On June 4, 2025, Resolution 78/2025 (the “Resolution”) was published in the Official Gazette by the Financial Information Unit (“UIF” after its spanish acronym), aiming to reformulate reporting criteria and client profiling for financial institutions, motor vehicle and real estate registries, and public notaries. The goal is to reinforce a risk-based approach and eliminate excessive formal requirements, in compliance with Decree 353/2025 (the “Decree”).
1. Real Estate Transactions
The Decree established that real estate purchase agreements exceeding 750 Minimum Living and Mobile Wages (“S.M.V.M.” after spanish acronym) must be subject to analysis by Obligated Entities, in accordance with the amendment to Article 12, subsection 2 of UIF Resolution 70/2011. This requires assessing the origin and destination of the funds to prevent activities related to money laundering or terrorist financing.
Furthermore, all cash transfers related to real estate purchases exceeding 750 SMVM must be reported to the UIF.
2. Motor Vehicle Transactions
Obligated Entities in the motor vehicle sector must define a Client Profile for individuals or legal entities conducting annual transactions equal to or greater than ARS $115,000,000, as set out in Article 16 of UIF Resolution 127/2012.
This obligation does not apply when transactions are conducted via electronic means such as bank transfers, personal checks, or loans granted by financial institutions regulated under Law 21.526, provided the funds come from accounts in the client’s name.
Additionally, when the difference in value between the traded-in and new vehicle is below the minimum threshold, the client profile is not required.
Obligated Entities may not request tax affidavits from clients, nor require accounting certifications.
The monetary thresholds for these obligations will be automatically updated every six months (January and July) based on the Automotive Sector Price Index published by the Association of Automotive Dealers of the Argentine Republic (“ACARA” after its spanish acronym).
For relevant transaction reporting, a new threshold of ARS $50,000,000 is established, also subject to automatic semiannual updates. As a one-time measure, the automatic update is suspended until January 2026.
3. Transactional Profile
The rules for building a client’s transactional profile have been amended, replacing Article 37 of UIF Resolution 14/2023 and Article 24 of UIF Resolution 242/2023.
The profile must be developed in advance of the commercial or professional relationship, based on the economic and financial information provided or gathered by the Obligated Entity, without requiring tax affidavits.
This profile is essential for identifying unusual or suspicious operations potentially linked to illicit activities.
4. Cash Transactions
The obligation to identify individuals making cash deposits equal to or exceeding 40 SMVM is reinforced, with a requirement to record whether they are acting on their own behalf or on behalf of a third party.
Deposits made using previously issued identification methods, such as magnetic cards, are exempted.
Additionally, enhanced due diligence measures are promoted when the risk analysis is justified.
5. Systematic Transaction Reports
Subsections (a) and (b) of Article 44 of UIF Resolution 14/2023 are amended to state that any cash transaction, in local or foreign currency, equal to or greater than 40 SMVM, must be reported as a Cash Transaction Report (“RTE” after its spanish acronym).
This same threshold applies to foreign exchange cash transactions, which must be reported under the category RTE for Foreign Exchange Operations (“RTEOC”, after its spanish acronym).
6. Obligations for Public Notaries
Public notaries, due to their role in high-impact legal transactions, have specific obligations for the prevention of money laundering and terrorist financing.
They must implement Due Diligence measures to identify clients and verify the legitimacy of funds involved in the transactions they oversee, especially in real estate sales and corporate acts.
They are required to report to the UIF any suspicious or unusual transaction exceeding established thresholds, such as cash transfers over 750 SMVM, or transactions that reasonably raise doubts about their legality.
Additionally, they must retain supporting documentation for client identification and transactions for at least five years, to facilitate potential audits or inspections.
This regulation entered into force on June 5, 2024.
