Financial Intelligence Unit Implements New Measures

On December 19, 2024, the Financial Intelligence Unit (UIF) issued Resolution 200/2024, establishing obligations necessary to manage and mitigate risks of money laundering, financing of terrorism, and financing of mass destruction weapons proliferation (ML/TF/PF), following the international standards and the Recommendations of the Financial Action Task Force (FATF). These obligations reach issuers, operators, collection and/or payment service providers, and non-financial credit providers, which have been included in the list of reporting entities as of the entry into force of Law 27739.

 

 Reporting Entities

 

According to the Resolution, the following will be considered reporting entities:

 

1. Issuers: credit, charge, or prepaid cards, and/or traveler’s checks issuers.

 

2. Collection Agents and Payment Service Providers (PSPs):

 

1. 1. 1. Legal entities that, although not financial institutions, provide tax and/or utility collection services on behalf of third parties through agent networks, using cash and/or payment instruments.

 

1. 1. 2. Those entities that are part of a retail payment scheme as account providers, acceptors, acquirers, aggregators, or sub-acquirers.

 

3. Non-financial Credit Providers: legal entities that, although not financial institutions, offer credit to the public as a primary or ancillary activity, granting financing on a regular basis.

 

Main obligations of reporting entities

 

The main responsibilities the Resolution establishes are:

 

1. Registration: registering before the UIF as reporting entities.

 

2. ML/FT/FT/FP Prevention Manual: drafting and annually updating a ML/FT/FP Prevention Manual.

 

3. Compliance Officer: appointing regular and alternative compliance officers.

 

4. Code of Conduct: establishing an Internal Code of Conduct.

 

5. Risk Self-Assessment Technical Report:

 

• This Reprt should consider, at least, the following risk factors: clients, products, and/or services offered; distribution channels and geographic locations; information provided by the UIF or other authorities.

 

• It must be self-sufficient, annually updated and filed befre the UIF and the Argentine Central Bank (BCRA) before April 30 every year.

 

6. External Review: carrying out a independent external review every other year [MF1] and submitting before the UIF the report within 120 days from the deadline to submit the technical report.

 

7. Systematic Reports: Submitting the corresponding systematic reports, including the monthly credit card report, the cash transaction report, and the annual systematic report, as applicable.

 

8. Clients’ Segmentation and Due Diligence:

 

• Segmenting clients accrding to the risk assigned to each and applying due diligence measures accordingly.

 

• Carrying ut ongoing due diligence and updating clients’ information according to the risk level assigned to them.

 

9. Red flags alert signals: these should be considered to determine whether a suspicious transaction report should be filed, for example, when sequential transactions or simultaneous electronic transfers are carried out without apparent reason, when the customer operates with third-party funds, among others.

 

Validity and key deadlines

 

Although the Resolution became enforceable on December 20, 2024, it establishes specific dates for certain obligations:  

 

1. The first risk self-assessment technical report must be submitted by April 30, 2026.

 

2. The first independent external auditor's report must be submitted by August 31, 2026.

 

3. The first monthly reports must be submitted as of May 2025.

 

The first annual systematic report must be submitted between January 2 and March 15, 2026.