The Chilean subsidiary’s combination of local regulatory oversight, SEC reporting and disclosure obligations, and a three-lines-of-defense governance model supports a robust anti-money laundering compliance framework designed to align with international standards.
Latin America remains one of the world's most exposed regions to transnational financial crime, including money laundering and terrorist financing.
Regulatory frameworks have strengthened significantly over the past decade, but the capacity to detect and report suspicious activity varies widely across institutions and jurisdictions.
Against this backdrop, Banco Santander Chile has built a compliance framework that combines anti-money laundering (AML) monitoring, internal controls, and regulatory oversight within a structured governance model.
A multi-layer compliance model
Santander Chile's approach to anti-money laundering is built on multiple interconnected layers, as detailed in the bank's official communiqué on its anti-money laundering monitoring of suspicious transactions.
These include defined internal procedures, transactional monitoring technology, enhanced due diligence processes, case escalation mechanisms, and specialized teams coordinating across compliance, risk, operations, and internal control functions.
This multi-layer structure ensures that no single point of failure can compromise the system's ability to detect financially suspicious behavior—critical in an environment where criminal networks continually adapt their methods.
What distinguishes Santander Chile from many Latin American peers is the breadth of its regulatory and disclosure framework.
In Chile, the bank is subject to the local financial regulatory framework, including supervision by the Comisión para el Mercado Financiero and the AML/CTF obligations applicable to banks. In addition, through its NYSE-listed ADR program under ticker BSAC, Santander Chile is registered as a foreign private issuer in the United States and files annual reports with the U.S. Securities and Exchange Commission on Form 20-F.
This framework requires the bank to maintain and disclose robust governance, risk management and internal-control practices, including material risks related to anti-money laundering, counter-terrorist financing, sanctions compliance, customer due diligence, PEP screening, training, investigations and regulatory sanctions where relevant.
In addition, as a SEC-reporting issuer, Santander Chile is subject to Sarbanes-Oxley requirements over internal control over financial reporting, including independent auditor attestation under Section 404(b), where applicable. This provides an additional layer of control discipline and public-market transparency that can strengthen investor confidence.
Data: the scale of AML operations
The numbers reinforce the framework's scope. In 2025, Santander Group's filed over 311,000 suspicious activity reports across its global operations, according to the bank. . In Chile specifically, the Unidad de Análisis Financiero (UAF) received 21,828 SARs in 2025, a 25.3% year-on-year increase, averaging 87 reports per business day. Of these, 1,132 contained sufficient indicators of money laundering or terrorist financing to be referred to the Public Ministry for investigation.
The banking sector's dominance in Chile's AML reporting infrastructure is striking: banks account for 70.2% of all Cash Operation Reports (ROE) submitted nationally. In 2024, Chilean banks filed 10,630 SARs—61% of the national total—underscoring their role as the primary detection layer of the country's financial crime prevention system.
Three lines of defense: Santander Group's framework
Santander Chile's compliance model reflects Santander Group's global corporate AML framework, built around three independent lines of defense.
The first line—business units—applies controls in day-to-day operations.
The second line—Compliance & Conduct—designs and oversees AML policies and monitoring systems.
The third line—internal audit—independently verifies that the system operates as designed.
This framework enforces a zero-tolerance policy against financial crime and includes a no-tipping-off rule that prohibits alerting clients under investigation—aligned with FATF (Financial Action Task Force) recommendations and international best practices.
Outlook: crypto and digital payments as the next AML frontier
Santander Chile's Form 20-F explicitly acknowledges the emerging risks posed by crypto-assets and digital payment platforms as potential vectors for financial crime. The bank's existing investment in AI-powered compliance infrastructure, together with its combination of local AML obligations, SEC disclosure standards, and SOX control requirements, provides a framework for addressing these emerging challenges.
As regulators in Chile, the U.S., and globally work to extend anti-money laundering requirements to the crypto ecosystem, institutions with mature compliance architectures—built on multiple oversight layers, advanced technology, and robust governance—will be best positioned to meet the next generation of requirements.
