Anti-Money Laundering and Terrorism Financing

On January 9, 2014 the Financial Information Unit (“UIF”) issued Resolution No. 3/2014 (the "Resolution") by which it introduced certain modifications to the anti-money laundering system. In particular, (i) it reduced the timeframe for issuing the Suspicious Transaction Report (the "ROS"), (ii) amended the definition of Obliged Person of the UIF resolution applicable to independent licensed professionals whose activities are regulated by the Professional Councils in Economics Sciences (“Economic Sciences’ Professionals”), and (iii) established a new Report on Registration and Compliance.
As from the Resolution’s effective date, when an Obliged Person identifies a transaction as suspicious, it has 30 days to issue the corresponding ROS to the UIF, though the maximum timeframe is still 150 days counted as from the date the corresponding transaction has been executed. The Central Bank (BCRA), the Securities Exchange Commission (CNV), the Federal Tax Authority (AFIP), the National Superintendency of Insurance (SSN) and the Institute of Cooperatives and Social Economy (INAES), are exempted from this new 30-day timeframe.
Furthermore, the Resolution amended certain aspects of the definition of Obliged Persons of the resolution applicable to Economic Sciences Professionals, by stating that, those Economic Sciences Professionals shall be considered Obliged Persons if they perform financial statements audits and/or act as member of the supervisory committee in entities with more than AR$ 10,000,000 in assets.
The amendments listed above became effective as of January 10, 2014.
Lastly, the Resolution established new requirements that Obliged Persons must comply with when dealing with other Obliged Persons: (i) request sworn statements on compliance with anti-money laundering regulations; and (ii) request evidence of registration with the UIF); by setting forth that they are obliged to make a monthly report in connection with registration and compliance (the "RSM on Registration and Compliance") of its customers (who are Obliged Persons as well) who do not comply with any of the above mentioned requirements. The obligation to issue the RSM on Registration and Compliance will begin in March 2014. This report shall be issued monthly until the 15th day of each month, reporting those transactions carried out in the preceding calendar month.