Warning signs

If within your functions situations occur that generate doubts or are outside the usual behavior of people or operations, you must inform the immediate boss and the compliance officer, avoiding that the institution ends up immersed in crimes such as money laundering, financing terrorism, corruption, fraud, among others.

You are part of an institution that works on risk mitigation, prevention and control. Here are some red flags to watch out for

  • Increases (equity, income, operations, amounts, etc.) not justified or outside the averages of the respective sector or economic activity.
  • Alleged misuse of identities, for example: use of non-existent identification numbers, identification numbers of deceased persons, impersonation of persons, alteration of names.
  • Presentation of false or allegedly false data documents or information.
  • Acting on behalf of third parties and apparently fronted companies.
  • Relationship with people linked or allegedly linked to criminal activities.
  • Relationship with assets of alleged illicit origin.
  • People who refuse to provide the information and documentation requested.
  • Inconsistency of financial data.
  • People reported in the mass media or on the restrictive lists.
  • Which are listed on the OFAC - UN and INTERPOL lists and on the national lists (Police, Attorney General's Office, Comptroller's Office, etc.).
  • That request payments to third parties that are not involved in the operation.
  • Breach of contract clauses.
  • Quotes from suppliers that are well below those offered in the market.
  • Employees who receive gifts, invitations and gifts from certain clients without clear and reasonable justification.
  • Make contracts with people who are not fully identified - Who refuse to provide or do not fill out the required documentation.
  • Make a contract without leaving documentary evidence of them.
  • They split transactions to avoid documentation requirements.
  • They fill out the forms or formats with illegible handwriting.


Additionally, the following considerations should be taken into account with people who identify themselves as publicly or politically exposed PEP, where greater attention should be paid since they are people classified with greater sensitivity and exposure to LAFT risk.

  • Person who takes advantage of PEP recognition to simplify know-your-customer and due diligence procedures.
  • PEP who transacts outside of your usual profile and tries to use your status and popularity to evade controls or justify unusual operations.
  • PEP that recommends linking a customer.
  • Client requesting a “simplified” link given the PEP reference.
  • PEP who in some cases verbally intimidate the employee, who wants to put controls first, stating that not receiving the client can cause more serious problems for the organization.


one Always handle the concept of prevention and the caution.

From Complete the validations in the restrictive lists and, as a good practice, verify in the media that there is comment on the person or company with whom you intend to manage the relationship.

three Identify warning signs, it should not necessarily be considered suspicious, it is only sufficient if you generates doubts, notify your immediate boss and the Risk Management area.

four As a new preventive measure, those in charge of contractual relationships must attach in documentss that are sent to the legal office, the verifications you do on the restrictive lists.

Know the formats

one We invite you to know the current formats that are handled in the institution in the matter of SARLAFT, they apply for the due diligence of customer and employee relationships and for contractual relationships (contracts, agreements and projects). Learn more

From It should be remembered that for new supplier connections, the current format published on the web portal must always be used, which must be delivered to the accounting area. Learn more

three Finally, we want to inform you that non-compliance with the SARLAFT process at the CES University and its headquarters, leads to the imposition of sanctions provided for in the institution's labor regulations.

Did you know that CES University is creating a culture that fights against money laundering and terrorist financing?

  • Do you know what money laundering is?
    It is a figure that seeks to give the appearance of legality to money of illegal origin.
    Criminals through the movement of money assets, seek to give legal appearance of their profits or make it difficult to trace the legal origin of their profits.
  • Do you know what terrorist financing is?
    It is an act that provides, collects, delivers, receives, manages, contributes, custody, saves funds, goods or resources, financial support to illegal armed groups or to national or foreign terrorist groups.
  • Effects of money laundering and terrorist financing
    Laundering assets, financing terrorism with or without knowledge for others to do so, are crimes at a national and international level, which generate social, economic, legal and reputational problems. Reputational: loss of reputation due to rumors and bad press - being blacklisted - loss of business relationships - loss of financial services.
    Economic order: destabilization of prices - exchange uncertainty - inflation - bankruptcy.
    Social order: corruption - social decomposition - loss of values - violence.
    Legal: face legal actions - expropriation of assets.
  • Warning signs
    Identify unusual customer behaviors and atypical situations.
    Calling attention to a customer, event or situation that requires further analysis.
    Recognize an operation that corresponds to a type of money laundering and / or financing of terrorism.
  • Remember:
    Money launderers and terrorism financiers don't care: Losing money because it is a cost that is part of the business
    Involve anyone to stay clean, a success factor in your business.

We must always know who we associate with

When you are going to link a supplier, make a contract, an agreement or any contractual relationship keep in mind:

  1. Verify background, legal representative and business name.
  2. Use the vendor linking format.
  3. It includes the SARLAFT prevention clause if a contract or agreement is to be made.
  4. Send the SARLAFT policy when you make a contractual relationship.
  5. Confirm that the counterpart delivers the documents requested, otherwise the relationship is suspended.
  6. Notify compliance officer if public or politically exposed PEP is linked.
  7. Inform the compliance officer if the company or person is on the background checklists.
  8. Pay attention to behaviors that are not related to economic activity.
  9. Updated provider information changes during the term of the contract.

Did you know that there is a new type of money laundering?

It consists of the loan of savings accounts to save money in exchange for a monthly payment, ignoring the origin of the funds. The money has been found to come from extortion and kidnapping.

This type of money laundering can lead to a sentence of between 9 and 12 years in prison for the crimes of conspiracy to commit a crime and theft through computerized means.

Therefore, we invite the entire University community to report any situation that generates an alert signal or any suspicion.