BNDES, as an ethical and responsible financial institution, operates in compliance with international commitments taken on by the federal government and aims at preventing the practice of fraud, corruption, money-laundering and the financing of terrorist activities when carrying out its operations in the country and overseas, in accordance with the national legislation and the legislation in effect in every country where it operates.

BNDES participates in collective initiatives to combat fraud and preventing money-laundering and the financing of terrorist activities (AML/CFT) such as the Integrity and Anticorruption Business Pact (Ethos Institute), the National Strategy to Combat Corruption and Money Laundering (Enccla), the National Forum of Management of Ethics in State-owned Enterprises and commissions of the Brazilian Federation of Banks (Febraban) on compliance and AML/CFT, and promotes much training of its employees on how to combat fraud and prevent money-laundering and/or the financing of terrorist activities.

The measures and mechanisms adopted by BNDES for the prevention, detection and remediation of deviations, fraud, irregularities and illegal acts committed against Bank or against third parties are gathered in our Integrity Program, related to the dimensions (1) management environment, (2) risk analysis, (3) structuring and implementation of policies and procedures, (4) communication and training and (5) monitoring, remediation measures and application of penalties.

Specifically on AML/CFT, we highlight some efforts carried out by the BNDES System:

• the registration analysis conducted by BNDES includes the postulant of financial support, its controllers, shareholders, other companies that integrate their economic group (which have common control) and their managers, pursuant to Brazilian Central Bank Circular No. 3,461/2009; 
• consultation of national data sources and international lists, such as the World Bank and the Inter-American Development Bank, among others;
• rejection of the transaction of resources through anonymous current accounts or linked to fictitious parties in the BNDES’ operations;
• it analyzes the instruments used in its operations, as well as the operational structure, the parties and amounts involved, the financial capacity and the economic activity of the stakeholders and/or beneficiaries and any indication of irregularity or illegality, thus allowing the Bank to identify evidence of money-laundering and/or the financing of terrorist activities and fraud;
• when the circumstances reveal evidence of money-laundering, it uses measures of a restrictive nature regarding the stakeholders and/or beneficiaries, blocking operations; and
• procedures for internal verification, which result in indicated improvement suggestions that are being monitored by the compliance unity.

The main compliance documents are applicable in Brazil and abroad to all participants of the BNDES System and to people with whom they maintain relations:

• Compliance Policy
• Integrity Program
• BNDES System Corporate Integrity Policy (PCIN)
• The Wolfsberg Group Anti-Money Laundering Questionnaire
• Policy for Prevention of Money Laundering and Combating Terrorist Financing