Newsletters

2026-02-10

New Regulation to the Anti-Money Laundering Law: A Brief Analysis of What Is Coming

The Official Gazette dated February 2, 2026 published Executive Decree No. 298, which contains the General Regulation to the Organic Law on the Prevention, Detection, and Combat of Money Laundering and the Financing of Other Crimes.

This regulatory framework adopts an approach fully aligned with FATF standards and strengthens the national prevention system through a risk-based model, more robust interinstitutional coordination, and a stricter sanctioning regime for obligated entities in both the financial and non-financial sectors.

The Regulation tightens due diligence obligations applicable to Politically Exposed Persons (PEPs), extends controls to their relatives and close associates, and reinforces the functions and responsibilities of the Compliance Officer. It also empowers the UAFE to order the temporary administrative freezing of funds for up to 72 hours, subject to judicial control. The text consolidates a preventive approach that requires not only the reporting of suspicious transactions, but also the demonstration of reasonable analysis, the implementation of ongoing monitoring, and adequate risk management, with special emphasis on the identification of the ultimate beneficial owner.

Implementation will be carried out progressively and will depend on the issuance of secondary regulations, technical guidelines, and technological updates by the UAFE, the SRI, and sectoral supervisory authorities, expected within the next 30, 60, and 90 days. We recommend that obligated entities initiate impact assessments, update their internal manuals, and strengthen their compliance systems in order to mitigate legal, financial, and reputational risks. Additionally, the SRI will need to update regulations concerning the beneficial ownership registry.

We remain at your disposal to assist with impact assessments, training, and implementation of this highly relevant regulation.

This document is a summary of the referenced Resolutions and contains information that we consider relevant; it does not necessarily reflect the opinion of Robalino® and therefore cannot be considered as legal advice. Should you require further information regarding its content, please do not hesitate to contact us at unidadtributaria@robalinolaw.com.