Circular 12-2018: Anti-Money Laundering, Counter-Terrorism Financing, and Counter-Proliferation Financing Self-Assessment Questionnaire

[Logo: SMV Superintendence of the Securities Market Republic of Panama]

Panama, December 18, 2018
CIRCULAR SMV- 12 -2018

To:
Chief Executives and
Compliance Officers
City

Subject: "Self-Assessment Questionnaire for the Prevention of Money Laundering, Terrorism Financing, and Financing of the Proliferation of Weapons of Mass Destruction."

Respected Sirs:

By means of this communication, we inform the Chief Executives and Compliance Officers of the obligated entities (securities houses, investment advisors, investment managers, self-regulatory organizations, pension fund administrators, and severance fund administrators, investment companies, self-administered investment companies, Provider of Administrative Services for the Securities Market) that, in compliance with Article 20 of Law 23 of April 27, 2015, the Directorate for the Prevention and Control of Illicit Operations has initiated a process to strengthen its risk-based supervision methodology. Consequently, you must complete the "Self-Assessment Questionnaire for the Prevention of Money Laundering, Terrorism Financing, and Financing of the Proliferation of Weapons of Mass Destruction," which must be submitted no later than January 31, 2019, with information corresponding to the period from January 1 to September 30, 2018.

This questionnaire includes:

1. The document titled "Self-Assessment Questionnaire," which corresponds to an Excel file containing a series of questions focused on general information, guidelines, policies, and procedures regarding AML/CFT/CPF, due diligence, reporting of suspicious transactions, and corporate governance.

According to the obligated entity, you must complete the following annex:

Page 2 of 2 Circular No. SMV-12-2018

a. Securities Houses correspond to SMV R.03 b. Investment Advisors correspond to SMV R.01
c. Investment Managers correspond to SMV R.01
d. Self-Regulatory Organizations correspond to SMV R.01 e. Severance Fund Administrators and Pension Fund Administrators correspond to SMV R.01 f. Investment Companies correspond to SMV R.01 g. Self-administered Investment Companies correspond to SMV R.01 h. Provider of Administrative Services for the Securities Market correspond to SMV R.01

2. "SMV R.01 Operational Information" (Annex 2), which is composed of a series of questions and financial data of the entity.

On December 28, 2018, we will send you via email a link to access the aforementioned annexes. Once the questionnaires are completed, they can be submitted to the SMV through a Dropbox, the link for which will also be sent to you via the same channel on January 11, 2019.

If an extension is required, you must request a meeting by sending an email to the following address: csmv@supervalores.gob.pa, indicating "Self-Assessment Questionnaire" in the subject line. A slot will be assigned on a first-come, first-served basis on the dates of January 7 to 11, 2019.

Sincerely,

[Signature]
Marelissa Quintero de Stanziola
Superintendent

50th Street, P.H. Global Plaza Building, 8th Floor. Tel.: (507) 501-1700 Fax: (507) 501-1709 www.supervalores.gob.pa P.O. Box 0832-2281 WTC Panama, Rep. of Panama.