SANCTIONS COMPLIANCE · ANTI-MONEY LAUNDERING (AML) · KNOW YOUR CUSTOMER (KYC) VIEW COMPLIANCE POLICIES
PromoVEN
SANCTIONS COMPLIANCE · ANTI-MONEY LAUNDERING (AML) · KNOW YOUR CUSTOMER (KYC)VIEW COMPLIANCE POLICIES
PromoVEN LLC
PromoVEN LLC · Integrity & Trust

Global Corporate Compliance, Sanctions, & Anti-Money Laundering Policy Manual

We are committed to transparency, integrity, and compliance with applicable laws and regulations, including sanctions, anti-money laundering (AML), and know-your-customer (KYC) requirements.

Integrity & transparencyClear communication and accurate information guide our work.
Know your customerWe review businesses, ownership, representatives and relevant participants as appropriate.
Responsible oversightWe address potential compliance concerns before moving forward.

1. Executive Statement & Governance Framework

1.1 Statement of Zero-Tolerance Commitment

PromoVEN LLC (the “Company”) maintains a zero-tolerance policy toward money laundering, terrorist financing, proliferation financing, sanctions evasion, and other financial crimes or unlawful commercial activity. The Company verifies participating businesses to support cross-border trade.

1.2 Regulatory Jurisdictions & Governing Authorities

The Company's Global Compliance Program addresses requirements in the United States, Venezuela, Colombia, and relevant international standards. It takes into account the laws and regulatory guidance of the following authorities:

  • United States: The Financial Crimes Enforcement Network (FinCEN), the Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Bank Secrecy Act (BSA) [31 U.S.C. § 5311 et seq.], the USA PATRIOT Act, and the Corporate Transparency Act (CTA).
  • Venezuela: El Ejecutivo Nacional, la Superintendencia de las Instituciones del Sector Bancario (SUDEBAN), la Unidad Nacional de Inteligencia Financiera (UNIF), y el Servicio Autónomo de la Propiedad Intelectual (SAPI), en estricto cumplimiento con la Ley Orgánica de Drogas (LOD) y la Ley Orgánica contra la Delincuencia Organizada y Financiamiento al Terrorismo (LODFT).
  • Colombia: La Superintendencia Financiera de Colombia (SFC), la Superintendencia de Sociedades (Supersociedades), y la Unidad de Información y Análisis Financiero (UIAF), bajo los lineamientos del Sistema de Autocontrol y Gestión del Riesgo Integral de LA/FT (SAGRILAFT) y el Sistema de Administración del Riesgo de Lavado de Activos y Financiación del Terrorismo (SARLAFT).
  • International Bodies: The Financial Action Task Force (FATF/GAFI), specifically its 40 Recommendations on Money Laundering and Terrorist Financing, and the Basel Committee on Banking Supervision.

1.3 Scope of Application

This Policy applies universally to all applicants, approved members, corporate entities, subsidiaries, affiliates, legal representatives, and third-party contractors accessing the Company's platform, data networks, or marketplace infrastructure across all geographic boundaries.

2. Institutional Cross-Border Business Verification (KYB & KYC)

2.1 The Onboarding Mandate

No company or individual may activate an account, access data, or view the marketplace until completing the Company's required Know Your Business (KYB) and Know Your Customer (KYC) checks.

2.2 Jurisdictional Documentation Requirements

Applicants must submit verified, unaltered, and current documentation depending on their specific country of incorporation and physical operational footprint:

A. United States Entities

  • Corporate Existence: A certified Certificate of Good Standing or Certificate of Existence issued by the Secretary of State of the state of formation within the preceding ninety (90) days.
  • Formation Documents: Articles of Incorporation, Articles of Organization, or Certificates of Formation, inclusive of all active amendments.
  • Tax Identification: Internal Revenue Service (IRS) Form CP-575 or an official W-9 certifying the entity's Employer Identification Number (EIN).
  • Governance Records: Executed Operating Agreements, Corporate Bylaws, or Partnership Agreements outlining the managerial structure and voting allocations.

B. Venezuelan Entities (Personas Jurídicas)

  • Commercial Registry Lineage: The complete, sequential Acta Constitutiva y Estatutos Sociales filed before the corresponding Registro Mercantil, accompanied by every subsequent registered corporate assembly, modification of capital, or change in board composition.
  • Tax and Fiscal Registration: A valid, unexpired Registro Único de Información Fiscal (RIF) matching the exact corporate name and address listed in the commercial registry.
  • Operational Verifications: The municipal commercial license (Patente de Industria y Comercio), confirming a legitimate physical operating presence, alongside the Registro Nacional de Contratistas (RNC) certification if applicable.
  • Legal Representation: The official publication or registry entry designating the Presidente, Director, o Administrador with valid corporate signature powers (Firma Autorizada).

C. Colombian and Regional Latin American Entities

  • Chamber of Commerce Certification: A current Certificado de Existencia y Representación Legal issued by the corresponding Cámara de Comercio within the preceding thirty (30) days.
  • Tax Identification: The national tax registry form (Registro Único Tributario - RUT), detailing the company’s Número de Identificación Tributaria (NIT) and specified economic activities (CIIU codes).
  • Financial Statements: Audited financial statements or accounting certifications verified by a licensed Contador Público, establishing legitimate commercial operations.

2.3 Individual KYC Verification

Registered individual users, executive officers, and legal representatives must provide high-resolution biometric identification:

  • International Passports: Mandatory for non-resident foreign investors or cross-border transactors.
  • Local Identification Cards: Legally issued national identity documents, specifically the Cédula de Identidad (Venezuela/Colombia) or U.S. State-issued Driver's Licenses/ID cards.
  • Proof of Residential Address: Utility bills, banking statements, or municipal residency certificates issued within the prior ninety (90) days.

3. Ultimate Beneficial Ownership (UBO) & Control Person Framework

3.1 The More-Than-10% Structural Disclosure Rule

The Company requires identification of each Ultimate Beneficial Owner (UBO / Beneficiario Final) to help prevent shell companies from concealing illicit activity.

  • Definition of UBO: Any natural person who ultimately owns or controls, directly or indirectly, more than 10% of the shares, voting rights, ownership interests, or financial benefits of the applicant corporate entity.
  • Alignment with U.S. FinCEN BOI: This framework is architected to apply PromoVEN’s independent, stricter disclosure standard, which is separate from any applicable governmental BOI reporting threshold.
  • Alignment with Latin American Registries: The process complies with Colombia's Registro Único de Beneficiarios Finales (RUB) and equivalent compliance mandates executed by SUDEBAN in Venezuela.

3.2 Complex and Layered Corporate Architectures

Where an applicant entity is owned by intermediate corporate layers, holding companies, offshore trusts, or Sociedades Anónimas (S.A.), the compliance department will execute "look-through" procedures.

  • Exhaustive Mapping: The applicant must provide explicit corporate capitalization tables (Libro de Accionistas) and legal organization charts tracing equity ownership up through every intermediary layer until every natural person exceeding the 10% threshold is identified.
  • Trusts and Foundations: If shares are held via trust (Fideicomiso) or private foundation, the identities of the Settlor, Trustee, Protector, and all named Beneficiaries must be disclosed and verified.

3.3 Control Person Identification & Legal Representation

If no natural person directly or indirectly owns more than 10% of the corporate entity, the Company requires identification of a Control Person.

  • Executive Leadership: The natural person with ultimate managerial authority over the enterprise must be processed through full KYC protocols. This includes the Chief Executive Officer (CEO), Chief Financial Officer (CFO), Managing Director, or the registered Representante Legal / Administrador Único.
  • Validation of Authority: The Company requires the submission of formal, unexpired powers of attorney (Poderes Notariados o Registrados) to verify that the individual executing agreements has the true, legal authority to bind the foreign or domestic corporation.

4. Economic Sanctions Screening & Restricted Entities Protocols

4.1 Automated Real-Time Screening Systems

The Company screens applicants, corporate entities, parent organizations, subsidiaries, affiliates, directors, officers, and UBOs against global restrictions and sanctions lists. Screening takes place during onboarding and continues throughout the business relationship.

4.2 Primary Enforcement Databases

Screening parameters include, but are not limited to, the following high-risk registries:

  • United States (OFAC): The Specially Designated Nationals and Blocked Persons List (SDN List), the Sectoral Sanctions Identifications List (SSI List), and the Foreign Sanctions Evaders List. This includes strict adherence to the OFAC 50 Percent Rule, which automatically bars any entity owned 50% or more in the aggregate by one or more blocked persons, whether or not the entity itself is explicitly named on a list.
  • United Nations: The United Nations Security Council Consolidated Sanctions List (UNSC).
  • European Union: The EU Consolidated List of Financial Sanctions Targets.
  • Regional Registries: Restrictive lists maintained by the Colombian UIAF, the Venezuelan UNIF, and international law enforcement agencies (e.g., Interpol Red Notices).

4.3 Politically Exposed Persons (PEPs / APREs)

The Company applies Enhanced Due Diligence (EDD) to entities associated with a Politically Exposed Person (PEP).

  • Scope of Definition: Includes heads of state, senior politicians, senior government, judicial, or military officials, senior executives of state-owned corporations (Empresas del Estado), and important political party officials.
  • Extended Network Screening: PEP screening extends to immediate family members (cónyuges, familiares en primer grado de consanguinidad) and close business associates (estrechos colaboradores).
  • Approval Authority: Onboarding any entity displaying a PEP match requires the explicit, written sign-off of the Chief Compliance Officer (CCO) following a rigorous source of wealth (SoW) and source of funds (SoF) evaluation.

4.4 Prohibited Sectors and Entities

The Company strictly prohibits participation from:

  • Entities subject to asset freezes, blocking orders, or executive orders targeting specific economic sectors in Venezuela or other sanctioned jurisdictions.
  • Military, intelligence, or security apparatuses of prohibited regimes.
  • Entities located in or operating from non-cooperative countries and territories designated by the FATF as high-risk or subject to a Call for Action.

5. Ongoing Risk Auditing & Enhanced Due Diligence (EDD)

5.1 Dynamic Risk-Scoring Methodology

Compliance is executed as an active, continuous monitoring program. Every member entity is assigned an automated, risk-based classification (High Risk, Medium Risk, Low Risk) dictated by their operational jurisdiction, corporate complexity, and economic sector.

5.2 Enhanced Due Diligence (EDD) Triggers

The Company applies Enhanced Due Diligence to higher-risk profiles, including those involving foreign capital, complex cross-border joint ventures, or operations in volatile economic environments. EDD requires the following:

  • Source of Wealth (SoW) Verification: Documented proof of how the corporate enterprise accumulated its total net worth (e.g., audited corporate historical filings, inheritance records, asset sales).
  • Source of Funds (SoF) Validation: Explicit tracking of the specific funds utilized in transactions or platform fees, requiring bank statements, audited wire trails, and certifications from licensed financial intermediaries.
  • On-Site and Independent Verification: Utilizing localized corporate intelligence and independent legal reviews to confirm that the business has genuine, ongoing operations (operaciones legítimas y continuas) and is not a passive front entity.

5.3 Trigger-Based Event Reviews

An immediate, out-of-cycle corporate re-audit is triggered by any of the following events:

  • Any material alteration in the company’s ownership structure or capitalization table exceeding a 10% shift.
  • A change in the registered Representante Legal, CEO, or Board of Directors.
  • Modifications to the physical or operational address of the business.
  • The updating or expansion of international sanctions lists that introduce proximity risks to the member’s supply chain or industry sector.
  • Failure to provide updated, renewed documentation upon the expiration of essential corporate records (such as an expired RIF in Venezuela or an expired Certificado de Existencia in Colombia).

5.4 Remediation, Suspension, and Termination Protocols

The Company may take the following compliance actions against an account that fails to meet its requirements:

  • Administrative Pause: If a member fails to provide required documentation within seven (7) business days of an update request, data visualization and profile activation will be immediately suspended.
  • Permanent Termination: If an entity triggers a verified sanctions match, fails an absolute UBO verification, or is found to have supplied fraudulent corporate records, the relationship will be terminated permanently without prior notice, and all marketplace profiles will be expunged.

6. Data Governance, Cyber Security, & Regulatory Reporting

6.1 Military-Grade Data Security

All corporate intelligence, KYB documentation, personal identity records, and verification histories collected under this Policy are treated as highly confidential and restricted assets.

  • Encryption Protocols: Data is protected utilizing Advanced Encryption Standard AES-256 at rest and Transport Layer Security (TLS 1.3) in transit.
  • Access Control: Access to compliance files is restricted via strict Role-Based Access Controls (RBAC) and Multi-Factor Authentication (MFA), limited exclusively to vetted compliance personnel.

6.2 Statutory Record-Retention Policies

To comply with the Bank Secrecy Act, FinCEN regulations, and applicable financial-supervision requirements in Latin America, the Company follows this data-retention schedule:

  • Retention Period: All onboarding records, historical KYC scans, corporate registries (Actas Constitutivas), compliance officer logs, and audit trails are securely preserved for a mandatory minimum period of seven (7) years.
  • Commencement of Timeline: The seven-year retention timeline commences explicitly on the exact date that the business relationship is formally terminated or the corporate account is closed.

6.3 Regulatory Disclosures and Financial Intelligence Sharing

While the Company respects standard corporate privacy and trade confidentiality, our statutory obligations to international financial integrity supersede private contracts.

  • Mandatory Reporting: The Company will actively cooperate with competent judicial authorities, federal law enforcement, and financial intelligence networks (such as FinCEN, UIAF, and UNIF).
  • Subpoena Compliance: Corporate files, verification logs, and communication data will be surrendered immediately upon the receipt of a valid judicial subpoena, court order, or statutory request from an authorized regulatory agency.
  • Tipping-Off Prohibition: In accordance with international AML best practices, the Company is strictly prohibited from notifying ("tipping off") any entity if they are the subject of an internal investigation, a suspicious activity review, or an official regulatory inquiry.

Compliance Validation Notice

By applying for membership, completing the corporate onboarding questionnaire, or uploading corporate records to the PromoVEN network, the applicant company, its directors, and authorized legal representatives agree to follow the requirements in this Global Compliance Policy Manual.