Financial Information Unit Amended List of Individuals Considered Politically Exposed Persons

The Financial Information Unit (“UIF”) issued UIF Resolution No. 15/2019 (the “Resolution”), published in the Official Gazette on February 25, 2019, with the purpose of clarifying the extent of the list of individuals to be considered Politically Exposed Persons (“PEP”) under UIF Resolution No. 134/2018.

In sum, the Resolution has amended UIF Resolution No. 134/2018 to limit the characterization as PEPs to those individuals who control or deal with public funds on a usual basis and can dispose of such funds. It has also limited consanguinity and affinity from the 3rd to the 2nd degree.

Likewise, the UIF resolved that individuals who are members of the management and administration bodies of business chambers will only be considered PEPs to the extent that they, by reason of their role:

1. Have administrative, decision-making, control or capacity to dispose of funds provided by the national, provincial municipal or the City of Buenos Aires’s public sectors; or
2. Carry out for-profit activities, either for the chamber or its parties that involve dealing, acting as intermediary or hiring on a usual basis with the national, provincial, municipal or the City of Buenos Aires’s state.

Furthermore, the UIF made other amendments to the list of PEPs. The UIF restricted the categorization as PEPs to individuals who have administrative, decision-making, control or capacity to dispose in private entities in those cases in which they receive public funding destined for third parties and have control and capacity to dispose of  such funds.

Finally, the extent of UIF Resolution No. 134/2018 has been limited, and the degree of consanguinity and affinity that determines a person’s consideration as PEP has been limited from the 3rd to the 2nd degree.

For more information on the prior regime, please view our article on UIF Resolution No. 134/2018, dated November 28, 2018.