KYC | LOMIOPRIMERO

Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

Money laundering involves concealing the illegal source of funds by converting them into cash or apparently legitimate investments.

General provisions

Our anti-money laundering policy (hereinafter, the "AML Policy") is based on the following essential principles:

Not establishing business relationships with criminals and/or terrorists.
Not processing transactions originating from criminal and/or terrorist activities.
Not facilitating any transaction related to criminal and/or terrorist activities.

Verification procedures

The Store has its own procedures to ensure compliance with the standards set forth in the AML Policy and the Due Diligence (KYC – Know Your Customer) policy.

Store customers must complete a verification process (requiring the submission of a government-issued identification document, such as a passport or national ID card). The Store reserves the right to use customers' identification information to ensure compliance with the AML Policy. Such information is processed and stored strictly in accordance with the Store's Privacy Policy. The Store verifies the authenticity of the documents and information provided by customers and reserves the right to request additional information from customers identified as posing a potential risk.

If a customer's identification information changes or if their activity appears suspicious, the Store reserves the right to request updated documents from the customer, even if such documents were previously authenticated.

AML-KYC Policy Compliance Officer

The Store has an Anti-Money Laundering (AML) Compliance Officer responsible for ensuring adherence to the AML Policy and the execution of KYC procedures, such as:

Collecting customer identity information.
Updating and maintaining internal policies and procedures to generate, review, submit, and store all required reports in accordance with applicable laws and regulations.
Monitoring and tracking transactions to analyze any significant deviations from customers' normal activity patterns.
Establishing a record management system to store and retrieve documents, files, forms, and records.
Regularly analyzing risk assessments.

Transaction monitoring

Monitoring the Client's transactions and analyzing the data obtained serves as a tool to assess their risk level and detect suspicious transactions. In the event of any suspicion of money laundering, the Store will monitor all transactions of the relevant Client and reserves the right to:

Request that the Client provide additional information and documents.
Suspend or close the Client's Account.

Record retention and information reporting

As part of our AML program, we maintain relevant documentation regarding client identity and electronic fund transfers. The record retention period is updated in accordance with applicable regulations.

The currently established retention period for such records is ten years. Records must be maintained in a manner that makes them accessible to all employees requiring access to the client in question.

We will respond to written, substantiated, and legally binding requests issued by official authorities within the legal framework regarding accounts and transactions; we will search our records to determine whether we hold—or have held—information on, or have conducted transactions with, any individual, entity, or organization clearly defined and named in the request.

If no information is found, we will provide the appropriate response, retain documentation regarding the search performed, and log the name of the individual or company listed in the request within our risk-based procedures.

Customer identification and source of funds

We store certain identifying information for each of our clients before they carry out any transaction:

For individuals

Name and any other name used.
National ID, passport number, national identity card, residence card, driver's license number, or other identification number.
Residency information (address and/or utility company customer number, details, etc.).
Biometric verification.
Other additional client information if necessary to meet the requirements of the risk-based approach.

For companies or legal entities

Company name.
Information regarding the principal place of business.
Contact information.
Incorporation details (registration number, date of incorporation, etc.).
Payment details and/or banking information.
Relevant residency information (address details or utility customer data).
Details of persons authorized to act on behalf of the company and authorization details.
Biometric verification of the entity's administrator(s).
Other additional client information if necessary to meet the requirements of our risk-based approach.

We will apply relevant risk-based measures to verify each client's identity and maintain the necessary records.

Risk assessment

In accordance with international requirements, La Tienda applies a risk-based approach to combat criminal activity. Consequently, measures designed to prevent money laundering and terrorist financing are proportionate to the identified risks, allowing resources to be allocated effectively. Resources are deployed based on priority, the higher the risk, the greater the attention.

KYC & AML