Analyzes standards and regulations to prevent the risks of money laundering, terrorist financing and criminal corruption risks, from the risk manager’s perspective.
Objective and functions
Analyze standards, current and pending regulations, guides, recommendations and manuals from internationally recognized organizations that serve as a reference to identify, monitor and prevent the risks of money laundering and terrorist financing (AML/CFT) and anti-corruption criminal risks, and manage potential events from the risk manager’s perspective.
- 01Achieve the publication of official and reliable statistics on AML/CFT risk events, as an input for managing the sector.
- 02Develop methodologies, manuals or guides that support the promotion of new regulations and more efficient management by compliance officers and risk managers.
- 03Hold discussions with figures from the public and private sectors.
What money laundering and terrorist financing risk is
Money laundering
The process by which the proceeds of criminal activity are processed to disguise their illegal origin and make them appear legitimate.
Terrorist financing
The collection or provision of funds, from lawful or unlawful sources, to finance terrorist acts or organizations. Unlike laundering, what is sought to be hidden is usually the destination of the funds rather than their origin.
AML/CFT risk
For the FATF, risk is a function of three factors: threat, vulnerability and consequence. Its risk-based approach requires each institution to identify, assess and understand the risks it is exposed to and to apply measures proportionate to them.
SourcesGAFI/FATF, Guidance National Money Laundering and Terrorist Financing Risk Assessment (opens in a new tab)GAFI/FATF, Risk-Based Approach for the Banking Sector (opens in a new tab)
How it is measured and quantified
Inherent risk is assessed by factor and compared against the quality of controls to obtain residual risk.
Inherent risk matrix
Rates the institution’s risk factors: customers, products and services, distribution channels and geographic areas. Each factor receives a rating and a weight.
Residual risk
Residual risk = inherent risk against the effectiveness of controlsIt results from comparing inherent risk with the strength of controls. It guides where to reinforce resources.
Customer segmentation
Profiles each customer (low, medium, high) according to their activity, source of funds, country and whether they are a politically exposed person.
Program performance indicators
Alerts generated and reviewed, proportion of false positives, review time, suspicious transaction reports sent to the authority, and training coverage.
National risk assessment
Each country assesses its own threats and vulnerabilities. Those results feed each institution’s assessment.
How it is managed
Coordination
Those who lead the committee. The coordination and co-coordination roles rotate once a year.
Coordination
Claudia Alvarez Troncoso
President, Etikamente

Co-coordination
Jerussa Valverde
CEVALDOM
Regulations and recommended readings
Standards and documents that the committee uses as the basis of its work.
- Law 155-17, against Money Laundering and Terrorist Financing
- Current regulations from the superintendencies and local bodies
- GAFILAT, Financial Action Task Force of Latin America (opens in a new tab)
- FATF, Frequently Asked Questions (opens in a new tab)
- GAFI/FATF, Guidance National Money Laundering and Terrorist Financing Risk Assessment (opens in a new tab)
- GAFI/FATF, Risk-Based Approach for the Banking Sector (opens in a new tab)
- FIBA and ACAMS
- UNE 19601, Criminal compliance
- UNE 37001, Anti-bribery
Sign up for this committee
Members who wish to take part notify the Club’s Executive Committee, and this form is the channel. Regular members and representatives of sponsor members may take part. Not a member yet? Find out how to become one.
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