On November 3, 2025, through UIF Resolution No. 207/2025 (the “Resolution”), the Financial Information Unit (“UIF”) enacted a comprehensive update of the regime applicable to the Reporting of Suspicious Transactions Related to Terrorist Financing (“TFR”) and the administrative freezing of assets or other property, expressly repealing UIF Resolution No. 29/2013.
The measure was issued pursuant to the powers conferred by Laws No. 25,246 and 26,734 and their implementing regulations, and responds to the need to align local regulations with the international standards of the Financial Action Task Force (FATF), in particular those set forth in Recommendation 6, as well as with the conclusions of the most recent Mutual Evaluation conducted on the Republic of Argentina.
Among the core aspects of the reform is the redefinition and systematization of the circumstances that trigger the obligation to report suspicious terrorist financing transactions, incorporating clear criteria related to direct or indirect ownership, control, beneficial ownership, and acting on behalf of or under the direction of natural persons, legal entities, or organizations designated by the United Nations Security Council or by the competent bodies of the National Executive Branch, in accordance with the applicable regime. Likewise, the obligation to consult and verify the Public Registry of Persons and Entities Linked to Acts of Terrorism and Their Financing (“REPET”) is maintained and strengthened.
As a significant new feature, the Resolution specifies the deadlines and modalities for Terrorist Financing Reports, establishing that obligated entities must submit the TFR within twenty-four (24) hours of the transaction being carried out or attempted. It also allows for advance communication by any means when necessary and provides for immediate judicial intervention in exceptional cases.
With respect to the administrative freezing of assets or other property, the regulation more clearly distinguishes between cases in which the freezing must be applied immediately by obligated entities, prior to the filing of a report, and those in which the freezing is ordered directly by the UIF through a reasoned resolution. It also details the operational obligations following notification of the measure, including the cross-checking of client databases, the immobilization of present and future assets, the mandatory use of the Freezing Order Reporting System, and the duty of confidentiality vis-à-vis clients and third parties.
Another relevant addition is the express regulation of the duration of the administrative freezing, distinguishing between cases involving persons or entities designated on international lists—where the measure remains in effect as long as the designation subsists—and those based on alleged links to terrorist financing offenses, in which case the freezing is ordered for a maximum period of six (6) months, renewable once.
This Resolution reaffirms the applicable sanctions regime in the event of non-compliance with the established obligations and provides that it shall enter into force upon its publication in the Official Gazette, thereby consolidating an updated, more precise regulatory framework aligned with the international commitments undertaken by the Argentine State in the prevention and suppression of terrorist financing.
This regulation entered into force on November 4, 2025.
