AML and KYC in Argentina: UIF obligations for companies, banks and other reporting parties

Key rules

1. Legal architecture

1.1 The statute and its amendments

BO dates for the decrees and resolutions are taken from the Infoleg record of norms that modify or complement Law 25.246 (verVinculos, id 62977).

1.2 Key definitions (Law 25.246 art. 4 bis, added by Law 27.739 art. 4)

Law 27.739 brought a definitions article into the statute for the first time:

• Beneficial owner (beneficiario final): the natural person or persons who hold an interest or voting rights in, or by any other means exercise direct or indirect control of, a company, legal person or other contractual entity or legal structure. The term also covers the natural persons who exercise ultimate effective control, "with the scope defined in the regulations". For trusts and similar domestic or foreign structures it includes every natural person who acts or participates in the structure under any name, and the beneficial owners of each party. If none can be identified, the persons in charge of management, administration or representation are treated as the beneficial owners.
• Clients: any natural person, legal person or other legal structure, domestic or foreign, and anyone acting on their behalf, with whom a financial, economic or commercial contractual relationship is established, whether occasional or permanent.
• Risk based approach: regulation and application of measures proportional to the identified risks, covering identification, assessment, monitoring, management and mitigation.
• Suspicious facts or operations: attempted or completed operations that cause suspicion, or give reasonable grounds to suspect, that the assets come from or are linked to a criminal offence, terrorist financing or proliferation financing. The term also covers operations first flagged as unusual whose unusual nature the reporting party cannot justify after analysis.
• Unusual operations: attempted or completed operations, isolated or repeated and regardless of amount, that lack economic or legal justification, do not match the client's risk level or transactional profile, or deviate from market practice.
• Specific supervisory bodies: BCRA, CNV, INAES (cooperatives and mutuals) and SSN (insurance), plus any added by regulation.
• Politically exposed persons: natural persons who hold or have been entrusted with prominent public functions in Argentina, abroad or in international organisations; the detail is left to regulation.
• Virtual asset: a digital representation of value that can be traded or transferred digitally and used for payments or investment. Argentine pesos and foreign fiat currencies are expressly excluded.
• Virtual asset service provider (VASP): any natural or legal person who, as a business and for or on behalf of another person, (i) exchanges virtual assets and fiat, (ii) exchanges between virtual assets, (iii) transfers virtual assets, (iv) provides custody or administration of virtual assets or of instruments enabling control over them, or (v) participates in and provides financial services related to an issuer's offer or sale of a virtual asset.

1.3 The criminal offences (Criminal Code, as replaced by Law 27.739 arts. 2 and 3)

The administrative regime protects against the criminal offences, and the thresholds matter when advisers assess exposure:

Laundering applies even if the predicate offence was committed abroad, as long as it was also punishable where committed (art. 303(5)). The peso value of 150 SMVM depends on the minimum wage in force at the time of the facts (unconfirmed).

2. Who must comply: the reporting parties (art. 20)

Article 20 was replaced by Law 27.739 art. 14, and paragraph 7 was replaced again by Decree 891/2024. The current list:

Professionals (para. 17). Lawyers, accountants and notaries are reporting parties only when, in the name or on behalf of clients, they prepare or carry out:

• purchase or sale of real estate above 700 SMVM;
• management of assets above 150 SMVM;
• management of bank, savings or securities accounts above 50 SMVM;
• organisation of contributions to create, operate or manage legal persons or structures;
• creation, operation or management of legal persons or structures, and purchase or sale of businesses or of interests in legal persons.

Accountants are also covered when they prepare audit reports on financial statements. Independent lawyers, notaries and accountants are not required to report suspicious transactions where they obtained the information in circumstances subject to professional secrecy (art. 20(17), last paragraph).

Company and trust service providers (para. 18). These are persons who, habitually and for clients, act as formation agents, act as or arrange for others to act as directors, attorneys or partners, provide a legal, commercial or postal address or physical space, or act as trustee of a non financial trust.

Exclusions for payment businesses. UIF 200/2024 art. 2(v) excludes the issuers of the card used by the Sistema Único de Boleto Electrónico, issuers of in store purchase cards, fuel cards and pure payment initiators whose only function is to send a valid payment instruction to the account provider.

VASP exemption threshold. Under CNV RG 994/2024 (new Title XIV, Chapter III, art. 1 of the CNV Rules), VASPs whose aggregate activity does not exceed UVA 35,000 per calendar month are exempt from the CNV registry. The UVA is valued on the last day of the month (unconfirmed).

Trap: old numbering. Resolutions issued before Law 27.739 (UIF 14/2023, 78/2023, 99/2023, 126/2023, 169/2023, 194/2023, 1/2023, 2/2023, 43/2024) cite the old paragraph numbers of art. 20. For example, UIF 78/2023 originally referred to paragraphs 4, 5 and 22. UIF Resolution 109/2026 art. 3 replaced those references with paragraphs 7 and 8 for the capital markets resolution. Whether the other sector resolutions have been similarly updated is (unconfirmed). Read each resolution by its definition of "Sujeto Obligado" rather than by paragraph number.

3. The core duties (art. 21)

Article 21 was replaced by Law 27.739 art. 15 and again by Decree 274/2025 art. 3. The UIF sets the scope of each duty "according to a risk based approach". Reporting parties must:

Two further rules in art. 21 are important in practice:

• Reliance and information sharing. Reporting parties may share CDD information with each other if the data subject consents and confidentiality is protected, under UIF rules. They may also rely on other reporting parties for client identification within limits. Responsibility stays with the party that relies on the third party (art. 21(a)).
• Refusal rule. If a reporting party cannot complete the measures in letters a), g), h) and i), it must not start or continue the relationship. It must also carry out additional analysis to decide whether to file a ROS (art. 21, final paragraph).

No secrecy against the UIF. In the context of a ROS, a voluntary declaration or an exchange with a foreign FIU, reporting parties cannot invoke banking, tax, stock exchange or professional secrecy, or contractual confidentiality, against the UIF (art. 14(1)). The UIF may also request information from any public body or natural or legal person, who must answer within the term set "under legal warning" (art. 14(1)). This applies to ordinary companies too.

Safe harbour. Reporting in good faith creates no civil, commercial, labour, criminal or administrative liability (art. 18).

Secrecy duty and its sanction. UIF staff, reporting parties and voluntary declarants must keep the information secret. Revealing it is punishable by 6 months to 3 years in prison (art. 22). If a company's executive body commits that offence, the company faces a fine of 15 to 2,500 modules (art. 23).

4. The risk based approach in the sector resolutions

The post 2023 resolutions share a common structure. The references below are to UIF 200/2024 (payments and non bank lenders), with parallel articles in UIF 14/2023 (banks) and UIF 49/2024 (VASPs).

4.1 Risk assessment and appetite

• Risk factors (art. 4): at least clients, products and services, distribution channels and geographic zones. A risk analysis is required before launching new products, practices or technologies.
• Self assessment technical report (art. 5): annual, documented, self sufficient, kept with methodology and data at the address registered with the UIF. It must be sent to the UIF and the BCRA, once approved, before 30 April each year and whenever the risk level changes. A business that is starting activities must complete it before beginning operations, based on its projected business plan. Filing does not imply tacit approval, and the UIF may object or require changes.
• Risk tolerance statement (art. 6): approved by the board and filed with the self assessment before 30 April.
• Mitigation (art. 7): enhanced measures for high risk; simplified measures only where low risk is "verified", meaning the firm can show tables, statistics or analytical documents proving the absence or marginal nature of risk factors.

Exchange houses under Law 18.924 may file the self assessment, tolerance statement and external review every two years (UIF 14/2023 arts. 5, 6 and 19). Payment and lending firms under UIF 200/2024 have a biennial external review (art. 19(a)). Banks (UIF 14/2023 art. 19) and VASPs (UIF 49/2024 art. 19) have an annual one.

4.2 Minimum compliance policies (UIF 200/2024 art. 8)

The list includes:

• screening against RePET before starting the relationship, plus permanent screening;
• applying the PEP rules;
• CDD on all clients and continuous identification of beneficial owners;
• risk rating of every client;
• acceptance or rejection of high risk clients and foreign PEPs with reasons;
• rules on incomplete wire transfers;
• alerts and monitoring;
• a register of unusual operations;
• ROS and systematic reports;
• a training plan;
• appointment of a compliance officer and alternate;
• record keeping;
• internal audit and independent external review;
• screening and hiring standards for staff;
• a code of conduct;
• taking into account FATF lists: jurisdictions under increased monitoring (risk factor) and high risk jurisdictions subject to a call for action (mandatory enhanced due diligence).

4.3 Compliance officer

The officer's duties under UIF 14/2023 art. 12 include proposing policies, preparing the self assessment and manual, implementing monitoring and ROS procedures, and approving high risk clients and foreign PEPs. They also include monitoring RePET, keeping the unusual operations register, filing systematic reports, and proposing a remediation plan for deficiencies found by internal audit or the external reviewer.

4.4 Training, code of conduct, records

• Training (UIF 200/2024 art. 18; UIF 14/2023 art. 18): an annual plan covering all directors, managers and staff. New joiners must be trained within 60 business days (UIF 14/2023 art. 18). Records of training must be kept available for UIF and BCRA.
• Code of conduct (art. 20): breaches of AML policies must be internal disciplinary offences, and staff must acknowledge the code.
• Records (art. 17; Law 25.246 art. 21(n)): transaction documents for at least 10 years from the operation; client and BO files for at least 10 years from the end of the relationship or the last transaction, whichever is later. Records must be kept in digital form with a backup copy.

4.5 Independent external reviewer

The external reviewer must be registered under UIF Resolution 67/2017 (BO 12 Oct 2017). Requirements include at least 5 years of professional experience in AML/CFT (art. 2). Incompatibilities (art. 3) include being a partner, shareholder, director or employee of the reporting party or its group, relatives up to the third degree, and acting simultaneously as the BCRA required external auditor of the same entity. The reporting party must keep a file on the reviewer for 5 years (art. 4 onwards). For PSPs the report is biennial, covers both years, and must be filed within 120 calendar days of the self assessment deadline (UIF 200/2024 art. 19). It must expressly assess the remote onboarding process (art. 25).

5. Customer due diligence

5.1 Identification data (UIF 200/2024 arts. 22 to 25)

Non face to face onboarding (art. 25) is allowed with "rigorous, storable, auditable and non manipulable" techniques that are protected against physical and digital fraud. Automated verification is allowed if it performs at least as well as a human agent. The firm must risk assess the remote process. No prior UIF authorisation is needed, but the external reviewer must opine on it.

Anonymous accounts and accounts in false names are prohibited (art. 21).

5.2 Risk rating and levels of due diligence

Sources: UIF 200/2024 arts. 26 to 30. For medium and low risk clients, the firm may decide on a risk and materiality basis whether the update is needed within the stated term (art. 30).

Article 26 lists higher risk indicators the firm must consider or expressly justify excluding:

• non residents, except tourists buying currency;
• personal asset holding vehicles;
• cash intensive activity not matching the business;
• excessively complex ownership chains;
• jurisdictions of concern;
• countries that finance or harbour terrorism;
• sanctioned countries;
• FATF increased monitoring jurisdictions;
• entities handling third party funds that are not themselves reporting parties.

Acquirers and card issuers may defer the risk rating up to the close of the second billing cycle or 60 days, if the client's enabled volume does not exceed 15 SMVM (art. 26).

Refusal and tipping off. If CDD cannot be completed, the firm must not start or continue the relationship and must consider a ROS. Missing documents alone do not make an operation suspicious (arts. 26, 30 and 32). If performing CDD would alert a suspected client, the firm may skip it provided it files a ROS (art. 32).

Clients that are themselves reporting parties (art. 31): the firm must obtain the client's UIF registration certificate and may not start the relationship if the client is not registered. It may request the client's manual, visits and contact with its compliance officer, and in appropriate cases apply the "client's client" principle.

Banks: no tax returns. Since UIF Resolution 78/2025 (BO 5 Jun 2025, art. 5), banks building the transactional profile under UIF 14/2023 art. 37 may not require tax sworn statements (declaraciones juradas impositivas). The same resolution replaced the bank rule on cash deposits. Banks must now identify the depositor for cash deposits at or above 40 SMVM, and file systematic cash transaction reports (RTE) and cash FX reports (RTEOC) at or above 40 SMVM (UIF 14/2023 arts. 42 and 44 as replaced).

5.3 Beneficial owner

The ARCA general resolution that implements the Law 27.739 registry, the filing form and the current deadline are not in the sources (unconfirmed).

5.4 Politically exposed persons (UIF 35/2023, as amended by UIF 192/2024)

• Foreign PEPs (art. 1) include:
• heads of state or government, ministers and equivalents;
• members of parliament;
• senior judges;
• ambassadors and consuls;
• party authorities;
• senior military officers (from colonel) and police (from commissioner);
• directors of state owned companies, and of private or mixed companies where the state holds 20% or more or has control;
• central bank and financial regulator authorities;
• senior management of international organisations.
• Domestic PEPs (art. 2) include national, provincial, municipal and City of Buenos Aires officials such as the President, legislators, governors, mayors, ministers and secretaries, judges and prosecutors from first instance upward, ambassadors, heads of the armed and security forces, university rectors and deans, and heads of licensing and control bodies, among others.
• Other PEPs (art. 3) include persons who control private legal persons that receive public funds for third parties.
• By family or closeness (art. 4):
• spouse or partner;
• parents, siblings, children, parents in law and children in law, brothers and sisters in law;
• close associates with business ties, even informal ones;
• any other relevant link on a risk basis.
• Duration (art. 6): while in office and 2 years after leaving.
• Sworn statement (art. 8): required at onboarding and whenever the status changes; it can be signed electronically. The firm must first show the client the content of the resolution.
• Risk measures (art. 7): reasonable measures to detect PEPs among clients and BOs; risk factors include product, cash use, jurisdictions, source of funds, conflicts of interest and exposure to corruption. Automated alerts and intense monitoring are mandatory in all cases.
• Foreign PEPs are always high risk (UIF 200/2024 art. 29) and require compliance officer approval (UIF 14/2023 art. 12(e)).

6. Monitoring, unusual operations and suspicious operation reports

6.1 Transactional profile and monitoring

The profile is prospective (ex ante) and is recalibrated with actual activity. It is based on the purpose of the relationship and the client's economic, financial and asset documentation (UIF 200/2024 art. 33). Monitoring must use automated rules and alerts (art. 34).

6.2 Register of unusual operations (art. 35)

For each alert the firm must record:

• client and risk level;
• profile;
• operation and amount;
• detection method;
• date, time and source of the alert;
• type of unusual feature;
• analyst;
• actions taken;
• date of the final reasoned decision.

6.3 ROS deadlines

ROS must be reasoned, include all data and supporting documents, and remain confidential. They may not be shown to supervisors, except to the BCRA in an on site supervision in cooperation with the UIF. External reviewers may see anonymised information to test the monitoring system (UIF 14/2023 art. 40(d)). The statute requires reporting "without any delay" (Law 25.246 art. 21(b)). UIF 56/2024 (BO 26 Mar 2024) aligned the ROS articles of all sector resolutions with the new statutory definitions.

6.4 Systematic reports (payments and VASPs)

The peso value of each SMVM threshold is the minimum wage in force at 31 December of the prior year or 30 June of the current year, as applicable (UIF 200/2024 art. 2(u); UIF 14/2023 art. 2(ñ)) (unconfirmed).

7. Terrorist financing lists and freezing: RePET

The Public Registry of Persons and Entities linked to Acts of Terrorism and its Financing (RePET) was created by Decree 489/2019 (BO 17 Jul 2019), which added Chapter VI (arts. 23 to 32) to Decree 918/2012. It operates within the Ministry of Justice (art. 23). Its content and effects:

• Who is registered (art. 25): persons charged by a court or prosecutor with terrorism offences (Criminal Code arts. 41 quinquies and 306); persons listed by the UN Security Council (art. 28); and persons subject to a UIF administrative freeze (art. 29).
• Effects (arts. 30 to 32): the UIF must order a freeze where it verifies suspicious operations, if it has not already done so. Reporting parties must report any operation, carried out or attempted, involving registered persons. Foreign registered persons are barred from entering Argentina.
• Public access with the scope set by the Ministry of Justice (art. 24).

UIF Resolution 207/2025 (BO 4 Nov 2025) now governs the reporting party side and repealed UIF 29/2013 (art. 9):

1. Report as TF suspicious any operation where the assets are owned or controlled, directly or indirectly, by a person designated under UN Security Council Resolution 1267 or by the Executive under Decree 918/2012 art. 25(d). The same applies where such a person carries out or benefits from the operation, or where the assets may be linked to TF (art. 1). Reporting parties must check RePET.
2. Report within 24 hours of the operation; the UIF may be warned in advance by any means. If that is impossible without delay, involve the competent judge immediately (art. 2).
3. Freeze without delay and without notice (inaudita parte) the assets involved where there is a designation match, inform the UIF immediately and file the TF ROS (art. 3).
4. On receiving a UIF freeze resolution: check the client base, immobilise assets, report results within 24 hours, report later attempted operations, freeze later incoming assets and do not tip off (art. 4).
5. Freezes based on a designation last while the listing lasts. Freezes based on suspected links last up to 6 months, extendable once (art. 7).

UIF Resolution 3/2026 (BO 8 Jan 2026) creates a parallel regime for proliferation financing. It covers persons designated under UN Security Council Resolutions 1718 (DPRK) and 1737 (Iran). It requires periodic list checks, 24 hour reports, freezing without delay and the same order of congelation reporting (arts. 2 to 8).

Trap. UIF 14/2023 art. 12(m) and UIF 200/2024 art. 8(b) still refer to "Resolution UIF 29/13 or those that modify, complement or replace it". That reference now points to UIF 207/2025. Manuals that copy the old wording should be updated.

8. Virtual asset service providers

VASPs face two layers:

CNV registration (Law 27.739 arts. 37 to 39; CNV RG 994/2024, BO 25 Mar 2024):

• Argentine resident or incorporated persons must register before carrying out any VASP activity (CNV Rules Title XIV, Chapter III, art. 1(a)).
• Foreign persons must register if they act "in the country" (art. 3), which means any of the following:
• using a ".ar" domain;
• having commercial agreements or affiliates that let them receive local funds or assets from Argentine residents (on ramp services);
• clearly targeting Argentine residents;
• advertising clearly aimed at Argentine residents;
• Argentine business volume above 20% of total volume in the relevant activities.
• Unregistered persons must refrain from the activity (art. 2).
• Exemption below UVA 35,000 of aggregate monthly activity (art. 1).
• Documents (art. 4): identity, tax ID, addresses, phone, notification email, website and social media handles, and the activities performed. For companies, add bylaws with registration, the legal representative and the main activity. Applications are made at www.argentina.gob.ar/cnv.
• Persons domiciled in jurisdictions that are non cooperative for tax transparency (Decree 862/2019 annex art. 24) and considered non cooperative or high risk by FATF cannot register (art. 4).
• A mandatory legend on websites and social media states the registration number and that registration does not imply a licence or CNV supervision of the activity (art. 5). CNV may require a licence in future (art. 6).
• Providers already active had 45 days from RG 994's entry into force to apply (CNV Rules Title XVIII, Chapter XIV).
• CNV RG 996/2024 (BO 5 Apr 2024) lists VASPs among the capital market reporting parties under CNV's AML title (CNV Rules Title XI, Section I, art. 1(i)).

Whether CNV has since replaced the registry with a full licensing regime, and the current CNV rule numbers, are (unconfirmed).

UIF obligations (UIF 49/2024, BO 25 Mar 2024): the full risk based system, with annual self assessment, annual external review, ROS deadlines as above, systematic reports and the travel rule. The travel rule requires identifying originator and beneficiary in transfers between VASPs under FATF standards, in the form the UIF sets (art. 37). The first self assessment was due before 30 April 2025 covering 2024, the first external review before 31 August 2025, and the first RSA between 2 January and 15 March 2025 (art. 41).

9. Registration with the UIF

Registration is through the UIF's online reporting system (SRO). The 2011 resolution refers to www.uif.gov.ar/sro, later ones to www.uif.gob.ar/sro, and UIF 200/2024 to https://www.argentina.gob.ar/uif. Check the current portal before filing (unconfirmed). A party that starts activity must register between the 1st and the 30th of the month in which it starts (UIF 50/2011 art. 3).

Documents for a legal person (UIF 50/2011 art. 3 bis, III), uploaded in PDF:

1. Note signed by the highest authority, legal representative or compliance officer with name, CUIT, activity, address, phone and electronic domicile (which becomes the domicile for UIF notices), data on the titular and alternate compliance officers and their board positions, and data on all board members and their terms.
2. Updated bylaws or registered constitutive contract.
3. CUIT certificate.
4. Licence, authorisation or registration enabling the activity, if any.
5. Minutes appointing the board and allocating positions.
6. Minutes appointing the titular and alternate compliance officers.
7. BO sworn statement with full data and PEP status.
8. Criminal record certificates from the National Recidivism Registry (or foreign equivalent for non residents) for board members and beneficial owners.
9. Trust contracts if registering as trustee.

The UIF may raise observations, which must be cured within 15 administrative business days (art. 3 bis, I).

10. Sanctions and procedure

10.1 Sanctions table (Law 25.246 art. 24, as replaced by Decree 274/2025)

Rules applying to fines:

• Fines for multiple independent breaches are added together.
• If the offender is a legal person, the same sanction applies to the members of its administrative and management bodies, who answer jointly and severally.
• Sanctions must be effective, proportionate and dissuasive, considering the nature and risk of the breach, organisational size, history, business volume and recidivism. Recidivism means a new breach within 5 years of a final sanction.
• The module started at ARS 40,000 (Law 27.739 art. 19). It was updated to ARS 54,140 by UIF Resolution 95/2025 (BO 23 Jun 2025). The UIF may update it every budget year (unconfirmed).
• The legal person sanction under art. 23 (secrecy breach by its organ) is also 15 to 2,500 modules.

10.2 Procedure and deadlines

10.3 Abbreviated procedure (UIF 90/2024, Annex I, Chapter III, as approved by UIF 129/2024)

• Scope (art. 34): total or partial breach of art. 21 duties other than ROS, if the parties are not recidivists.
• Fixed settlement (art. 35): 30 modules per charge for a total breach in monitoring, terrorist lists, PEPs, beneficial owner, registration and compliance officer appointment, duty to cooperate or enhanced due diligence; 25 modules for a partial breach in those areas; 15 modules or a warning for other charges.
• Acceptance (arts. 36 and 37): the reporting party and the board members for the period must accept jointly and unconditionally within 10 days, pay, and commit to remediate within 3 months together with a registered independent external reviewer. Acceptance implies admitting the breaches.
• Effect (art. 39): the final resolution creates no record and does not count for recidivism if there is no new breach within 5 years. If payment or remediation fails, the ordinary procedure resumes and any payment counts on account.
• Transitional regime (Annex I, transitional clauses 1 and 2, as replaced by UIF 195/2024 of 16 Dec 2024): for cases under the pre Law 27.739 regime, a peso based scale applied (up to ARS 70,000, 50,000 or 30,000 per charge). For pending cases including ROS charges, the first instalment could be paid.

15. FATF context

• Argentina has been a full member of FATF and GAFILAT since 2000 (Decree 489/2019, recitals).
• In March 2024 CNV stated that FATF was carrying out its evaluation of Argentina, which explained the urgency of the VASP registry (CNV RG 994/2024, recitals).
• By April 2025 FATF had issued its Fourth Round Mutual Evaluation report on Argentina. Decree 274/2025's recitals cite several of its points:
• "priority actions" on detecting TF beyond ROS (g), risk based supervision (i) and the UIF's role as a complainant in criminal cases (d);
• a recommended action for a national counter terrorism strategy (Immediate Outcome 9).
• Decree 891/2024's recitals also refer to FATF Recommendation 29 (FIU operational independence) in removing the UIF advisory council.

The report's publication date, the technical compliance and effectiveness ratings, the follow up category and whether Argentina is subject to any FATF list are not in the sources (unconfirmed). A National Money Laundering Risk Assessment was approved by Decree 653/2022 (BO 23 Sep 2022), according to the Infoleg record. Its content was not reviewed (unconfirmed).

Step by step

Online process; no paper filing in the sources.

1. Scope check (week 1). Map your activities against Law 25.246 art. 20(5) and (6) and the definitions in UIF 200/2024 art. 2: account provider, acceptor, acquirer, aggregator or sub acquirer, collection network, card issuer, non bank lender. Confirm you are not merely a payment initiator (art. 2(v)(IV)). If you also touch virtual assets, add UIF 49/2024 and CNV RG 994/2024.
2. Corporate set up. Incorporate. Appoint a board that includes the titular and alternate compliance officers, who must be board members (art. 21(f)). Obtain criminal record certificates for directors and beneficial owners (UIF 50/2011 art. 3 bis).
3. Risk assessment before launch. Prepare the self assessment technical report and methodology on your business plan before operations start, and the board's risk tolerance statement (UIF 200/2024 arts. 5 and 6).
4. Policies. Approve the AML manual (art. 9), code of conduct (art. 20) and annual training plan (art. 18). Set the onboarding flows, including the remote onboarding risk analysis (art. 25). Embed RePET screening before onboarding (art. 8(a); UIF 207/2025), the PEP sworn statement (UIF 35/2023 art. 8) and the BO sworn statement (UIF 112/2021 art. 5).
5. Register with the UIF in the SRO in the month activity starts, uploading the documents listed in section 9 (UIF 50/2011 arts. 3 and 3 bis). Cure observations within 15 business days.
6. BCRA registration as a payment service provider, if applicable, under BCRA rules (unconfirmed).
7. Go live with monitoring. Run automated alerts (art. 34) and the unusual operations register (art. 35). File ROS within the deadlines in section 6.3.
8. Monthly reports. RTE between the 1st and 15th; RMTC between the 15th and the last business day, if applicable (art. 39).
9. Annual cycle. RSA between 2 January and 15 March. Self assessment and tolerance statement to UIF and BCRA before 30 April. Internal audit covering AML each year (art. 19(b)).
10. Biennial external review by a reviewer registered under UIF 67/2017, filed within 120 days of the self assessment deadline (art. 19(a)).
11. Ongoing. Refresh client files every 1, 3 or 5 years by risk (art. 30). Notify officer substitutions within 24 hours and removals within 15 days (art. 11). Notify changes in your own BOs within 30 days (UIF 112/2021 art. 7).

For an ordinary company that is not a reporting party the steps are shorter. File BO information with ARCA under Law 27.739 art. 29 and with IGJ or the local registry in registry filings (IGJ Rules art. 421). Give your banks and brokers your BO and PEP sworn statements and report BO changes within 30 days (UIF 112/2021 art. 5). Answer any UIF information request within the term set (Law 25.246 art. 14(1)).

Worked examples

All USD figures use the dolar MEP rate of ARS 1,563.90 per US$ on 23 October 2026 supplied in dólar MEP selling rate (dolarapi.com) (unconfirmed). The module value used is ARS 54,140 (UIF 95/2025) (unconfirmed).

Example 1: fine exposure for a missed suspicious operation report

Facts. A payment account provider (UIF 200/2024) sees a client receive many small transfers from unrelated payers. The funds are withdrawn the same day, totalling ARS 180,000,000 over two months. The transactions were completed between 1 March and 30 April. Alerts fired, but the analyst closed them without a reasoned decision and no ROS was filed. A UIF inspection in November finds the gap.

Step 1: classify the breach. A failure to file a ROS falls under Law 25.246 art. 24(3), not the module scale.

Step 2: apply the statutory range.

Step 3: check timing. Even if the firm had concluded in November that the transactions were suspicious, the latest permissible ROS date was 90 calendar days after each operation (UIF 200/2024 art. 36(c)(i)). The March and April operations were already out of time by the end of July. A late report is also a breach under art. 24(3) ("realización fuera de los plazos").

Step 4: add related breaches. The inspection also finds that the unusual operations register lacked the reasoned decision (art. 35(i)). The UIF could charge that as a separate infringement on the module scale.

Fines for independent breaches are added together (art. 24, after para. 5).

Step 5: director exposure. Article 24 states that if the breach was committed by a legal person, "the same sanction" is applied to the members of its administrative and management bodies, who answer jointly and severally. A three member board therefore faces personal exposure that mirrors the company's fine. How the UIF quantifies and collects this in practice (one fine shared jointly or a separate fine per director) is not stated in the sources (unconfirmed).

Step 6: mitigation levers. * Since Decree 274/2025, the UIF may reduce the ROS fine below the 1× minimum where it is not proportionate (art. 24(3), second paragraph). The decree's recitals explain that the 1× minimum produced disproportionate results in some cases. * The abbreviated procedure of UIF 90/2024 is not available for ROS charges (Annex I art. 34), and suspension on probation under art. 24 ter also excludes art. 21(b). * The limitation period is 5 years from the breach (art. 24 bis), so a 2026 omission can be charged until 2031.

Practical reading. A single missed ROS on a mid sized flow can exceed the firm's annual compliance budget (compare Example 3) by a factor of two or more, even at the statutory minimum.

Example 2: abbreviated procedure for non ROS breaches

Facts. A real estate brokerage (UIF 43/2024) is inspected. The UIF finds:

• (a) no BO identification for three corporate buyers;
• (b) partial PEP screening;
• (c) a self assessment filed late.

The firm has no prior sanctions.

Step 1: eligibility. None of the charges relates to art. 21(b), and the firm is not a recidivist, so the abbreviated procedure is open (UIF 90/2024 Annex I art. 34).

Step 2: liquidation per charge (Annex I art. 35).

The table assumes that (a) is a single charge. If the UIF raised one charge per buyer, (a) would be 90 modules (ARS 4,872,600, US$ 3,115.67) (unconfirmed).

Step 3: compare with the ordinary procedure. Three separate breaches at 15 to 2,500 modules each give a range of 45 to 7,500 modules: ARS 2,436,300 to ARS 406,050,000 (US$ 1,557.84 to US$ 259,639.36), before publication of the sanction on the UIF website.

Step 4: conditions. All board members for the period must accept within 10 days and pay. They must remediate within 3 months with a registered external reviewer, whose fee adds to the cost (unconfirmed). The result is not published (Annex I art. 33) and does not count for recidivism if there is no new breach in 5 years (art. 39).

Example 3: Cost to do it, compliance programme for a small fintech

Assumptions about the business (hypothetical). A wallet and payment account provider plans 20,000 clients in year one and 5,000 new clients a year after that. Risk mix: 5% high, 25% medium, 70% low.

Step 1: sourced workload. File refresh cycles are at most 1 year for high, 3 for medium and 5 for low risk (UIF 200/2024 art. 30).

Fixed statutory deliverables each year: 12 monthly RTE filings, 12 RMTC filings if it acquires or aggregates cards, 1 RSA, 1 self assessment and tolerance statement, 1 internal audit cycle, and an external review every 2 years.

Step 2: hypothetical unit costs. These are not sourced market prices. They are placeholders to show the arithmetic and must be replaced with real quotes (unconfirmed):

• identity verification and screening: ARS 1,500 per check (US$ 0.96);
• compliance analyst: ARS 30,000,000 fully loaded per year (US$ 19,182.81), two needed;
• external review: ARS 15,000,000 per biennial engagement (US$ 9,591.41);
• manual, methodology and set up advice: ARS 10,000,000 one off (US$ 6,394.27).

Step 3: year one.

Step 4: steady state per year.

Step 5: regulatory fees, capital and months. * Fees: no UIF registration fee appears in UIF 50/2011 (unconfirmed). No CNV registry fee is stated in RG 994/2024 for VASPs (unconfirmed). * Capital: the UIF rules impose no minimum capital. Any BCRA requirement for payment providers is outside the sources (unconfirmed). * Months: self assessment before launch; UIF registration in the launch month; first RSA in the following 2 January to 15 March window; self assessment refiled each 30 April; first external review within 120 days of the self assessment deadline in the review year.

Comparison with Example 1. The steady state budget of about ARS 83 million is less than half of the minimum statutory fine for one missed ROS of ARS 180 million.

Example 4: VASP registry threshold check

Facts. A foreign exchange platform has no ".ar" domain and no local advertising. Its Argentine users generate 12% of its global volume. It does, however, accept peso deposits through a local payment partner.

Analysis. Under CNV RG 994/2024 (Title XIV, Chapter III, art. 3), any one of the five connecting factors is enough. The 20% volume test is not met, but the local on ramp agreement (factor 2) is. The platform must register before operating unless its aggregate Argentine activity stays at or below UVA 35,000 per month (art. 1). Example: at a hypothetical UVA value of ARS 1,500, the ceiling would be ARS 52,500,000 a month, or US$ 33,569.92 (unconfirmed). Once registered, it is a reporting party under art. 20(13) and UIF 49/2024.

Practical traps

1. Compliance officer must sit on the board. Hiring an "AML officer" employee is not enough under Law 25.246 art. 21(f). The registered officer must be a board member, and every director remains jointly and unlimitedly liable.
2. The 90 day backstop. Under the 2024 rule the 24 hour clock runs from the firm's own conclusion, but the report can never be later than 90 calendar days after the operation (UIF 56/2024; UIF 200/2024 art. 36). A slow alert backlog turns into automatic lateness.
3. TF clock is different. For terrorist and proliferation financing the 24 hours run from the operation, not from the analysis (UIF 207/2025 art. 2; UIF 3/2026 art. 3), and freezing must happen before the report (UIF 207/2025 art. 3).
4. Repealed cross references. Sector resolutions still cite UIF 29/2013 (repealed by UIF 207/2025) and the old art. 20 numbering. Update manuals.
5. Do not onboard unregistered reporting parties. If your client is itself a reporting party, you may not start the relationship until it shows its UIF registration (UIF 200/2024 art. 31(b)).
6. Banks cannot demand tax returns for the transactional profile (UIF 14/2023 art. 37 as replaced by UIF 78/2025). Clients asked for them can point to this rule; banks can still use other economic and financial documents.
7. BO threshold differs from some foreign regimes. Argentina uses 10% (UIF 112/2021), plus a control test. Groups that design structures around a 25% threshold elsewhere may still have identifiable BOs in Argentina.
8. BO changes within 30 days. The client must tell each reporting party, and a reporting party must tell the UIF about its own BOs (UIF 112/2021 arts. 5 and 7). This is separate from the ARCA registry filing.
9. PEP status lasts 2 years after leaving office, and covers in laws and close business associates (UIF 35/2023 arts. 4 and 6 as amended).
10. Abbreviated procedure is a one way door. Accepting it implies admitting the breaches and needs unanimous acceptance by all board members of the period (UIF 90/2024 Annex I arts. 36 and 37).
11. Professional secrecy carve out is narrow. Lawyers, accountants and notaries escape the reporting duty only for information obtained under professional secrecy. They still have the CDD, registration and record keeping duties for covered transactions (art. 20(17)).
12. Portal names change. Older resolutions refer to uif.gov.ar and uif.gob.ar. Use the current official portal and keep evidence of submission.
13. VASP registration is not a licence. The mandatory CNV legend says so expressly (RG 994/2024, Title XIV, Chapter III, art. 5). Do not market it as authorisation.
14. Abbreviated module amounts move with the module. Liquidations are in modules, so the peso cost changes when the UIF updates the module (art. 24, last paragraph; art. 25 bis).

Recent changes

Pending changes

• Art. 24 ter probation. Its operation depends on UIF rules "to be issued" (unconfirmed).
• ARCA BO registry. Implementing rules, public access scope (Law 27.739 art. 31, last paragraph) and current filing deadlines (unconfirmed).
• CNV VASP licensing. RG 994/2024 art. 6 anticipates a licence "that may be required" (unconfirmed).
• Non profit organisations. Chapter VI of Law 25.246 (art. 34) assigns TF prevention functions over NPOs to "organisms and authorities determined by regulation" (unconfirmed).
• Sector resolutions still pending or old: art. 20(18) company and trust service providers, art. 20(19) registries other than real estate, art. 20(20) regulators, art. 20(23) sports bodies (unconfirmed).
• Simplified income tax return as a favourable factor. Law 27.826 art. 12 (BO 9 Oct 2026) instructed the UIF to issue complementary rules within 15 business days of publication; whether and when the UIF did so, and the ARCA validation service for reporting parties, are (unconfirmed).
• Module update for each budget year (art. 24, last paragraph) (unconfirmed).
• SMVM peso values for all thresholds (unconfirmed).

FAQ

1. My company is a regular trading SME in Buenos Aires. Do I have UIF obligations? Not as a reporting party, unless an activity in art. 20 applies to you. Examples are lending to the public, operating a payment service or acting as a real estate broker. You must still file BO information with ARCA (Law 27.739 art. 29) and in IGJ filings (IGJ Rules art. 421). You must give BO and PEP sworn statements to your banks and brokers and answer any UIF information request (Law 25.246 art. 14(1)).

2. What is the beneficial owner threshold in Argentina? 10% of capital or voting rights, or control by other means. If nobody qualifies, the person in charge of management or representation (UIF 112/2021 art. 2; Law 25.246 art. 4 bis).

3. How fast must a suspicious operation be reported? Money laundering: within 24 hours of concluding it is suspicious, and never later than 90 calendar days from the operation. Terrorist or proliferation financing: within 24 hours of the operation (UIF 200/2024 art. 36; UIF 207/2025 art. 2; UIF 3/2026 art. 3).

4. Can I tell the client I filed a report? No. Article 21(c) forbids disclosure, and disclosing protected information is punishable by 6 months to 3 years in prison (art. 22). Good faith reporting carries no liability (art. 18).

5. What does it cost if we miss a report? A fine of 1 to 10 times the value of the operation (art. 24(3)), which the UIF can now reduce below the minimum on proportionality grounds. The same sanction can reach directors jointly and severally (art. 24). See Example 1.

6. What is a "module" and how much is it? The unit for non ROS fines. It started at ARS 40,000 in Law 27.739 and was ARS 54,140 from UIF Resolution 95/2025 (BO 23 Jun 2025) (unconfirmed). Fines run from 15 to 2,500 modules per breach.

7. Can a foreign crypto exchange serve Argentine residents without registering? Only if none of the five connecting factors in CNV RG 994/2024 applies, or if its activity stays at or below UVA 35,000 per month. Otherwise it must register with CNV before operating and comply with UIF 49/2024.

8. Who can be the compliance officer? A member of the board, with AML training or experience, plus an alternate, both registered with the UIF (art. 21(f); UIF 200/2024 art. 11). Groups may appoint one officer who sits on every group reporting party's board (art. 13).

9. How long must records be kept? At least 10 years (art. 21(n)). Client and BO files run 10 years from the end of the relationship or the last transaction, whichever is later (UIF 14/2023 art. 17; UIF 200/2024 art. 17).

10. Is a foreign PEP always high risk? Yes under the payments and banking resolutions: foreign PEPs are listed as high risk clients requiring enhanced due diligence (UIF 200/2024 art. 29). The compliance officer must approve the relationship (UIF 14/2023 art. 12(e)).

11. What is RePET and do I have to check it? It is the Ministry of Justice register of persons and entities linked to terrorism and its financing (Decree 918/2012 arts. 23 to 32, added by Decree 489/2019). Reporting parties must screen clients and BOs before onboarding and permanently. They must freeze and report matches without delay (UIF 200/2024 art. 8; UIF 207/2025).

12. Can we settle a UIF case? For non ROS breaches, yes. The abbreviated procedure (UIF 90/2024 Annex I arts. 34 to 39) uses fixed amounts of 15, 25 or 30 modules per charge, a 3 month remediation and no public record. Suspension on probation under art. 24 ter may also apply once the UIF regulates it (unconfirmed).

13. How long does the UIF have to sanction us? Five years from the breach, interrupted by notice of the opening of proceedings (art. 24 bis).

14. A client says they adhere to the new simplified income tax return. Does that change our KYC? The law requires reporting parties to treat the adherence certificate as a favourable factor in identification and monitoring. All CDD duties remain in force under UIF rules (Law 27.799 art. 40 bis, added by Law 27.826 art. 7). The UIF's complementary rules were due within 15 business days of 9 Oct 2026 (Law 27.826 art. 12) (unconfirmed).

15. Can we appeal? Yes, directly to the National Court of Appeals in Federal Administrative Litigation, within 15 judicial business days, with suspensive effect (art. 25).

Primary sources

• Law 25.246, consolidated text (Infoleg)
• Law 27.739 (BO 15 Mar 2024)
• Decree 891/2024 (BO 10 Oct 2024)
• Decree 274/2025 (BO 16 Apr 2025)
• Decree 918/2012, consolidated
• Decree 489/2019 (BO 17 Jul 2019)
• UIF Resolution 50/2011, consolidated (registration)
• UIF Resolution 67/2017 (external reviewers)
• UIF Resolution 112/2021 (beneficial owner)
• UIF Resolution 14/2023 (banks and exchange entities)
• UIF Resolution 35/2023, consolidated (PEP)
• UIF Resolution 61/2023 (supervision procedure)
• UIF Resolution 78/2023 (capital markets)
• UIF Resolution 99/2023 (credit cooperatives and mutuals)
• UIF Resolution 126/2023 (insurance)
• UIF Resolution 169/2023 (capitalisation and savings societies)
• UIF Resolution 194/2023 (gambling)
• UIF Resolution 242/2023 (notaries)
• UIF Resolution 1/2023 (remitters, BO 8 Jan 2024)
• UIF Resolution 2/2023 (cash in transit, BO 8 Jan 2024)
• UIF Resolution 42/2024 (accountants)
• UIF Resolution 43/2024 (real estate brokers)
• UIF Resolution 48/2024 (lawyers)
• UIF Resolution 49/2024 (VASPs)
• UIF Resolution 54/2024 (art and antiques)
• UIF Resolution 55/2024 (luxury goods, jewellery, precious metals)
• UIF Resolution 56/2024 (ROS harmonisation)
• UIF Resolution 90/2024 (sanction procedure)
• UIF Resolution 110/2024 (asset regularisation regime)
• UIF Resolution 129/2024 (amends 90/2024)
• UIF Resolution 192/2024 (PEP amendments)
• UIF Resolution 195/2024 (transitional sanctions clause)
• UIF Resolution 199/2024 (amends 14/2023)
• UIF Resolution 200/2024 (payment providers, card issuers, non bank lenders)
• UIF Resolution 78/2025 (banks: profile and cash thresholds)
• UIF Resolution 95/2025 (module value)
• UIF Resolution 207/2025 (terrorist financing reports and freezing)
• UIF Resolution 3/2026 (proliferation financing)
• UIF Resolution 35/2026 (supervisor information exchange)
• UIF Resolution 93/2026 (real estate registries)
• UIF Resolution 109/2026 (amends 78/2023)
• UIF Resolution 29/2013 (repealed; historical)
• CNV General Resolution 994/2024 (VASP registry)
• CNV General Resolution 996/2024 (AML title of CNV Rules)
• Infoleg list of norms modifying or complementing Law 25.246 (BO dates)

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