Lima, 17 August 2016

S.B.S. Resolution No. 4463-2016

The Superintendent of Banking, Insurance and Private Administrators of Pension Funds

WHEREAS:

That, Law No. 27693 and its amending norms establish the list of obligated subjects required to report, who are responsible for implementing a system for the prevention of money laundering and terrorist financing that involves, among other aspects, reporting suspicious transactions and designating a compliance officer duly accredited before the Financial Intelligence Unit of Peru (UIF-Peru), responsible for receiving, analyzing, processing, evaluating and transmitting information for the detection of money laundering and terrorist financing;

That, article 3 of Law No. 29038 provides that among those obligated to report are, among others, natural or legal persons engaged in the granting of loans and pawnbroking;

That, in accordance with the provisions of article 3 of Law No. 27693, as amended by the first complementary amending provision of Legislative Decree No. 1106, Legislative Decree on the effective fight against money laundering and other crimes related to illegal mining and organized crime, it is the function and power of the Superintendency of Banking, Insurance and Private Administrators of Pension Funds, through the UIF-Peru, to regulate the guidelines, requirements, sanctions and other aspects related to the prevention systems of the obligated reporting subjects and the reports of suspicious transactions and the transaction registry format, among others, in accordance with the scope of the provisions of the aforementioned law and its regulations;

That, in this context, it is necessary to approve the norm for the prevention of money laundering and terrorist financing applicable to natural or legal persons engaged in the granting of loans and pawnbroking, considering international standards on the matter;

That, in order to gather the opinions of the general public regarding the regulatory proposals, the pre-publication of the draft resolution was ordered on the Superintendency's electronic portal, under the provisions of Supreme Decree No. 001-2009-JUS and its amending norms;

With the approval of the UIF-Peru and the Deputy Superintendency of Legal Advisory;

In use of the powers conferred by Law No. 29038 and the General Law of the Financial System and the Insurance System and Organic Law of the Superintendency of Banking and

SUPERINTENDENCY OF BANKING, INSURANCE AND AFP Republic of Peru

Insurance, Law No. 26702 and its amending norms, in accordance with Law No. 27693 and its amending norms;

RESOLVES:

Article 1.- To approve the Norm for risk management and prevention of money laundering and terrorist financing applicable to obligated subjects engaged in the granting of loans and pawnbroking, with the following text:

NORM FOR RISK MANAGEMENT AND PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING APPLICABLE TO OBLIGATED SUBJECTS ENGAGED IN THE GRANTING OF LOANS AND PAWNBROKING

CHAPTER I GENERAL PROVISIONS

Article 1.- Scope

This norm is applicable to obligated subjects engaged in the granting of loans and pawnbroking, in accordance with the definition established in article 2, which are under the supervision of the Financial Intelligence Unit of Peru (UIF-Peru), in matters of prevention of money laundering and terrorist financing.

Article 2.- Definitions and abbreviations

For the application of this norm, the obligated subject must consider the following definitions and abbreviations:

a) Code: code of conduct for the prevention of ML/TF.

b) Days: calendar days.

c) Identity document: national identity document in the case of Peruvians, and the foreigner's card, passport or legally established document for the identification of foreigners, as applicable.

d) Terrorist financing: crime typified in article 4-A of Legislative Decree No. 25475 and its amending norms.

e) Economic group: set of two or more legal persons, national or foreign, in which one of them exercises control over the others, or when control over the legal persons corresponds to one or several natural persons acting as a decision unit.

f) ML/TF: money laundering and terrorist financing.

g) Money laundering: crime typified in Legislative Decree No. 1106, Legislative Decree on the Effective Fight against Money Laundering and other Crimes Related to Illegal Mining and Organized Crime, and its amending norms.

h) Law: Law that creates the Financial Intelligence Unit of Peru, UIF-Peru, Law No. 27693 and its amending and complementary norms.

i) Manual: manual for the prevention and management of ML/TF risks.

j) Norm: Norm for risk management and prevention of money laundering and terrorist financing applicable to obligated subjects engaged in the granting of loans and pawnbroking.

k) Unusual transactions: transactions carried out or attempted to be carried out, whose amount, characteristics and frequency are not related to the client's economic activity, fall outside the normal parameters in force in the market or do not have an evident legal basis.

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l) Suspicious transactions: transactions carried out or attempted to be carried out, whose amount or characteristics are not related to the client's economic activity, or which do not have an economic basis; or which, due to their number, amounts traded or their particular characteristics, may reasonably lead to suspicion that the obligated subject is being used to transfer, manage, take advantage of or invest resources originating from criminal activities or destined for their financing.

m) Supervisory body: the UIF-Perú.

n) Politically exposed persons (PEP): natural persons, national or foreign, who perform or who in the last five (5) years have performed prominent public functions or prominent functions in an international organization, whether in the national or foreign territory, and whose financial circumstances may be the subject of public interest. Likewise, the direct collaborator of the highest authority of the institution is considered a PEP.

o) Loan and pledge: mutual loan of money in which a natural or legal person (client) receives from the obligated subject a sum of money and, in order to secure the payment of said obligation, grants as collateral precious stones, precious metals and/or jewelry of precious metals and/or precious stones.

p) Regulation of the Law: Regulation of the Law that creates the UIF-Perú, approved by Supreme Decree No. 018-2006-JUS.

q) ML/TF risks: possibility that the obligated subject is used for ML/TF purposes.

r) ROSEL: Online Suspicious Operations Report System. Technological tool developed by the SBS to allow that, in accordance with current regulations, obligated subjects submit to the UIF-Perú the suspicious operations report (ROS) by electronic means, under standards that ensure that the information is transmitted with an adequate level of security.

s) SBS: Superintendency of Banking, Insurance and Private Administrators of Pension Funds.

t) Obligated subject: natural person with a business or legal person dedicated to the granting of loans and pledge that has an establishment and operating license or activity authorization issued by the corresponding Municipality and that is duly registered in the "Registry of Companies and Persons that carry out Financial or Currency Exchange Operations".

u) Worker: natural person who maintains an employment or contractual relationship with the obligated subject; includes the general manager, managers, administrators or those who perform similar positions.

v) UIF-Perú: Financial Intelligence Unit of Peru, specialized unit of the SBS.

Article 3.- ML/TF prevention system

3.1 Obligated subjects must implement an ML/TF prevention system, through the management of the ML/TF risks to which they are exposed by dedicating themselves to the granting of loans and pledge. The prevention system is made up of policies and procedures established by the obligated subjects, in accordance with the Law, the Regulation, this norm and other provisions on the matter, whose purpose is to prevent and avoid that they are used for illicit purposes linked to ML/TF; as well as by the measures that the obligated subject establishes to guarantee the indefinite duty of reserve of the information related to the ML/TF prevention system.

3.2 The ML/TF prevention system must be applied by the obligated subject (if a natural person) as well as by the entire administrative and operational organization of the obligated subject, including the compliance officer, its workers and directors if it has said governing body; in accordance with the functions that correspond to them, applying the Code and the Manual approved for said purpose, in accordance with the provisions of this norm and other provisions on the matter.

3.3 The application of the ML/TF prevention system must focus on the detection of unusual operations and the prevention, detection and reporting of suspicious operations that are presumably linked to ML/TF, in order to communicate them to the UIF-Perú, within the established legal term.

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CHAPTER II OF THOSE RESPONSIBLE FOR THE ML/TF PREVENTION SYSTEM

Article 4.- Supervision of the obligated subject to inform

4.1 It corresponds to the UIF-Perú to supervise compliance with the Law, the Regulation, this norm and other provisions on ML/TF prevention and detection, using not only its own supervision mechanisms, but it may also have the support of the compliance officer, of the internal audit provided that the social statute or the policy of the obligated subject so provides and of the external audit firms, if applicable.

4.2 The ML/TF prevention system must be evaluated by the internal audit, if the obligated subject has one, or by a manager or worker different from the compliance officer of the obligated subject.

4.3 The ML/TF prevention system must be evaluated by an external audit firm, if the obligated subject has a legal obligation to have one, different from the one that issues the annual report of financial statements, or by a team completely different from this one.

4.4 The UIF-Perú may carry out supervision visits on ML/TF prevention matters, in accordance with the planning it determines. The SBS exercises the sanctioning power for non-compliance with the obligations derived from this norm and in accordance with the corresponding Regulation of Infractions and Sanctions.

Article 5.- Responsibilities of the obligated subject

The obligated subject is responsible, among other obligations contemplated in the Law, for implementing the ML/TF prevention system and for fostering an internal environment that facilitates its development. To do so, it must:

a) Establish and periodically review the functioning of the ML/TF prevention system.

b) Approve the policies and procedures for the management of ML/TF risks.

c) Approve the manual and the code of conduct.

d) Designate a compliance officer with the characteristics, responsibilities and attributions that current regulations establish.

e) Provide the resources and infrastructure that allow the adequate fulfillment of the functions of the compliance officer.

f) Establish measures to maintain the confidentiality of the compliance officer, so that their identity is not known by persons outside the obligated subject.

Article 6.- Compliance officer

6.1 The compliance officer is the natural person designated by the obligated subject in accordance with this regulation, responsible for overseeing the proper implementation and operation of the LA/FT prevention system, on a full-time basis. They are the contact person between the obligated subject and the UIF-Peru and an agent on whom they rely in carrying out the control and supervision of the LA/FT prevention system.

6.2 The person designated as compliance officer may only serve as such for one obligated subject at a time, unless it is a corporate compliance officer. An obligated subject that is a natural person may be their own compliance officer.

6.3 In cases where, due to the size of its organization, complexity or volume of operations, it is not justified for the obligated subject to have a full-time compliance officer, the obligated subject may request from the UIF-Peru the authorization to have a non-full-time compliance officer, who must comply with articles 7 and 8 of this regulation. The request must be duly supported and

contain the following minimum information:

a) Composition of the compliance office;

b) Description of the distribution of the workload of the non-full-time compliance officer;

c) Description and support of the reasons that justify their request for the designation of a non-full-time compliance officer;

d) Information describing the level of exposure to LA/FT risks faced by the obligated subject; and,

e) Description of other characteristics of the obligated subject.

6.4 Notwithstanding this, if the UIF-Peru determines that the management by the non-full-time compliance officer does not allow for adequate management of the LA/FT risks faced by the obligated subject, it may revoke the authorization to have a non-full-time compliance officer.

Article 7.- Requirements of the compliance officer

7.1 The compliance officer must meet the following requirements:

a) Have experience in the activities inherent to the obligated subject, or experience as a compliance officer or as a worker in the area in charge of a compliance officer.

b) Not have been convicted of the commission of an intentional crime.

c) Not have been removed from public office or have been terminated from it for serious misconduct.

d) Not have debts overdue for more than one hundred twenty (120) days in the financial system or in judicial collection, nor protests of documents in the last five (5) years, not clarified to the satisfaction of the SBS.

e) Not have been declared bankrupt.

f) Not be nor have been the internal auditor of the obligated subject, if applicable, during the six (6) months prior to their designation.

g) Not be subject to any of the impediments indicated in article 365 of Law No. 26702, excepting subsection 2 of the aforementioned article.

h) Have a direct employment or contractual relationship with the obligated subject and enjoy autonomy and independence in the exercise of their responsibilities and functions.

i) Others established by the SBS.

The aforementioned requirements may be accredited with a sworn statement.

7.2 The compliance officer who ceases to meet any of the aforementioned requirements may not continue acting as such and must communicate it in writing to the obligated subject –as a sworn statement– within a maximum period of five (5) business days of the occurrence of the fact. When the obligated subject becomes aware of the non-compliance with requirements, even if the compliance officer has not communicated it, they must remove them from the position and inform this action, supporting the reasons that justify the measure to the UIF-Peru within a maximum period of five (5) business days.

In this case, the obligated subject must designate a new compliance officer who meets the requirements established in the previous paragraph, considering the procedure indicated in the following article.

7.3 Taking into account, among other aspects, the LA/FT risks faced by the obligated subject, the size of the organization, complexity and volume of its operations, the UIF-Peru may exempt obligated subjects from compliance with some of the requirements indicated in this regulation, unless they are specifically established in the Law. This exception may be revoked by the UIF-Peru, by means of a letter communicated to the obligated subject, when any of these conditions changes or does not contribute to

the prevention and management of LA/FT risks.

Article 8.- Designation, removal and vacancy of the position of compliance officer

8.1 The designation of the compliance officer must be made by:

a) The obligated subject, when it is a natural person.

b) The board of directors or equivalent body when it is a legal person; or general manager, manager, sole manager or administrator, if the legal person, in accordance with its bylaws, is not required to have a board of directors.

8.2 The designation of the compliance officer must be communicated by the obligated subject to the UIF-Peru, confidentially and reservedly, within a period no greater than fifteen (15) business days from the date of designation, indicating at least the following information of the compliance officer:

a) Names and surnames.

b) Type and number of identity document.

c) Nationality.

d) Address.

e) Address of the office where they work.

f) Contact details (telephones and email, if applicable).

g) Indicate whether the position will be performed on a full-time basis or not.

h) Date of entry and position held.

Likewise, the obligated subject must attach the following information:

a) Sworn statement referring to compliance with the requirements indicated in the previous article or the documentation that supports compliance with them; and

b) Sworn statement indicating the person or body that made the appointment of the compliance officer, in accordance with numeral 8.1. The minutes of the general shareholders' meeting or of the board meeting or other document that evidences the appointment, as corresponds to the nature of the appointing party, must be available to the UIF-Peru.

Changes in the information regarding compliance officers must be communicated by the obligated subject to the UIF-Peru within a period no greater than five (5) business days from the occurrence of the change.

8.3 The obligated subject may appoint, at any time, an alternate compliance officer, to serve in said position only in the case of temporary absence or vacancy of the holder.

8.4 The vacancy of the position of compliance officer cannot last more than thirty (30) days from the date it occurs and must be communicated to the UIF-Peru within a period of five (5) business days from its occurrence. In the case of vacancy, the obligated subject must appoint a compliance officer in accordance with the provisions of this article.

8.5 The removal from the position of compliance officer must be supported by the reasons justifying such measure and must be approved by the person or body that appointed the compliance officer as indicated in numeral 8.1. The removal and its support must be communicated to the UIF-Peru within five (5) business days of the decision being adopted.

8.6 In the case of the corporate compliance officer, communications must be signed by the representatives of each of the obligated subjects that make up the economic group; and, addressed to the UIF-Peru and the other supervisory bodies.

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8.7 The requirements, conditions, obligations, functions and responsibilities of the compliance officer established in this regulation apply to alternate and corporate compliance officers.

Article 9.- Alternate compliance officer

In cases where an alternate compliance officer is required to perform the functions established in this regulation, without prejudice to complying with the provisions set forth in the previous article, the following must be considered:

a) In the case of temporary absence or vacancy, the alternate compliance officer may perform their functions until the return or appointment of the new compliance officer, as applicable.

b) In cases where the alternate compliance officer is required to perform the functions established in this regulation, the obligated subject must communicate this in writing to the UIF-Peru, within a period no less than five (5) business days prior to the absence of the compliance officer or vacancy of the position, except in duly substantiated cases of force majeure. The communication must indicate the period of temporary absence, when applicable, and request the activation of the secret codes of the alternate compliance officer.

c) The period of temporary absence of the compliance officer cannot last more than four (4) months.

Article 10.- Corporate compliance officer

10.1 The obligated subjects that make up the same economic group may appoint, with prior authorization from the respective supervisory bodies and the UIF-Peru, in accordance with the provisions of the following numerals, a single corporate compliance officer on an exclusive basis, who must comply with the requirements established in this regulation.

10.2 For the authorization of the position of corporate compliance officer, the following must be complied with:

a) The obligated subjects must submit a single authorization request to the heads of the respective supervisory bodies and to the UIF-Peru, which must be signed by the legal representative of each of the obligated subjects that make up the economic group, attaching the technical report referred to in article 11.

b) The supervisory bodies, if applicable, approve the request, with respect to the obligated subjects under their supervision. The authorizations issued by the supervisory bodies must be supported by a technical report that must contain at least the analysis of complexity and volume of operations, quality of the computer tools used by the obligated subjects that make up the economic group, the level of LA/FT risk they face, if applicable, among others they consider pertinent. Each of the pronouncements of the supervisory bodies must be sent to the UIF-Peru.

c) The UIF-Peru issues the authorization, if applicable, with respect to the entire economic group, once the corresponding supervisory bodies have issued their pronouncements.

d) The pronouncement of the UIF-Peru is communicated to the obligated subjects that submit the request for the economic group and to the respective supervisory bodies.

10.3 Additionally, in the case of authorization to have a corporate compliance officer, the obligated subjects must consider the following:

a) In the case of the appointment of a new corporate compliance officer and, provided that the economic group has not changed substantially in relation to the one it maintained at the time of the initial authorization, the obligated subjects that make up the economic group must submit a document informing of said appointment to each of the supervisory bodies and to the UIF-Peru, considering the provisions of articles 6, 7 and 8.

b) The obligated subjects that make up the same economic group authorized to have a corporate compliance officer, that require incorporating a new obligated subject into the economic group,

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must submit a single authorization request to the holders of the respective supervisory bodies and to the UIF-Peru, which must be signed by the representatives of each of the obligated subjects that make up the economic group.

10.4 The authorization to have a corporate compliance officer may be revoked by the UIF-Peru, when due to the particular characteristics of the obligated subjects that make up the economic group, the authorization to have a corporate compliance officer is not justified.

Article 11.- Authorization to have a corporate compliance officer

The technical report that the obligated subject must submit to support the feasibility of having a corporate compliance officer must contain the following information and/or documentation:

a) The list of obligated subjects that make up the economic group, including those that are not supervised by the supervisory body, indicating for each of them: RUC number, name of the legal representative, main activity, and name of the supervisory body, if applicable.

b) Report signed by the legal representative of each of the obligated subjects that make up the economic group, including those that are not supervised by the supervisory body, supporting the feasibility of having a corporate compliance officer, based on the ML/TF risks they face. This report must support that it will not harm or endanger compliance with current regulations, the proper development and application of the ML/TF prevention system of each obligated subject that is part of the economic group, whether or not supervised by the supervisory body, as well as setting out what measures will be implemented to prevent this from happening.

c) The existing relationship between the obligated subjects that make up the economic group, whether or not supervised by the supervisory body, and include the following information for each of them:

i. Financial statements for the last two (2) fiscal years.

ii. Number of workers and establishments annexed as of the month prior to submission of the request.

iii. Number of regular and occasional clients as of the month prior to submission of the request.

iv. Service and distribution channels.

v. Number of transactions carried out in the previous year, including the medium and form of collection and/or payment.

vi. System through which transactions are recorded.

vii. Others that the UIF-Peru and/or the supervisory bodies consider pertinent to request, if applicable.

d) The list of workers who will be in charge of the corporate compliance officer and those who are responsible for coordinating directly with him matters related to the ML/TF prevention system and who work in each of the obligated subjects that are part of the economic group it represents, whether or not supervised by the supervisory body.

e) A sworn statement specifying that the corporate compliance officer will be exclusively dedicated, will have managerial level in one of the legal entities forming the economic group, and will have the assistance of sufficient personnel.

Article 12.- Confidentiality of the identity of the compliance officer

12.1 The obligated subject must protect the identity of the compliance officer. For the proper confidentiality of his identity, the appointment of the compliance officer must not be registered in the registries that make up the National System of Public Registries. When the compliance officer is appointed - additionally - to a managerial, administrative or directorial position, only the part pertaining to the appointment to such positions must be registered in the registry entry of the legal entity.

12.2 The UIF-Peru assigns secret codes to both the obligated subject and the compliance officer, alternate compliance officer

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and/or corporate compliance officer, if applicable, after verifying the documentation and information submitted.

12.3 The codes assigned by the UIF-Peru serve only as identification in all communications sent to the UIF-Peru, to guarantee the confidentiality of the identity of the compliance officer and the confidentiality of the information sent to the UIF-Peru. In the case of a corporate compliance officer, the codes are assigned once the authorization from the UIF-Peru is obtained.

12.4 The obligated subject and its principal, alternate or corporate compliance officer must adopt the necessary measures to guarantee the confidentiality of the secret codes assigned to them.

Article 13.- Responsibilities and functions of the compliance officer

The responsibilities and functions of the compliance officer, among others contemplated in the Regulations of the Law, are the following:

a) Propose the strategies of the obligated subject to prevent and manage ML/TF risks.

b) Monitor the proper implementation and operation of the ML/TF prevention system, including the procedures for timely detection and reporting of suspicious transactions.

c) Implement the policies and procedures to ensure the proper management of ML/TF risks.

d) Evaluate and verify the application of the policies and procedures implemented in the ML/TF prevention system, including those related to customer and worker due diligence, identification of PEPs, recording of transactions and the timely detection and reporting of suspicious transactions, among others.

e) Propose alert signals to be incorporated into the manual.

f) Adopt the necessary actions for the training of the organization of the obligated subject and that of its workers and directors, if it has such a governing body, in matters of prevention and detection of ML/TF.

g) Verify that the LA/FT prevention system includes the review of the lists indicated in Annex No. 1 - Lists that contribute to the prevention of LA/FT.

h) Evaluate operations and, where appropriate, classify them as suspicious and report them, maintaining the duty of confidentiality referred to in article 12 of the Law, through the ROS to the UIF-Peru, on behalf of the obligated subject.

i) Keep a record of those unusual operations that, after the respective analysis, were not determined to be suspicious.

j) Prepare and submit annual reports on the status of the LA/FT prevention system and its compliance.

k) Be the interlocutor of the obligated subject before the supervisory body and the SBS, through the UIF-Peru, on matters related to its function.

l) Verify the proper preservation and safekeeping of documents related to the LA/FT prevention system.

m) Respond to requests for information or additional and/or complementary information requested by the competent authorities.

n) Report on the modifications and additions to the list of high-risk and non-cooperative countries published by the Financial Action Task Force – FATF.

o) Any others that are necessary or established by the SBS, to oversee the functioning and level of compliance of the LA/FT prevention system.

CHAPTER III
KNOWLEDGE OF THE CLIENT AND THE WORKER

Article 14.- Determination of clients

For the purposes of this regulation, client is any natural or legal person, national or foreign, who requests and receives from the obligated subject a sum of money in the context of loan and pawn operations. The executing party and the beneficiary of the operation are considered as the client.

The Law, the Regulation and this regulation are applicable to all clients of the obligated subject, regardless of their particular characteristics or the frequency with which they carry out operations.

Article 15.- Knowledge of the final beneficiary

15.1 For the LA/FT prevention system, the final beneficiary is the natural person in whose name an operation is carried out and/or who owns or exercises final effective control over a client in whose favor an operation is carried out. Obligated subjects must identify the final beneficiaries of the services they provide and take reasonable measures to verify their identity, so that they are convinced, to the extent that due diligence allows, that they know who the final beneficiary is.

15.2 In the case of legal persons, if it cannot be determined who holds final effective control, by majority participation, the person who exercises control by other means is considered; and, only when in such cases a natural person is not identified, the natural person who performs management and/or administration functions is considered.

15.3 The provisions of this article are applicable regardless of the due diligence regime to which the client is subject.

Article 16.- Stages of due diligence in client knowledge

16.1 The provisions on due diligence are applicable to all clients of the obligated subject regardless of their characteristics or the frequency with which they carry out operations.

16.2 The due diligence process in client knowledge implies that the client is identified by the obligated subject; and consists of the stages of identification, verification and monitoring:

a) Identification stage.- consists of developing and implementing procedures to obtain information that allows determining the identity of a client or final beneficiary.

b) Verification stage.- implies the application of verification procedures with respect to the information provided by the clients and, if applicable, their final beneficiary, with the aim of ensuring that they have been duly identified.

c) Monitoring stage.- its purpose is to ensure that the operations carried out by clients are compatible with the information declared by them (profile), as well as to obtain more information when there are doubts about the veracity or currency of the data provided by the clients. Obligated subjects must determine the frequency with which they carry out this stage, considering the LA/FT risks they face.

The partial or total completion of each of these stages depends on the provisions established in this regulation.

16.3 When the obligated subject is not in a position to comply with the aforementioned due diligence stages in client knowledge, it must proceed as follows: i) not initiate commercial relations, not carry out the operation and/or terminate the commercial relationship initiated; and/or ii) evaluate the possibility of making a suspicious operation report (ROS) in relation to the client.

16.4 In the event that the obligated subject has suspicions of LA/FT activities and considers that carrying out due diligence actions would alert the client, it must report the suspicious operation to the UIF-Peru, without carrying out such actions. These cases must be substantiated and documented.

Article 17.- Client knowledge and due diligence

The obligated subject must identify its clients, in each operation, in accordance with the following:

a) General regime of due diligence in client knowledge The obligated subject must request from its client, executing party of the operation, the presentation of the following minimum information:

1. Names and surnames.

2. Type and number of identity document.

3. Nationality, in the case of foreigners.

4. Occupation.

5. Address.

6. Telephone number.

7. Purpose of the relationship to be established with the obligated subject, provided that this does not arise directly from the object of the contract.

8. If a PEP, indicating, if applicable, the position and name of the institution (public body or international organization). In this case, the rules of the enhanced regime referred to in subsection b) below must be applied. If a PEP, refer to: i) their relatives up to the second degree of consanguinity and second degree of affinity, ii) spouse or cohabitant of the PEP.

9. The identity of the beneficiary of the operation:

    i. If the operation is carried out in favor of oneself, the origin of the funds/assets involved in the operation.

    ii. If the operation is carried out in favor of a third party who is a natural person: ii.1) the names and surnames of the natural person, ii.2) details of the representation (whether acting under a power of attorney and whether it is by public deed) or mandate and ii.3) the origin of the funds/assets involved in the operation.

    iii. If the operation is carried out in favor of a legal entity: iii.1) its name or corporate name; iii.2) RUC number, if applicable; iii.3) details of the representation (whether acting under a power of attorney and whether it is by public deed) or mandate iii.4) origin of the funds/assets involved in the operation, iii.5) identification of the shareholders, partners or associates who directly or indirectly hold more than 25% of the share capital, contribution or participation of the legal entity (names and surnames in the case of natural persons and name or corporate name in the case of legal entities).

To perform customer due diligence under the general regime, the obligated subject may use the Sworn Statement Form of Customer Knowledge under the general regime, referred to in Annex No. 2.

b) Enhanced due diligence regime The application of this regime implies for obligated subjects the development and implementation of enhanced due diligence procedures in knowing their customers additional to those of the general due diligence regime. Obligated subjects must identify and register under this regime

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customers who demonstrate a pattern that does not correspond to their LA/FT risk profile, as well as those customers who could be highly affected by LA/FT risks.

This regime must be mandatorily applied to the following customers:

1. Nationals or foreigners, non-residents.

2. Non-domiciled legal entities.

3. PEPs and identified as: i) relatives of PEPs up to the second degree of consanguinity and second degree of affinity, ii) spouse or cohabitant of PEP; and, iii) legal entities or legal entities where a PEP holds a participation equal to or greater than 25% of its share capital, contribution or participation.

The additional measures to be applied in these cases must be proportional to the identified risks. Among others at the discretion of the obligated subject, they may involve:

1. Increase the frequency in the review of the customer's transactional activity.

2. Conduct inquiries and apply additional identification and verification measures, such as: obtaining information on the main suppliers and customers, collecting information from public or open sources, conducting visits to the domicile.

3. The decision of acceptance and/or maintenance of the relationship with the customer must be in charge of the highest managerial level of the obligated subject or similar position, which may delegate this function to another managerial position within the organization or to a committee established for this purpose, retaining responsibility for the acceptance and/or maintenance or not of the customer.

Article 18.- Knowledge of directors and workers

18.1 Obligated subjects must implement a due diligence policy in knowing their workers and directors, if they have such a governing body. This policy must be part of their recruitment and selection program for new, permanent and temporary personnel, in order to ensure their integrity.

18.2 To comply with the provisions of the previous paragraph, the obligated subject must establish the profiles of workers and directors, after evaluating them, for which they must require a sworn statement that includes the following minimum information:

a) Full names and surnames.

b) Type and number of identity document (including a copy).

c) Marital status, specifying the names and surnames of the spouse or cohabitant, if applicable.

d) Profession or occupation.

e) Occupation and/or position in the obligated subject.

f) Address, telephone number and email, if applicable.

g) Professional studies and specialized training received.

h) Information on their police and criminal records.

i) Employment history in the last two (2) years prior to hiring.

j) Asset history (asset information and other income generated outside the obligated subject).

18.3 The minimum information indicated in the previous paragraph must be part of the personal documentation of each of the workers of the obligated subject and of its directors, if they have such a governing body. For this purpose, the “Sworn Statement Form of Knowledge of Directors and Workers” referred to in Annex No. 3 must be used. The obligated subject must require its workers that, in

case the referred information changes, it must be communicated to the obligated subject within a maximum period that does not exceed fifteen (15) calendar days from the occurrence of the change.

18.4 Obligated subjects must comply with the following:

a) At the time of selection or hiring and after the relationship between the parties, verify the lists indicated in Annex No. 1 – Lists that contribute to the prevention of LA/FT, in order to determine whether the directors, if they have such a governing body, and workers are included in them.

b) Verify at least once a year that the information referred to in paragraph 18.2 is updated as appropriate.

c) Establish internal mechanisms in order to sanction infractions of the regulations on the prevention of ML/TF, as well as of the manual and the code.

Article 19.- Use and responsibility of third parties or intermediaries

19.1 The obligated subjects may, if they consider it necessary, use third parties or intermediaries to comply with the services related to the identification and/or verification of information of clients, directors and workers.

19.2 The obligated subjects must adopt the corresponding measures to obtain the information, copies of the identification data and other pertinent documentation; as well as a sworn statement by which the third party or intermediary indicates that it has taken the necessary measures to comply with the provisions on customer due diligence of clients, directors or workers.

19.3 The obligated subjects retain responsibility for the due diligence process in the knowledge of clients, directors or workers, even when it has been entrusted to a third party or intermediary, whether related or not, and must supervise compliance with the provisions of current regulations.

CHAPTER IV ON TRAINING

Article 20.- General aspects

20.1 The obligated subject, through the compliance officer, must inform the directors and workers within thirty (30) days following their date of entry, about the scope of the ML/TF prevention system, leaving a record thereof.

20.2 In addition to the information indicated in the preceding paragraph, the directors and workers of the obligated subject, the compliance officer, as well as the obligated subject when it is a natural person, must have at least one annual training in matters of prevention and/or detection of ML/TF, in order that they be instructed - according to their specialty and function they perform -, at a minimum, regarding the aspects indicated in the following article.

20.3 The training is an obligation of the obligated subject and may be given by third parties, specialized entities or by the compliance officer, under any modality. The obligated subjects must keep a record of the trainings received, which must be available to the UIF-Perú, in the information corresponding to each director or worker, in physical and/or electronic media. In the case that the training has been carried out by the compliance officer, the latter must issue a record with the character of a sworn statement indicating the day, place, duration and the topics of the training, as well as the names and surnames and positions of the persons trained.

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20.4 The compliance officer is responsible for communicating to the obligated subject and all workers about the changes made in the regulations of the ML/TF prevention system.

Article 21.- Minimum training requirements

The obligated subject that is a natural person, the directors and workers must be trained, according to their functions, at a minimum on the following:

a) Definition of the crimes of ML/TF.

b) Policies and procedures established by the obligated subject on the model of prevention and management of ML/TF risks.

c) ML/TF risks to which the obligated subject is exposed.

d) Current regulations on ML/TF prevention.

e) ML/TF typologies detected in the activities of the obligated subject or other obligated subjects.

f) Internal rules of the obligated subject.

g) Alert signals to detect unusual and suspicious operations.

h) Procedure for reporting unusual operations.

i) Information on the lists indicated in Annex No. 1 - Lists that contribute to the prevention of ML/TF.

j) Responsibilities regarding the prevention of ML/TF, according to their specialty and function they perform.

CHAPTER V REGISTRY OF OPERATIONS

Article 22.- Aspects related to the registry of operations

22.1 The obligated subject must keep and maintain updated a registry of operations (RO) in which it records the individual loan and pawn operations carried out by its clients. The mere inclusion of an operation in the RO does not necessarily imply that the client has carried out an unusual or suspicious operation.

22.2 The information that supports the RO must be available to the UIF-Perú and to the jurisdictional bodies and competent authorities in accordance with Law. The obligated subjects must keep a backup copy of the RO.

22.3 On the content and form of the RO

a) The obligated subject must record the operations on the day they have occurred. The RO must be kept and maintained in chronological, precise and complete form.

b) The RO must contain, with respect to each operation, the information provided in Annex No. 4 - Registry of Operations (RO) in accordance with the provisions of numeral 9.3 of article 9 of the Law and article 7 of the Regulation of the Law and is kept through computer systems, which are easily retrievable.

c) With respect to the natural and legal persons that intervene in the operation, the identification of the executor and beneficiaries must be recorded, as corresponds to the operation.

22.4 Thresholds for the RO

a) Net realization and/or adjudication value of precious stones, precious metals and/or jewels of precious metals and/or precious stones granted by clients as collateral, when said value is for amounts equal to or greater than US$ 2,500.00 (two thousand five hundred and 00/100 American dollars) or its equivalent in national currency or other currencies. Net realization value in the market is understood as the net value that the obligated subject expects to recover as a consequence of the eventual sale or execution of the asset, in the situation as and where it is.

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b) The obligated subject must register advance loan payments, provided that the amount of the advance payment is equal to or greater than US$ 10,000.00 (ten thousand and 00/100 US dollars), its equivalent in national currency or other currencies, as the case may be.

c) Companies must keep at the disposal of the Superintendency a registry of multiple transactions carried out in one or several offices, establishments or any type of electronic device that individually exceed the threshold of one thousand US dollars (US$1,000.00) or its equivalent in national currency or other currencies; and that, additionally, in their totality, during one calendar month, equal or exceed fifty thousand US dollars (US$ 50,000.00), its equivalent in national currency or other currencies, as the case may be.

d) The applicable exchange rate to establish the equivalent in national currency or other currencies, as the case may be, is the one obtained by averaging the daily selling exchange rates corresponding to the month prior to the transaction, published by the Superintendency.

Without prejudice to the established threshold, the obligated subject may internally establish lower thresholds for the RO, which may be set based on the risk analysis of the transactions it carries out, the economic sector, the client's profile or any other criterion it determines, in accordance with the provisions of this regulation.

22. 4 The obligated subject sends the RO to the UIF-Peru, in the structure, electronic means, periodicity, form and instructions established by this Unit or the SBS.

Article 23.- Non-exclusion of the RO

The obligated subject must not exclude any client that carries out transactions subject to the RO report, regardless of their habitual nature and the knowledge it has of them.

CHAPTER VI REPORTING OF SUSPICIOUS TRANSACTIONS AND THEIR COMMUNICATION

Article 24.- Reporting of suspicious transactions (ROS)

24.1 The obligated subject has the obligation to communicate to the UIF-Peru, through its compliance officer, the transactions carried out or that have been attempted to be carried out, that are considered suspicious, regardless of the amounts involved, in accordance with the provisions of the Law, the Regulation and this regulation. The communication must be made immediately and sufficiently, that is, within a period that - in accordance with the nature and complexity of the transaction - allows the compliance officer to qualify it as suspicious; and to prepare, document and submit the ROS to the UIF-Peru. The period to submit the ROS to the UIF-Peru must in no case exceed fifteen (15) business days from when the suspicious transaction is detected as such.

24.2 The compliance officer, on behalf of the obligated subject, qualifies the transaction as suspicious and proceeds with its communication to the UIF-Peru and leaves documentary evidence of the analysis and evaluations carried out, for the qualification of a transaction as unusual or suspicious, as well as the reason why an unusual transaction was not qualified as suspicious and reported to the UIF-Peru, as the case may be. Transactions qualified as unusual and the documentary support of the analysis and evaluations are kept, in accordance with the design provided in Annex No. 5 - Design for the identification of unusual transactions.

24.3 The obligated subject, through the compliance officer, must submit to the UIF-Peru the ROS and the attached or complementary documentation through the ROSEL system, using for this purpose the ROSEL template published on the portal for the prevention of money laundering and terrorist financing (plaft.sbs.gob.pe) enabled by the SBS for such purpose. In no case must the ROS include the

identity of the compliance officer or the obligated subject, nor any other element that could contribute to identifying them, except for the secret codes assigned by the UIF-Peru.

24.4 The compliance officer is responsible for the correct use of the ROSEL system and all the information contained in the respective template and its annexes, and must therefore adopt the necessary measures to ensure the accuracy and veracity of the information, its reserve and confidentiality.

24.5 Annex No. 6 - Alert Signals contains a list of the type of alert signals that each obligated subject must take into account in order to detect unusual or suspicious transactions. The foregoing does not exempt the obligated subject from communicating other transactions it considers suspicious, in accordance with its LA/FT prevention system and with the alert signals identified by the obligated subject itself, related to the activities it carries out. Without prejudice to this, the UIF-Peru may provide the obligated subject with additional information or criteria that contribute to the detection of unusual or suspicious transactions. The mere existence of elements configuring alert signals does not generate the obligation to file the ROS.

24.6 The communication of suspicious transactions to the UIF-Peru by the obligated subject, through the compliance officer, is confidential and reserved in nature. For all legal purposes, the ROS does not constitute a criminal complaint.

CHAPTER VII INTERNAL RULES

Article 25.- Prevention and management manual for LA/FT risks

25.1 The policies and procedures related to compliance with the LA/FT prevention system; and the management of LA/FT risks, must be included in the Manual. The Manual must contain at a minimum: i) general aspects of the LA/FT prevention system; ii) functions and responsibilities of the employees of the obligated subject, directors and the compliance officer, iii) General mechanisms for managing money laundering and terrorist financing risks, iv) Registration and communication procedures and v) International references and regulations on the prevention of money laundering and terrorist financing, considering the information indicated in Annex No. 7 - Basic content of the manual for the prevention and management of LA/FT risks.

25.2 The manual must be approved by:

a) The obligated subject, when it is a natural person.

b) The board of directors or equivalent body when it is a legal person or by the general manager, manager, owner-manager or administrator, if the legal person, according to its bylaws, is not required to have a board of directors.

25.3 The obligated subject must record the acknowledgment taken by it, its employees, the compliance officer, and directors, if applicable, regarding the manual and their commitment to comply with it in the exercise of their functions; as well as keep such record. For this purpose, the obligated subject may use Annex No. 8, which contains a model sworn statement of receipt and acknowledgment of the manual and/or code.

25.4 The manual must be updated in accordance with national regulations and international standards on the matter and must also incorporate, in addition to the alert signals in Annex No. 6 of this regulation, those identified by the obligated subject or its compliance officer in the development of its activity, as well as the criteria to be adopted regarding amounts, time periods and other aspects of the alert signals. Modifications to the Manual, when the obligated subject is a legal person, must be communicated to the employees, the compliance officer and directors, if applicable.

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25.5 The Manual must be available to the UIF-Peru, when required.

Article 26.- Code of conduct for the prevention of LA/FT

26.1 The obligated subject must approve and implement a code, aimed at ensuring the proper functioning of the LA/FT prevention system, which must contain, among other aspects, the guiding principles, values and policies that must be applied to manage exposure to LA/FT risks, as well as the measures to guarantee the indefinite duty of confidentiality of the information to which it has access regarding the LA/FT prevention system. The obligated subject may take into account the "Model code of conduct for the prevention of money laundering and terrorist financing" attached as Annex No. 9.

26.2 The code must highlight the mandatory nature of the procedures that make up the LA/FT prevention system, in accordance with current regulations on the matter; specifying those particular details to which the obligated subject, its employees, the compliance officer and its directors, if applicable, must adhere.

26.3 The code of conduct for the prevention of LA/FT must be approved by:

a) The obligated subject, when it is a natural person.

b) The board of directors or equivalent body when it is a legal person or by the general manager, manager, owner-manager or administrator, if the legal person, according to its bylaws, is not required to have a board of directors.

26.4 The code must be made known to the administrative and operational organization of the obligated subject, its employees, the compliance officer and its directors, if applicable, and a record must be kept thereof. For this purpose, the obligated subject may use Annex No. 8, which contains a model sworn statement of receipt and acknowledgment of the manual and/or code.

26.5 The code must be available to the UIF-Peru, when required.

CHAPTER VIII TREATMENT OF THE ECONOMIC GROUP

Article 27.- Economic group

Economic groups may develop corporate policies and procedures in relation to the LA/FT prevention system, including:

a) Group-level policies and procedures on risk management and LA/FT prevention.

b) Policies and procedures for exchanging information within the group for LA/FT prevention purposes, establishing adequate safeguards on confidentiality and the use of the exchanged information.

c) Necessary criteria that the members of the economic group must adopt to ensure high standards when hiring employees and appointing directors.

d) Training programs on LA/FT prevention.

CHAPTER IX REPORTS OF THE COMPLIANCE OFFICER

Article 28.- Annual report of the compliance officer

28.1 The compliance officer must prepare and submit to the UIF-Peru an annual report on compliance with the policies and procedures that make up the LA/FT prevention system implemented by the obligated

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obligated subject, called Annual Report of the Compliance Officer (IAOC), which contains at a minimum the following information:

a) The address and telephone of the obligated subject, as well as the email address of the compliance officer.

b) The indication as to whether the compliance officer performs the function as corporate compliance officer or not.

c) Name of the partners, shareholders or associates and percentages of participation in the obligated subject, if applicable.

d) Name of the managers or other employees responsible for the management of the business, if applicable.

e) Annual statistics of the RO, breaking down the information monthly, indicating the number of operations recorded and the amounts involved.

f) Annual statistics of detected unusual operations, breaking down the information monthly, specifying the amounts involved or any other aspect deemed significant.

g) Annual statistics of suspicious operations reported to the UIF-Peru, breaking down the information monthly, specifying the amounts involved or other aspects deemed significant.

h) Description of new unusual operation alert signals established by the obligated subject and typologies of suspicious operations that have been detected and reported, if any.

i) Customer, director and employee due diligence policies.

j) Number of training sessions on topics related to LA/FT prevention, including a general description of the training provided and the number of people who have been trained. Likewise, the number of people who were trained more than once a year must be indicated, as well as the detail of the training topics according to the profile of the recipient and their role in the obligated subject, as well as the LA/FT risks they face.

k) Last update date of the manual and code; and the level of compliance with the manual and code, indicating those cases in which it has been breached, the sanctions imposed and the corrective measures adopted.

l) Corrective actions adopted regarding the observations or recommendations that may have been made by the UIF-Peru and the internal and external auditors, when applicable.

m) Other important aspects related to its management, at the discretion of the compliance officer.

n) Others determined by the SBS.

28.2 The IAOC must have the approval of the board of directors or equivalent body of the obligated subject or, failing that, of the general manager, manager, owner-manager or administrator as applicable, provided that the legal entity, according to its bylaws, is not required to have a board of directors. In the event that the obligated subject is not a legal entity, approval of the report corresponds to the natural person who owns the activity. The report must be approved within thirty (30) days following the end of the respective annual period.

28.3 The IAOC must be submitted by the compliance officer of the obligated subject, no later than 15 February of the following year, to the UIF-Peru, through the asset laundering and terrorist financing prevention portal (plaft.sbs.gob.pe) or another means established by the SBS through a Circular or other means of communication, in the structure and in accordance with the instructions determined by the same means.

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27.4 In the case of the corporate compliance officer, they must submit an annual report for each of the obligated subjects that are part of the economic group, within the same deadlines indicated above.

CHAPTER X IDENTIFICATION AND ASSESSMENT OF LA/FT RISKS

Article 29.- LA/FT risk factors

Among the main LA/FT risk factors that must be identified and considered by obligated subjects in loan and pawn operations are:

a) Customers.- obligated subjects must manage the LA/FT risks associated with customers, their behavior, background and activities, at the beginning and throughout the business relationship. The analysis associated with this LA/FT risk factor incorporates the attributes or characteristics of customers.

b) Products and/or services.- obligated subjects must manage the LA/FT risks associated with the products and/or services they offer, including those linked to the distribution channels and means of payment with which they operate.

c) Geographic area.- obligated subjects must manage the LA/FT risks associated with the geographic areas in which they offer their products and/or services, taking into account their security, economic-financial and socio-demographic characteristics, the provisions issued by competent authorities or the Financial Action Task Force – FATF with respect to such jurisdictions, among others. The analysis associated with this LA/FT risk factor comprises the areas in which the obligated subjects operate, as well as those linked to the operation process.

Article 30.- Identification and assessment of LA/FT risks

Obligated subjects must develop and implement procedures for the identification and assessment of LA/FT risks, taking into account the LA/FT risk factors to which they are exposed. For these purposes, obligated subjects must:

a) Identify the risks inherent to their activity.

b) Assess their possible occurrence and impact.

c) Implement adequate control measures to mitigate the different types and levels of risk identified.

d) Permanently monitor the results of the applicable controls and their degree of effectiveness, in order to detect those operations that are unusual or suspicious and correct existing deficiencies in the risk management process.

CHAPTER XI RETENTION OF DOCUMENTS AND RESPONSE TO INFORMATION REQUESTS

Article 31.- Retention of documents

31.1 Obligated subjects must retain the information related to the LA/FT prevention system and that which supports compliance with the provisions established in this regulation for a period of no less than ten (10) years. This information mainly comprises the information related to the onboarding and operations carried out by customers, including all information obtained and/or generated in application of due diligence measures.

31.2 For this purpose, computer means are used that allow easy retrieval of the information for consultation and internal or external reporting to the competent authorities in accordance with Law.

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31.3 The aforementioned information must be kept up to date, considering for this purpose the LA/FT risk analyses and the periodicity established by the obligated subject and considered in the manual and, as applicable, must be available to the UIF-Peru.

Article 32.- Handling of information requests from authorities

32.1 Obligated subjects must develop and implement mechanisms for handling requests made by competent authorities in relation to the LA/FT prevention system, taking into account the deadlines and forms provided in the legislation and regulations on the matter.

32.2 The obligated subject must handle, within the required period, the requests for information or expansion of information made by the UIF-Peru, in accordance with current regulations.

32.3 The obligated subject, through its compliance officer, must send and/or make available to the UIF-Peru the reports, records of operations (RO) and suspicious operation reports (ROS), by electronic means or any other means established; as well as all information that allows proving compliance with the provisions of this regulation.

Article 33.- Communications sent by the obligated subject

33.1 The communications, reports, records and reports that, in accordance with the Law, Regulation and this regulation, the obligated subject must send through its compliance officer to the UIF-Peru, must be identified only with the secret codes assigned to the latter and to the obligated subject, adopting the measures that allow the confidentiality of the information and its senders.

33.2 The communications sent by the obligated subject to the UIF-Peru, for compliance with the provisions of this regulation, are made through physical or electronic means, as determined by the latter.

33.3 The communications referred to in this regulation are confidential in nature and all those involved are prohibited from making known to any person the content of such information, as well as whether such information has been requested, made available or provided to the UIF-Peru, under the corresponding administrative, civil and criminal liabilities.

COMPLEMENTARY AND FINAL PROVISIONS

First.- Annexes

The following annexes form an integral part of this Regulation:

Annex No. 1: Lists that contribute to the prevention of LA/FT.

Annex No. 2: Sworn declaration form of customer knowledge under the general regime.

Annex No. 3: Sworn declaration form of knowledge of directors and workers.

Annex No. 4: Registry of Operations (RO)

Annex No. 5: Design for identification of unusual operations.

Annex No. 6: Warning Signs

Annex No. 7: Basic content of the Manual for prevention and management of LA/FT risks.

Annex No. 8: Model of sworn declaration of receipt and knowledge of the Manual and/or Code.

Annex No. 9: Model Code of Conduct.

Second.- On exemption from liability

In accordance with article 13 of the Law, the obligated subject and its workers are exempt from criminal, civil and administrative liability, as applicable, arising from due compliance with current regulations on LA/FT prevention.

Article 2.- The annexes referred to in the Regulation for the management of risks and prevention of money laundering and financing of terrorism applicable to obligated subjects dedicated to the granting of loans and pawnbroking approved by article 1 of this resolution, are published on the Institutional Portal – www.sbs.gob.pe – in accordance with the provisions of Supreme Decree No. 001-2009-JUS.

Article 3.- The UIF-Peru, by Circular or other means, communicates to the obligated subjects the date from which the registry of operations required by the Regulation for the management and prevention of money laundering and financing of terrorism applicable to obligated subjects dedicated to the granting of loans and pawnbroking must be sent, in the structure, electronic means, periodicity and in accordance with the instructions it determines.

Article 4.- Obligated subjects within the framework of the regulation approved by Article 1 of this resolution, which at the date of entry into force of this, have authorization to have a corporate compliance officer, must adapt to the provisions of the aforementioned regulation within a period of sixty (60) business days counted from the entry into force of the regulation, so that the respective authorization remains in force. If the requirements demanded in said regulation are met, a sworn declaration to that effect must be sent to the UIF-Peru; otherwise, the respective supporting documentation and/or the new authorization request, if applicable, must be sent.

Obligated subjects whose authorization requests to have a corporate compliance officer, which at the date of entry into force of this regulation are in process, must submit the supporting documentation that proves compliance with the requirements established in the regulation approved by Article 1 of this resolution.

Article 5.- This Resolution enters into force on 1 December 2016, date from which numeral 7 of literal B. of article 1 of the Regulation for the Prevention of Money Laundering and Financing of Terrorism, of general application to obligated subjects to report that lack supervisory bodies, approved by SBS Resolution No. 486-2008, is repealed.

Register, communicate and publish.

JAVIER MARTIN POGGI CAMPODONICO
Superintendent of Banking, Insurance and Administrators Private Pension Funds (e)