SARLAFT / SIPLAFT — Colombia
In compliance with Colombian Law 526 of 1999, UIAF External Circular 027 of 2010, FATF Recommendations, and other applicable regulations, Amazon Carbon S.A.S. has implemented a Money Laundering and Terrorist Financing Risk Management System (SARLAFT/SIPLAFT).
AML/SIPLAFT Policy — Prevention of Money Laundering
1. Applicable Legal Framework
This policy is based on: Law 526 of 1999 (UIAF — Financial Information and Analysis Unit); Law 1121 of 2006 and Decree 1674 of 2021 (measures against terrorist financing); FATF Recommendations applicable to virtual assets (Recommendation 15); FATF Guidance on Virtual Assets 2019/2021; Applicable regulations in jurisdictions where Amazon Carbon S.A.S. operates or serves clients.
2. Know Your Customer Policy
Amazon Carbon S.A.S. applies a Know Your Customer (KYC) policy proportional to its operational risk: (a) For low-volume transactions (under USD $1,000): basic name and email registration; (b) For medium-volume transactions (USD $1,000 - $10,000): identity and organization validation; (c) For high-volume transactions (over USD $10,000): enhanced due diligence process, including documentary verification of identity and source of funds.
3. Red Flags
Amazon Carbon S.A.S. monitors and reports to UIAF when it detects red flags such as: (a) Transactions inconsistent with the user's profile or with no apparent economic justification; (b) Users attempting to fragment operations to avoid reporting thresholds; (c) Use of multiple wallets for the same operation without justification; (d) User presence on international control lists (OFAC, UN, EU); (e) Refusal to provide required identification information.
4. Suspicious Transaction Reporting
Amazon Carbon S.A.S. reports to the UIAF (Colombia's Financial Information and Analysis Unit) any transaction that raises suspicion of money laundering or terrorist financing, regardless of the amount. Reports are made confidentially, without notifying the reported user, as required by law.
5. AML Compliance Officer
The designated AML Compliance Officer is the Legal Representative of Amazon Carbon S.A.S., Jonathan Núñez Guevara. For compliance inquiries or to report irregularities, please contact us at: compliance@amazoncarbon.com or info@amazoncarbon.com. Amazon Carbon S.A.S. maintains internal training and periodic review procedures for its AML policy.
