The UAF replaces its anti-money laundering regulations with new obligations and biennial auditing

The Financial Analysis Unit (UAF) approved Resolution No. UAF-N-027-2026 on November 3, 2026, which replaces the two anti-money laundering regulations in effect since 2019 and establishes new obligations for due diligence, identification of the beneficial owner, monitoring, and external auditing every two years. The regulation was published in La Gaceta, Official Gazette No. 203 on November 5, 2026, under registration Reg. 2026-01096 on page 11123, and entered into force on that same day.

The instrument, signed by the director of the UAF, Denis Membreño Rivas, was issued based on articles 5, 11, and 12 of Law No. 976, article 30 of Law No. 977 —Law against Money Laundering, Terrorism Financing, and the Financing of the Proliferation of Weapons of Mass Destruction— and Presidential Agreement No. 170-2012, published in La Gaceta, Official Gazette No. 180 on September 21, 2012.

The resolution expressly repeals Resolution No. UAF-N-019-2019, published in La Gaceta, Official Gazette No. 64 on April 1, 2019, and Resolution No. UAF-N-020-2019, published in La Gaceta, Official Gazette No. 67 on April 4, 2019. According to the recitals, both required being “updated, harmonized, and consolidated” due to reforms in the national legal framework, the evolution of risks, and applicable international standards.

A single regulatory body for nine activities

The scope of application covers natural or legal persons who, according to Law No. 977, have the status of Obligated Entities under the regulation and supervision of the UAF in the following activities:

• Financial institutions: issuance and administration of payment methods; remittance service providers and similar; currency purchase/sale and/or exchange providers constituted as legal entities.
• Designated non-financial activities and professions: casinos and gaming halls; real estate brokers; dealers in precious metals and/or precious stones; dealers and distributors of new and/or used vehicles.

All must establish, implement, maintain, and update an AML/CFT/CPF Prevention Program with a risk-based approach, which comprises eleven minimum components, including the designation of the Compliance Officer, the AML/CFT/CPF Manual, individual risk assessment, and independent external auditing. The senior management or highest authority of the Obligated Entity remains responsible for ensuring its implementation and effectiveness.

Deadlines and reports to SIREL

The regulation establishes an annual and biennial submission calendar, all via the Online Reporting System (SIREL):

• Annual Compliance Officer Report (IAOC): no later than January 31 of each year, with three business days to remedy a rejection.
• Individual Risk Assessment (EIR): every two years, with the report submitted no later than October 31 of the corresponding year and seven business days to remedy.
• External audit report: no later than July 31 of the year in which the audit is conducted, required at least once every two years.
• Comprehensive Customer and Contractor Profile (PIC): annual update for high risk, every two years for medium risk, and every three years for low risk.
• Prevention training: at least once a year, including agents of remittance providers.
• Retention of records and analysis files: minimum of five years.

Due diligence thresholds and sanctions

Due diligence measures are triggered, among other scenarios, at these amounts:

• Financial institutions: occasional transaction equal to or greater than USD 10,000, and remittance operations regardless of their value.
• Casinos and gaming halls, and dealers in precious metals or precious stones: USD 1,000.
• Dealers and distributors of new and/or used vehicles: USD 5,000.
• Any operation with suspicion of ML/TF/PF, without any threshold.

Identity verification must be completed before or during the start of the relationship; only exceptionally afterwards, with a limit of ten business days. Article 60 warns that “partial or total non-compliance” with the regulations “shall be punishable” and allows the UAF to sanction the titular and/or alternate Compliance Officer, senior management or the highest authority, and/or the Obligated Entity, pursuant to Article 17 of Law No. 976, Article 36 of Law No. 977, and Chapter V of Decree No. 14-2018.

The impact is immediate for banks, financial companies, remittance providers, exchange houses, casinos, real estate agencies, and metal and vehicle businesses, which from this publication operate under a single compliance standard and are exposed to administrative sanctions for failures in due diligence, beneficial ownership, and reporting of suspicious operations.

Source: La Gaceta, Official Gazette No. 203 of November 5, 2026, Section I, p. 11123 (official reference: Resolution No. UAF-N-027-2026, Reg. 2026-01096).