On June 4, 2025, under Decree 353/2025, the Financial Information Unit (“UIF” after its spanish acronym) issued Resolution 78/2025 (the “Resolution”), updating the thresholds and procedures related to the prevention of Money Laundering, Terrorism Financing, and the Financing of the Proliferation of Weapons of Mass Destruction.
The new procedures and thresholds apply to the following Obligated Entities:
Banking Institutions, Currency Exchange Houses, and Agencies
Transactional Profile:
– The procedure for creating a customer’s Transactional Profile must be based on supporting documentation that demonstrates their economic, asset, and financial situation, such as pay stubs, property deeds, or banking information.
– Obligated Entities may not request tax affidavits from clients.
– The profile must be determined through a risk analysis that enables the detection of unusual or suspicious transactions.
– Cash Transactions Report: For both the Cash Transactions Report and the Cash Transactions in Currency Exchange Operations Report, the threshold requiring reporting has been raised from twenty (20) to forty (40) Minimum Living and Mobile Wages (“S.M.V.M.”after the spanish acronym).
Real Estate Registry:
– Real Estate Registries must report the registration of property sales for amounts exceeding seven hundred fifty (750) S.M.V.M.
Motor Vehicle Registry:
– An annual threshold of one hundred fifteen million pesos ($115,000,000) is set to define the Client Profile for transactions related to the purchase or sale of motor vehicles. The client’s economic, asset, and financial situation may be demonstrated through supporting documentation.
– A threshold of fifty million pesos ($50,000,000) is established for reporting vehicle acquisitions.
– The requirement to present an accountant’s certification is eliminated.
– The Motor Vehicle Registry may not request tax affidavits from clients.
– They are not required to define a Client Profile when:
*Transactions are carried out via bank transfers or personal checks from the client’s account, or when originating from loans granted by financial institutions governed by Law No. 21,526.
*Transactions are made through payment in kind, exchange, or similar methods, provided the value difference does not exceed the threshold of $115,000,000.
Public Notaries:
– Must report ownership transfers of real estate by cash purchases for amounts exceeding seven hundred fifty (750) S.M.V.M.
– The procedure for creating the customer’s Transactional Profile must be based on supporting documentation of their economic, asset, and financial condition.
– Tax affidavits may not be requested from clients.
– The profile must be determined through a risk-based analysis to detect unusual or suspicious transactions.
