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In brief

On 31 August 2023, the Financial Information Unit (UIF, for its Spanish acronym) issued Resolution UIF No. 169/2023 (“Resolution“), by which new guidelines were established for the management of money laundering and terrorist financing risks and minimum compliance for obliged entities of the sector (companies that carry out capitalization and savings operations) in order to manage procedures of control for risks generated by possible money laundering and terrorist financing actions by third parties. The Resolution will become effective on 1 November 2023.

In depth

On 31 August 2023, the UIF issued the Resolution, which regulates the mechanisms to be implemented by capitalization, savings, savings and loan, economy, capital formation, or other similar or equivalent determination companies that require in any form money or securities from the public with the promise of awarding or delivery of goods, services or future benefits (“Obliged Entities“) in order to avoid or prevent money laundering and financing of terrorism (ML/FT), with a Risk Based Approach (RBA), in accordance with the recommendations of the Financial Action Task Force (FATF).

The Resolution establishes parameters that Obliged Entities must take into account when adopting and applying policies, procedures and controls for the identification, evaluation, monitoring, management and effective mitigation of ML/FT risks to which they are exposed. The Resolution adopts the RBA in accordance with FATF recommendations and international standards, which led to the updating of other regulations in the field.

For this purpose, the Resolution entrusts Obliged Entities to review the National ML/FT Risk Assessments and the documents issued by the authorities to the sector, according to the risks of the specific Obliged Entity or its industry. 

In addition, the Resolution incorporates indicative warning signals for the Obliged Entities so that they can carry out the corresponding analysis and determine more efficiently whether a Suspicious Transaction Report (STR) should be filed. 

The Resolution will become effective on 1 November 2023 — the date on which Resolution UIF No. 50/13 will be repealed.

Click here to read the Spanish version.


Gabriel Gomez-Giglio is partner at Baker McKenzie’s Buenos Aires office, chair of the Latin America Banking & Finance Practice of Baker McKenzie and a member of the Global Steering Committee of the Firm’s Financial Institutions Industry Group. He advises clients on a variety of general commercial issues. His practice focuses on the areas of transactional and regulatory matters, including but not limited to multinational financial transactions, commercial agreements and mergers and acquisitions. Gabriel is a member of the Board and Adjunct Professor of Law at Universidad Torcuato Di Tella and a visiting professor with the Centre for Commercial Law Studies, Queen Mary College, University of London.


Jeronimo Argonz is an Attorney at law in Baker McKenzie, Buenos Aires office.


Nicolás Servente is an Associate in Baker McKenzie Buenos Aires office.

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