On April 18, 2023, the National Anti-Money Laundering and Counter-Terrorism Financing Secretariat (SENACLAFT) held a webinar for nonfinancial sector reporting entities, in which noted the following as the chief weaknesses detected in inspection processes:
• Failure to do risk assessments in writing, to determine the due diligence procedure to be applied to customers.
• Failure to maintain physical or digital documentary support of due diligence procedures performed on customers.
• Failure to identify the ultimate beneficiary of the transaction and failure to verify its identity.
• Regarding searches: (i) failure to maintain documentary evidence of searches performed; (ii) searches printed without dates; (iii) no analysis performed or matches found are disregarded.
• Failure to document the volume of income or origin of funds.
