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The minimum amounts set forth to detect and report suspicious transactions were amended by the Financial Information Unit (“UIF”).
By Resolution No. 104/2016 (the “Resolution”), published yesterday in the Official Public Gazzette, UIF has amended the minimum amounts set forth for the identification and subsequent reporting of suspicious money laundering operations of clients, regular and/or occasional, of persons obligated to report.

The Resolution amended UIF’s Resolution No. 121/2011, applicable to financial entities, and UIF’s Resolution No. 229/2011, applicable to stockbrokers and stockbrokerage entities, defining “usual” clients as those carrying out transactions for an annual amount reaching or exceeding the amount of ARS 260,000  or its equivalent in other currencies; and “occasional” clients as those performing annual operations not exceeding the sum of ARS 260,000. Previously the threshold amount was ARS 60,000.

In addition, in case of cash deposits of or in excess of ARS 200,000 or its equivalent in other currencies, financial entities shall identify the depositor by requiring a valid ID.

Author

Fernando Goldaracena is a partner in Baker McKenzie's Buenos Aires Office. He heads the White Collar Crime Practice Group and is a member of the Compliance & Investigations Practice Group. Prior to joining the Firm, Fernando served as secretary of the Federal Criminal Court No. 2 of San Isidro, where he led several criminal investigations ranging from white collar crimes, public corruption and tax fraud. He is member of both the Compliance & Money Laundering and the Criminal Law Practice Groups of the City of Buenos Aires Bar Association (Colegio de Abogados de la Ciudad de Buenos Aires).

Author

Gabriel Gómez Giglio practices mainly in banking and finance law in Baker & McKenzie’s Buenos Aires office. He is a correspondent of the Journal of International Banking Law and Regulation and International Company and Commercial Law Review. He is the author of more than 20 articles and book chapters on topics related to his area of practice published in the UK, Germany and Argentina. Mr. Giglio is a law professor at the Universidad Torcuato Di Tella and member of the Buenos Aires Bar Association.