Recent COAF decisions in two Administrative Sanctioning Processes (“Decisions”), published on June 25, 2024, imposed million-dollar fines on the Brazilian subsidiary of an international conglomerate in the luxury market. The penalty was motivated by non-compliance standards to prevent money laundering and the financing of terrorism and the proliferation of weapons of mass destruction (“AML/CTF”) related to markets for trading luxury or high-value goods and trade in jewelry, stones and precious metals.
The decisions were based on the following infractions, among others:
- Lack of identification and updating of customer records.
- Lack of registration of transactions.
- Failure to report operations involving cash transactions above the established limit.
- Failure to report suspicious ML/TF operations.
- Deficient implementation of AML/CTF policies.
The case serves as a warning about the importance of effective implementation of AML/CTF policies, especially by companies that deal with high-value goods, such as the luxury sector. Failure to comply with regulatory standards can result in serious financial and reputational consequences.
Our Compliance, Investigation, and White-Collar practice group is available to assist you and clarify any doubts regarding COAF Resolutions.
Isabel Franco | ifranco@azevedosette.com.br
Viviane Próspero João | vprospero@azevedosette.com.br