Confederación Española de Cajas de Ahorros

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Anti-Money Laundering

The Anti-Money Laundering Policy of CONFEDERACIÓN ESPAÑOLA DE CAJAS DE AHORROS (CECA) is a global policy designed to ensure that all employees and businesses of the Entity are well informed with respect to their customers and the nature of the transactions processed through their accounts.

CECA is domiciled in Spain and lead-regulated by the Bank of Spain. As such CECA is obliged to comply with spanish legislative and regulatory provisions, often based upon European legislation concerning the fight against money laundering and terrorism financing.

The objectives are:

To ensure compliance with anti-money laundering laws and regulations (follow the anti-money laundering recommendations that have been made by the Financial Action Task Force on money laundering).
To ensure observance regarding customer identification (“Know Your Customer” principles), obtaining verifying information and record keeping. It is incumbent upon the relationship manager to perform the requisite KYC due diligence involved in a new customer relationship. The policies address the significance of thorough KYC procedures and monitoring of foreign correspondent bank relationships.
To enable recognition, investigation and reporting of suspicious activity to the local established Authorities.
To protect the reputation and integrity of the Entity.

CECA has a global client acceptance & anti-money laundering policy based on national and international anti-money laundering standards. This policy applies to the London branch.

CECA is subject to regular audits by the Bank of Spain, to assure CECA’s compliance with spanish legal and regulatory provisions and with the CECA policies and procedures. We have the means and the internal written procedures in place to detect money laundering and/or terrorism financing channels or chains, including the Know Your Customer rules. The policy and procedures are controlled and supervised by our internal auditors.

CECA has created and independent supervisory committee, the Anti-Money Laundering Committee, charged with coordinating the Compliance Department. The members are senior managers drawn from units of the Entity, in order to provide a multi-disciplinary approach to the CECA’s anti-money laundering commitment. The skill sets drawn upon include knowledge of credit analysis, legal and regulatory issues, operations and technology and products and services.

Responsibilities of the Committee:

To investigate accounts identified through internal or external information or by the Entity’s monitoring systems as engaging in unusual or suspicious activity.
To recommend new and modified anti-money laundering procedures and policies.
To terminate account relationships suspected of being inconsistent with, or presenting unacceptable risk or being in violation of anti-money laundering laws and regulations.

The policies defines the responsibility of each department within the Entity to perform its own assessment of risk to money laundering activities, and to develop risk-based policies and procedures taking into consideration its services, customer characteristics, country and industry risk…Each department’s policies and procedures should contains a system of internal controls to provide for proper record keeping and reporting of suspected money laundering activities and must be reviewed and updated annually as appropriate.

The effectiveness of the CECA’s anti-money laundering efforts depends upon the knowledge and vigilance of its employees. Accordingly, the policy imposes certain training requirements, to coordinate and deliver formalized anti-money laundering training to CECA personnel.