The Financial Intelligence Unit (Unidad de Información Financiera, “UIF”) issued Resolution 200/2024, establishing minimum requirements for risk prevention in money laundering applicable to Payment and/or Collection Service Providers.
On December 19, 2024, the UIF issued Resolution 200/2024 (the “Resolution”), setting forth minimum standards for the identification, evaluation, monitoring, management, and mitigation of risks related to money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction. These standards apply to issuers of cards, operators and providers of payment and/or collection services, and non-financial credit providers (the “Obligated Entities”).
Under the Resolution, the following entities are classified as Obligated Entities:
i. Issuers: Entities that issue credit cards, prepaid cards, purchase cards, and traveler’s checks.
ii. Operators and Payment and/or Collection Service Providers: Legal entities that, while not financial institutions, engage in any of the following activities:
a. Collection Service Providers: Entities offering tax and/or utility collection services on behalf of third parties through agent networks, using cash and/or payment instruments.
b. Payment Service Providers Offering Payment Accounts (“PSPCP”): Entities that provide payment account services to facilitate the execution of debits and credits within a payment system.
c. Acceptors: Entities that integrate merchants into transfer payment systems for the purpose of facilitating payment initiation mechanisms, transmitting payment order information to system administrators or other participants and, when authorized, confirming transactions.
d. Acquirers: Entities that integrate merchants into card payment systems for the purpose of facilitating payment initiation mechanisms, transmitting payment order information to system administrators or other participants and, when authorized, confirming transactions.
e. Aggregators or Sub-Acquirers: Entities that contract with Acquirers to offer clients a platform or system for processing and/or settling card payments through various payment methods, in both face-to-face and non-face-to-face payment contexts.
iii. Non-Financial Credit Providers: Legal entities that, while not financial institutions, offer credit to the general public on a regular basis, as defined by the Argentine Central Bank’s regulations.
The Resolution exempts the following entities from being classified as Obligated Entities: (i) Issuers of cards for the Single Electronic Ticketing System, (ii) Issuers of cards exclusively for purchasing consumable goods within the issuer’s commercial premises, (iii) Issuers of cards exclusively for fuel and lubricant purchases, and (iv) Payment Initiators (PSI) that solely transmit valid payment instructions at a client’s request to a payment account provider or payment instrument issuer.
The Resolution specifies the clients for each category of Obligated Entities as follows:
a. Issuers: (i) cardholders, (ii) holders of traveler’s checks, and (iii) merchants accepting traveler’s check transactions.
b. Acceptors, Acquirers, Aggregators, or Sub-Acquirers: Merchants.
c. PSPCPs: Payment account holders.
d. Collection Service Providers: Natural or legal persons, or other legal structures, on whose behalf collections are made.
e. Non-Financial Credit Providers: Borrowers.
The Resolution imposes the following reporting obligations on Obligated Entities:
i. Monthly Credit-Card Report (RMTC): Applicable only to Aggregators/Sub-Acquirers and credit-card Issuers.
ii. Monthly Cash Transaction Report (RTE): Applicable to all Obligated Entities.
iii. Annual Systematic Report (RSA): Applicable to all Obligated Entities.
Obligated Entities must implement or adjust their policies and procedures by May 1, 2025, to comply with the Resolution’s requirements. Although the Resolution repeals Resolution 76/2019, Obligated Entities already registered with the UIF must comply with the applicable reporting obligations during 2025, that is: (i) Risk Self-Assessment Report, (ii) Risk-appetite Statement, (iii) Internal Audit and Independent External Review, and (iv) Systematic Reporting.
Finally, entities engaged in any of the activities listed in the Resolution and registering as Obligated Entities as of the effective date of the Resolution must submit:
i. The first Risk Self-Assessment Report and Risk-Appetite Statement by April 30, 2026.
ii. The first Independent External Review Report by August 31, 2026.
iii. The first Monthly Systematic Reports, starting in May 2025.
iv. The first Annual Systematic Report, between January 2 and March 15, 2026.
