The Compliance Subdivision is the unit responsible for detecting, monitoring and reporting unusual or suspicious transactions that might be linked to possible cases of asset laundering, terrorism financing, bribery and receiving stolen goods. This area forms part of the General Counsel’s office, although it reports directly to the Compliance Committee. With its focus being mainly preventive, this unit is also charged with ensuring compliance with the FATCA (Foreign Account Tax Compliance) law at the holding level, as well as the application of the Compliance Program.
The Manager of the Compliance Subdivision also acts as the “Head of Prevention”, a role that takes the lead on the Crime Prevention Model and is framed in the application of Law 20,393 on Criminal Liability of Legal Entities. As part of these responsibilities, the Compliance Subdivision seeks to permanently strengthen the procedures and technological tools which make it possible to track the transactions, products and services offered by Tanner Servicios Financieros S.A. and its subsidiaries.
During 2017, the Subdivision initiated the process of implementing the CRS (Common Reporting Standards) regulations, which will take effect in 2018 and which require Chile as a country that has signed this agreement to share tax information with 100 other countries on foreign residents in Chile and Chileans who have commercial activities abroad. The obligations contained in these regulations, signed by our country under the OECD umbrella, will channel Chilean companies through the Domestic Tax Service (Servicio de Impuestos Internos, “SII”). Similarly, the necessary adjustments have been made for the implementation of Circular No. 57 of the Financial Analysis Unit (Unidad de Análisis Financiero, “UAF”), to identify natural people who have the status of Final Beneficiary and/or Effective Controller of Legal Entities.
ENVIRONMENTAL AND SOCIAL POLICYIn line with our commitments to our external creditors, this policy has been fully implemented, undertaking a commitment to develop a culture of Environmental and Social Responsibility. This fits with the concern of Tanner Servicios Financieros S.A. for preserving the environment and demonstrating social responsibility, which today is one of the main challenges for the sustainable development of humanity and the continuation of economic and business models.
TRAININGDuring 2017, the Compliance Subdivision delivered its annual training plan, which included the following activities:
- Face-to-face presentations: organized throughout the year in line with a planned schedule and to meet the specific requirements of some areas.
- e-learning courses: training in asset laundering prevention and criminal liability of legal entities, which are mandatory for all employees once a year.