New Registration Procedure For Non-Regulated Subjects With The Secretary For The Prevention Of Money Laundering

Through a new resolution (Resolution 375, August 17, 2016), the Secretary for the Prevention of Money Laundering (Secretaría de Prevención de Lavado de Dinero, or "SEPRELAD") modified the procedure and information requirements for subjects that are obligated to register with SEPRELAD but are not regulated by a specific government entity, such as the Central Bank or National Stock Commission ("Non-regulated Subjects").

Non-regulated Subjects include (1) national and international non-profit organizations; (2) real estate agents; (3) pawn shops; (4) jewel, metal and precious stones merchants; (5) coin and stamp collectors; (6) art dealers; (7) importers and sellers of motor vehicles; (8) providers of safe deposit boxes; (9) cash transport service providers; and (10) money transfer service providers.

The new procedure extends the time period to present the documents necessary to register from 5 to 10 days, and creates a registry certificate that SEPRELAD issues upon the conclusion of the process.

Under the new procedure, Non-regulated Subjects must first register through the online system. Then, during the next 10 days, they must present to SEPRELAD all documentation required to support the online application. This documentation includes: (1) corporate bylaws (for entities) or national identification card or passport (for individuals); (2) tax registration; (3) record of the last appointment of authorities; (4) commercial license issued by the relevant municipal authority; and (5) a sworn declaration regarding the financial intermediaries with which it does business.

SEPRELAD is a governmental entity that pertains to the Executive branch. It is responsible for enforcing compliance with anti-money laundering norms and has the authority to initiate and conduct investigations into potential violations, and refer cases to the State Prosecutor. Noncompliance with anti-money laundering norms may result in administrative warnings or fines, and may constitute grounds for the initiation of an investigation.

Abbreviated KYC procedure for certain natural person securities investors

Through a new resolution (Resolution 427...