UIF Amended Minimum Thresholds for Certain Activities Subject to Oversight

The Financial Intelligence Unit (the “UIF”, after its acronym in Spanish) issued UIF Resolution No. 117/2019 (the “Resolution”) which was published in the Official Gazette on November 19, 2019. The Resolution updates the minimum thresholds upon which reporting entities listed in Article 20 of Law No. 25,246, as amended and restated, are required to carry out reinforced control and due diligence requirements established by the applicable anti money laundering and terrorism financing regulations.

This measure aims to “contribute to an efficient prevention of money laundering and terrorism financing” from a risk based approach, in accordance to the international standards promoted by the Financial Action Task Force (FATF), as established in the foreword of the Resolution.

The recitals of the Resolution highlight the fact that the latest update to the minimum thresholds was implemented more than two years ago by UIF Resolution No. 130/2018 and that, given the time elapsed and the variation of prices in the economy, an update to such thresholds was necessary.

Consequently, the Resolution updated the minimum thresholds contained in UIF Resolutions No. 21/2011, 28/2011, 30/2011, 65/2011, 70/2011, 199/2011, 11/2012, 16/2012, 17/2012, 18/2012, 22/2012, 23/2012, 32/2012, 66/2012, 140/2012, 50/2013, 30/2017, 21/2018 y 28/2018.

Likewise, the Resolution includes means of payment such as personal checks and payments made through the financial system as exceptions to the determination of client profiles in the regulations applicable to dealerships and resellers.