The Superintendency of Non-Financial Subjects (SSNF) imposes sanctions on non-financial obligated entities.

In an effort to strengthen regulatory compliance in the non-financial sector, the Superintendency of Non-Financial Subjects (SSNF) has imposed monetary sanctions on legal entities and individuals, with fines starting at USD 5,000.00, for non-compliance with the following obligations:

Non-compliance with the obligation to register with the SSNF set forth in Article 44 of Law 124 of January 2020, in accordance with the “THIRD” paragraph of Resolution No. S-010-2021 of December 2, 2021.

Over 36 companies have been sanctioned since 2021, according to the institution’s statistical information.

Other sanctions are due to non-compliance with the obligations set out in Articles 26, 27 and 29 of Law 23 of April 27, 2015, related to due diligence, updating and safeguarding.

It should be noted that Article 26 of this law states that financial obligated entities must conduct their operations with the care necessary to reasonably prevent such operations from being carried out with funds derived from activities related to money laundering, terrorism financing and financing of the proliferation of weapons of mass destruction.

They have also been fined for non-compliance with Article 36 of Resolution No. JD-REG-001-18 of May 2, 2018, related to the failure to submit all information or documentation required by the Superintendency of Non-Financial Subjects.

“Over 36 companies have been sanctioned by the Superintendency of Non-Financial Subjects from 2021 to date.”

“More than USD 350,000 in sanctions imposed on the Construction sector.”

Likewise, they have been sanctioned for failing to comply with the obligations regarding the employee knowledge policy and the obligation to train them on this matter.

In the case of companies in the Colón Free Zone, they were sanctioned for non-compliance with due diligence, design of controls for the application of preventive measures with a risk-based approach, control measures for free zones, preventive freezing and the obligation to provide training.

Some of the sanctioned law firms were due to their failure to register in the Private and Unique System of Ultimate Beneficiaries of the Superintendency of Non-Financial Subjects, set forth in Article 3 of Law 129 of March 17, 2020, in accordance with the “fourth” paragraph of Resolution No. S-011-2022 of July 5, 2022 and Article 2 of Executive Decree No. 13 of March 25, 2022.