New Exceptions for Labor Assistance Funds

Resolution 109/2026 of the Financial Intelligence Unit (UIF), issued on September 17, 2026, amends UIF Resolution 78/2023, which had established the measures and procedures that reporting entities had to observe to identify, assess, monitor, manage, and mitigate the risks of money laundering, terrorist financing, and financing of the proliferation of weapons of mass destruction.

This amendment is grounded on the fact that collective investment products intended exclusively to implement the Labor Assistance Funds (FAL) have characteristics different from those that general-purpose collective investment vehicles have. This results in an objectively reduced risk profile that includes (among others):
 

1. a specific legal purpose,
2. individualized identification of contributors (employer’s tax ID and FAL ID),
3. traceability of resources,
4. channeling of most contributions through the Argentine Tax Authority (ARCA),
5. restrictions on eligible investments, and
6. the impossibility of redeeming shares.

The new article 3 bis exempts from the measures, controls, procedures, and other obligations in UIF Resolution 78/2023:
 

1. Mandatory monthly employer contributions and the returns, interest, and other income derived from the investments the fund’s manager made.
2. Voluntary contributions, donations, bequests, and any other income in the FAL, if the regulations in force prohibit redeeming shares or participation certificates. This does not apply to the cases of extinction of the employer’s individual account established in article 72 of Law 2780