Anti-Money Laundering and Terrorist Financing Information Regime for the Insurance Sector

The Argentine Superintendence of Insurance (the “SSN”, after its acronym in Spanish), as insurance regulator and in compliance with its legal duty of cooperation with the Financial Intelligence Unit (the “UIF”, after its acronym in Spanish), by Resolution No. 263 (the “Resolution”) dated August 13, 2020, improves the Risk Matrix and monitors the insurance companies’ Prevention Systems. 

In accordance with UIF Resolution No. 155/2018, the SSN is in charge of preparing the Risk Matrix on Anti-Money Laundering and Terrorist Financing (“PLA/FT”, after its acronym in Spanish), which is confidential and should reflect the modifications produced in the insurance market, in order to be an effective instrument for an accurate and efficient supervision concerning PLA/FT.

For the purposes of the Resolution, the definitions and provisions set forth in UIF Resolution No. 28/2018 and/or those which modify, complete or replace it in the future must be taken into account, by means of which general guidelines were set forth for the Risk Management of PLA/FT, and that should be complied and applied by the Obliged Subjects in the insurance sector.

In addition, the SSN approved the “Informative Statement – PLA/FT System for the insurance market” form, and detailed the information that companies should provide through the online platform of “Paperwork at Distance” (the “TAD”, after its Spanish acronym) by entering into “Informative Statement - PLA/FT System for the insurance market” in the https://tramitesadistancia.gob.ar website.

Henceforth, insurance companies should submit an affidavit every six months with information on their Prevention Systems for Laundering and Terrorist Financing and compliance with their legal obligations. The information as of December 31, should be submitted between January 1 and 15, and that corresponding to June 30 should be submitted between July 1 and 15. For this one time, and within a period of 15 days from the effective date of the Resolution, the Statement should be submitted with the corresponding information as of June 30, 2020.

The implementation of this regime does not release the entities from complying with information requirements made during in situ or extra situ supervision procedures, and violations to these requirements will be considered an irregular conduct of insurance activity.