LESSON 5: GENERAL SCHEME OF A PREVENTION SYSTEM

Before the beginning of the business relationship or during it, a series of measures (called due diligence procedures) must be applied to both the client and the operation.

The application of these measures allows the obliged subject to detect possible risk elements that must be examined through a specific procedure called special examination. The internal body of the company that will hear about these operations is the ICU.

These elements of risk can also be detected by any employee of the company. In this case, both the client and the operation must be communicated to the ICU to carry out the special analysis.

After the examination of the operation by the ICU, it can be decided to:

  1. Execute the operation if there is not suspicion that the operation is linked to money laundering or terrorism financing.
  2. Communicate the operation to the Executive Service of the Commission in the event of not being able to prove all or some of the points that led to the special analysis.