New Reporting and Asset Freezing Regime for PF

Through Resolution 3/2026, the Financial Intelligence Unit (UIF) introduced a specific regime applicable to suspicious transactions related to the financing of the proliferation of weapons of mass destruction (PF), together with a procedure to immediately freeze funds and other assets belonging to designated persons or entities.

The new framework applies to all reporting entities listed in Law 25246 article 20, who must incorporate these requirements into their anti-money laundering, counter-terrorist financing, and proliferation financing prevention systems.

New PF Suspicious Transaction Report

Among the main changes, the Resolution introduces the Proliferation Financing Suspicious Transaction Report, which must be filed without delay in connection with completed or attempted transactions where the funds or other assets:

• are owned or controlled, directly or indirectly, by persons or entities designated by the United Nations Security Council—including regimes related to North Korea and Iran—,
• are intended to benefit or be made available to such persons or entities,
• may be linked to the offense of proliferation financing as defined in article 306, paragraph (f), of the Argentine Criminal Code.

The maximum reporting deadline is 24 hours, counted from the moment the transaction was completed or attempted to be executed.

List Screening and Asset Freezing

The Resolution also establishes the obligation to regularly and periodically screen the targeted financial sanctions lists issued by the United Nations Security Council, as well as any registers created within the Argentine jurisdiction.

Upon identifying any of the situations described above, reporting entities must immediately and without prior notice freeze the relevant funds or assets, promptly notify the UIF, and file the corresponding PF Suspicious Transaction Report.
 

Operational Duties and Sanctions

The regime sets forth specific operational obligations, including the immobilization of the affected assets, the use of the UIF’s Freezing Order Reporting system, and the prohibition of disclosing the adoption of these measures to clients or third parties (tipping-off).

Failure to comply with these obligations may result in the sanctions established in Law 25246, including fines and other administrative measures.