Based on the reciprocity principle, data is downloaded into the system by the database participants.
- It is ruled by the requirements established in the SISO File Principles, which legal basis is stipulated in Article 33.2 of the 10/2010 Act.
- ASNEF is responsible for and owner of the database.
In SISO the use and exchange of information among Participating Entities is carried out for the sole purpose of preventing and avoiding operations of money laundering or terrorism financing, where the characteristics or operative of a specific case could, once rejected, present itself once again as an identical operation, in whole or in part, to other Reporting Entities.
The information collected in the SISO can only be accessed and supplied by Participating Entity's Anti-Money Laundering Departments and their teams, under the previously defined purpose, and on request or agreement, giving rise to the data which ultimately feeds into the database.
SISO Alert System delivers to the participants an online access helping them to avoid operations considered under risk of money laundering or terrorism financing; operations for which other Reporting Entities might already have been alerted and as a consequence, communicated to SEPBLAC.
The database empowers the interrelation among Anti-Money Laundering Departments and the idea sharing regarding procedures and information, which is the main fundament of the SISO File, by creating of a technologic network of common practice which alerts the system when facing money laundering and allows the fulfillment of the current law.
The Benefits of Participating in the SISO File
- It provides access to a file with high quality information on anti-money laundering and counter-terrorism financing, which hosts every communication made to SEPBLAC.
- It improves customer approval and monitoring filters thereby reducing the risk of approving potential criminal operations.
- It enhances and improves internal control and the actions of anti-money laundering departments while reducing process and technology costs.
- It provides expert advice from the SISO Control Committee.
ASNEF, as owner of the SISO File, has created a Control Committee for monitoring the compliance of the legal requirements stipulated in the SISO File Regulation.
Apart from monitoring the compliance of the Regulation, the Control Committee members work together defining the basic standards to meet the law in any participating industry sector.