We received a request from the Corporate Legal Manager of Intercorp Retail to evaluate whether the companies IR MANAGEMENT SRL and INMOBILIARIA MILENIA S.A. qualify as obliged subjects to report their operations to the SBS-UIF PERU. In this regard, we proceeded to review all the corporate documentation of both companies, together with the applicable regulatory standards (SBS Resolution No. 789-2018, SBS Resolution No. 2351-2023, Law No. 27693 and others), in which it was determined that they do qualify as obligated parties for being real estate agents and therefore, they must implement a System for the Prevention of Money Laundering and Financing of Terrorism (SPLAFT) with all the documentation indicated in the applicable regulations. Then, we were asked to prepare a SPLAFT implementation plan, as well as the corresponding documents to comply with the regulations (designation of the compliance officer, policy of knowledge of employees, directors and final beneficiaries, among others).
