ANNUAL REPORT 2010

The control and oversight mechanisms in place, especially at Mercantil’s subsidiaries Mercantil
Banco Universal, Mercantil Seguros, Mercantil Merinvest, Mercantil Sociedad Administradora
de Entidades de Inversión Colectiva, Mercantil Bank Curaçao, Mercantil Bank (Panama),
Mercantil Bank (Schweiz) AG and Mercantil Commercebank, are adequate for the timely
detection of operations which - due to the nature of their activities - are presumed to involve
ML/TF, and for reporting such operations to the appropriate authorities.
The “Know your Customer” policy is crucial to the timely detection of operations presumed to
involve ML/TF. Anti-money laundering and combating the financing of terrorism (AML/CFT)
compliance processes are regularly reviewed by the supervisory authorities of the different
jurisdictions in which Mercantil Servicios Financieros operates, as well as by the External and
Internal Auditors.
Pursuant to the provisions of current legislation the Institution has a “Comprehensive AML/CFT
System” comprised by an AML/CFT Compliance Officer, a multidisciplinary committee, an
AML/CFT Unit and Compliance staff responsible for areas susceptible to ML/TF risks. There are
also Operational, Follow-up, Evaluation and Control Plans, a Code of Ethics, a Manual of AML/CFT
Risk Management Policies and Procedures, and Training Programs.
Its action during the year focused mainly on strengthening coverage and minimizing ML/TF risks
by approving and setting policies, updating the Manual of AML/CFT Risk Management Policies
and Procedures, appointing compliance staff in areas susceptible to risk, implementing new
AML/CFT administrative and operating policies, training staff with special emphasis on the
people for managing processes that are highly sensitive to risk, and the acquisition of state-ofthe-art
technology. All of this has provided the Institution with an efficient and effective structure
and highly professional risk management process, within a climate of ongoing improvements.
Mercantil Servicios Financieros developed an extensive program of training courses and
workshops in which 9,000 employees participated.
Mercantil Servicios Financieros liaises constantly with the regulatory bodies wherever it is
present and with which it maintains fluid and effective communications.
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