Compliance Officer Program in Peru — APLA Academy

This specialized program will help Compliance Officers and anyone interested to gain knowledge of risk management to prevent money laundering, terrorist financing and other crimes, and to analyze the Money Laundering Prevention Regulations and the risk-based (RBA) management models issued by the oversight body — SBS – UIF Peru.

Our commitment

• Provide Compliance Officers with the knowledge to carry out their duties in managing ML/TF/PF risks and preventing companies from being used to launder money.
• Help Compliance Officers meet the annual training requirement set by the SBS.
• Provide knowledge to anyone interested in implementing management systems that protect their companies from money laundering and terrorist financing.

Duration and certification

40 academic hours, certified by Líderes APLA with a digital certificate. Classes are live; if you cannot attend, they are recorded in the virtual classroom, where you will have access to the recordings, up-to-date regulations, presentations and all downloadable materials.

Digital materials included

• SPLAFT Matrix template.
• AML/CTF/PF Prevention Manual template.
• Annual Work Plan template.
• Annual Compliance Report (IAC) template.
• ROS (STR) report template.
• Structure of the Transaction Register (RO).
• Among others.

Syllabus

1. International and local regulatory framework — FATF standards and the Peruvian regulatory framework, what a Financial Intelligence Unit is, the crimes of money laundering, terrorist financing and financing of the proliferation of weapons of mass destruction, obligated entities under the General System and the Limited System, obligated entities in the non-financial sector, obligated entities without an oversight body, penalties for non-compliance.
2. The role of the Compliance Officer (CO) — who can be a CO, appointment and obtaining the CO code, legal, technical and ethical responsibilities of the CO, independence, authority and relationship with senior management and the regulator, essential soft skills.
3. Preparing the AML/CTF Prevention Manual and Code of Conduct — preventive policies and procedures, how to implement an appropriate policy, information gathering, delegation of responsibilities, structure of the AML/CTF Manual and the Code of Conduct.
4. The CO Semi-Annual Report (ISOC) and the Compliance Officer Annual Report (IAOC) — differences between the ISOC and the IAOC, monitoring compliance with policies and procedures, supervisor observations, preparing the information to be entered in the PLAFT portal, penalties for non-compliance.
5. Transaction Register (RO) and Unusual Transaction Register (ROI) — FATF Recommendation 11 (record keeping), recording single and multiple transactions, thresholds and transactions to report in the RO, submission channels and deadlines for the RO, structure of the RO and the ROI.
6. Due diligence — identification, verification and monitoring procedure, customer due diligence regimes, application to suppliers, employees/directors, ultimate beneficial owner, correspondent banking and market, Politically Exposed Persons (PEP), control lists and information sources.
7. Corruption offenses and their relationship with the ISO 37001 Anti-Bribery Management System — risk assessment and associated risks, main corruption offenses, corruption in Peru (cases), ISO 37001 Anti-Bribery Management Systems.
8. Designing the AML/CTF risk prevention system — ML/TF/PF risk and FATF Recommendation 1, risks associated with ML/TF/PF, the risk management process, how the ML/TF/PF Risk Matrix works, workshop on designing the Institutional Risk Matrix.
9. Designing the customer risk matrix — customer, geographic area and product/service risk factors, defining variables for each risk factor, risk rating, information sources, calculating the customer risk profile.
10. The importance of the Suspicious Transaction Report (ROS/STR) — red flags and their types, what an STR is, its types and principles, how to identify suspicious transactions, when to report suspicious transactions to the UIF Peru, the importance of the STR in preventing financial crimes, risks and penalties for inadequate reporting.

Faculty

Program taught by Shella Mendieta and Orlando Martínez, Líderes APLA faculty — see their full profiles on the Faculty page.

Program benefits

• Training on current regulations for each economic sector.
• Application of the regulations through practical workshops.
• Practical tools to implement the AML/CTF/PF Prevention system.
• Q&A with national and international faculty.
• Exclusive access to the Líderes APLA student group.

Why take the Compliance Officer Program in Peru?

Peru, like other countries in the region, is a member of the Financial Action Task Force of Latin America (GAFILAT) and must therefore adopt the recommendations of the Financial Action Task Force (FATF). Recommendation 1 states that financial institutions and designated non-financial businesses and professions (DNFBPs) must identify, assess and take effective action to mitigate their money laundering and terrorist financing risks.

According to the 2021 National Risk Assessment published by the Superintendency of Banking, Insurance and Private Pension Funds (SBS), the main vulnerabilities affecting the fight against money laundering in Peru are: the lack of social awareness of the consequences of money laundering, corruption among justice operators, and conditions that facilitate public corruption, including tolerance of it.

In this regard, a risk-based approach makes it possible to identify the greatest risks, so that the obligated entity can apply enhanced measures to high risks and optimize resources at the levels identified as low. It also seeks to raise social awareness so that obligated entities conscientiously fulfill their money laundering prevention responsibilities.

By the end of the program

You will be able to:

• Work as a Compliance Officer, carrying out duties aimed at managing ML/TF/PF risks and preventing companies from being used to launder money.
• Implement management systems that protect companies from money laundering and terrorist financing.
• Develop and implement matrices to determine the customer risk profile.
• Identify red flags related to the most common money laundering typologies.

Payment methods

Bank transfer, deposit, credit or debit card. We accept all cards.

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