The concept of corporate governance in modern banking goes far beyond mere compliance with minimum standards: it involves a highly specialised institutional architecture, capable of detecting, managing and reporting complex financial risks, with a critical focus on the systematic and transparent prevention of money laundering.
Santander Chile offers one of the most robust and comprehensive examples of this control structure in Latin America.
The Three Lines of Defence: The Structure Supporting Banking Compliance
The internal control model of Santander Chile is based on the corporate AML framework of Grupo Santander, structured into three independent lines of defence.
The first line consists of the business units: the commercial, operational, and customer service teams that apply controls on a daily basis. They are the first to detect a warning signal, such as a potential money laundering case, for example, and are responsible for applying due diligence procedures with each client.
The second line corresponds to the Compliance & Conduct teams, who design the policies, procedures, and monitoring systems, and oversee that the first line applies them correctly.
The third line is internal audit, which independently reviews the functioning of the first two. Its role is to certify that the system works as designed, not just on paper.
This internal structure is complemented by a regulatory and transparency requirement that is uncommon in the Chilean banking system.
Santander Chile is subject to the supervision of the Comisión para el Mercado Financiero (CMF) and must also comply with disclosure obligations before the United States Securities and Exchange Commission (SEC), as its ADRs are listed on the New York Stock Exchange under the ticker BSAC.
This means that the bank must also meet the requirements of the Sarbanes-Oxley Act, including the annual certification of its internal controls under Section 404(b) by an independent auditing firm.
This additional level of external scrutiny, public transparency, and discipline over internal controls is rare among banks that operate solely under local regulation in Latin America.
The Chilean Model in LATAM
The combination of a robust corporate framework with regulatory demands allows Santander Chile to have good practices in the prevention of money laundering. At the Group level, more than 311,000 reports of suspicious activities were submitted worldwide.
In Chile, the bank's control and monitoring system for unusual operations operates in a coordinated manner among banking compliance, risks, operations, and internal control.
According to the UAF's Statistical Report, there were more than 21,828 Reports of Suspicious Operations (ROS) in the country in 2025, a 25.3% increase from the previous year.
The notable increase in reports at both local and global levels is not a coincidence, but a direct result of an increasingly scrutinised and technological financial ecosystem.
In this scenario, Santander Chile's ability to align with the highest international standards demonstrates that regulatory compliance is no longer just a legal requirement, but an indispensable strategic pillar to ensure security, transparency, and trust in the banking of the future.
You may also like
