This is an informative translation. The governing text is the Spanish version.
Version: 1.1. Effective date: May 8, 2025. Last updated: October 5, 2026.
Confía Digital's Commitment to the Prevention of ML/TF/PF (in Spanish, LAFT/PADM)
At Confía Digital S.A.S., we are committed to the prevention of unlawful activities, such as Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction (ML/TF/PF; in Spanish, LA/FT/PADM).
Although we are not currently bound by a specific legal regime in this matter, we apply this policy voluntarily as part of our good corporate practices, business ethics and alignment with international standards such as those of the GAFI (FATF). This preventive approach strengthens the integrity of our operations and business relationships.
As part of our commitment to ethics and compliance, we have implemented rigorous policies that guide our operations and business relationships. The main principles governing our prevention policy are set out below:
- Actively collaborate in the fight against Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction, in accordance with current national and international legislation and the standards established by the GAFI (FATF).
- Apply a Risk-Based Approach (RBA; in Spanish, EBR) to identify, assess, manage and mitigate ML/TF/PF risks in its operations, internal processes and business relationships.
- Allocate and make available the technical, human and financial resources necessary to implement effective controls in the prevention of ML/TF risk.
- Monitor and abide by the resolutions issued by the United Nations Security Council, especially those related to targeted financial sanctions.
- Refrain from establishing contractual, commercial or institutional relationships with persons or entities included on restrictive, binding or international sanctions lists, such as those of the ONU (UN), OFAC or the UE (EU).
- Apply strict due diligence mechanisms (CDD; in Spanish, DDC) for the selection, onboarding, monitoring and termination of clients, suppliers, strategic partners, employees and third parties, in accordance with current internal procedures.
- Carry out continuous monitoring of business relationships through transactional monitoring processes, periodic review of counterparties and analysis of alerts.
- Include, within mandatory training programs, specific content on ML/TF prevention, promoting a culture of ethics, integrity and compliance.
- Establish secure and confidential internal channels for receiving reports or alerts related to possible ML/TF risk signals.
- Assign clear functions and responsibilities in the implementation, oversight and continuous improvement of the ML/TF Prevention System, including the role of the Compliance Officer (if applicable).
- Ensure that all employees, contractors, suppliers, clients and other stakeholders comply with this policy and with the legal provisions in force regarding ML/TF prevention.
- Periodically review and update this policy, adapting it to regulatory changes, new threats, international recommendations or adjustments to the organization's risk map.
Applicability and Confidential Reporting Channels
This policy applies to all processes, areas, employees, contractors, suppliers, strategic partners, clients and other stakeholders that maintain a commercial, contractual or institutional relationship with Confía Digital S.A.S., without exception, within the framework of its operations.
To strengthen the commitment to transparency and the prevention of ML/TF/PF, Confía Digital makes available the following secure and confidential channels for reporting warning signs, irregular events or possible associated cases:
- Email: legal@confiadigital.com.co
- Ethics Line Form: available on our website https://confiadigital.com.co
These mechanisms may be used anonymously or with identification and will be handled with absolute confidentiality by the Compliance Officer. Responses will be issued within a maximum period of five (5) business days, except in cases that require further analysis.
Misuse of these channels may also result in sanctions.