New Framework for Preventing Terrorist Financing

Regulatory modernization and international alignment

The Argentine Financial Intelligence Unit (UIF) issued UIF Resolution 207/2025 on November 3, 2025, which approves a new framework to prevent and detect terrorist financing, replacing the regulatory regime that had been in place since 2013. This new Resolution expressly repeals the former framework and updates reporting and asset-freezing procedures in line with the recommendations of the Financial Action Task Force (FATF).

The reform seeks to strengthen the response of both the financial and non-financial sectors to risks related to terrorism and proliferation of mass weapons, by harmonizing criteria and enhancing interinstitutional cooperation.


24-hour reporting obligation and expanded definition of assets

Among its key changes, the new framework establishes a maximum 24-hour deadline to report suspicious terrorist financing transactions, counted from the day a completed or attempted transaction has been detected.
The regulation also replaces the traditional reference to “assets or money” with the broader concept of “funds or other assets,” in accordance with international standards, thus expressly incorporating notions of direct or indirect ownership and joint control.
Entities bound to comply with the regulation must also verify transactions to see if there are matches with the Public Registry of Persons and Entities Linked to Terrorist Acts and Their Financing (REPET), together with designations issued by the United Nations Security Council and those adopted by the Argentine Executive Branch pursuant to Decree 918/2012.


Immediate freezing without prior intervention

The new regime introduces a more streamlined procedure for the preventive freezing of funds or assets. Accordingly, where a transaction involves individuals or entities designated by the United Nations or the Executive Branch, reporting entities must immediately freeze the funds or assets, without prior notice to or intervention of the affected party. At the same time, they must notify the UIF.
Under the previous framework, asset-freezing procedures were more fragmented and relied primarily on general cross-references to Decree 918/2012.

Unified obligations and operational simplification

The updated framework standardizes the obligations applicable to all reporting entities under article 20 of Law 25246, thus eliminating the sector-specific distinctions that previously applied to financial institutions, insurers, notaries public, registries, and non-profit organizations, among others.

Going forward, all reporting entities must:
•    Screen their client and transaction databases upon receipt of a freezing order.
•    Immobilize the relevant funds or assets the corresponding individuals or entities hold.
•    Report the results within 24 hours, even when no assets are identified.
•    Use the electronic Freezing Order Report system.
•    Maintain strict confidentiality, refraining from informing clients of the grounds for the measure.

Duration of measures and exceptions

Asset-freezing measures will remain in effect for as long as the underlying international or domestic order remains in force, or until judicial revocation. In cases not based on formal orders, the measure may be imposed for up to six months, renewable once for another six months.
The regulation preserves the exception applicable to insurers and reinsurers in connection with mandatory insurance, allowing payments to bona fide third parties not subject to freezing orders.