Bolivia Tightens Anti-Money Laundering Net with New Public Notary Obligations

In a significant move to bolster its anti-money laundering defenses, Bolivia’s Financial Investigation Unit has issued a landmark resolution requiring public notaries to report suspicious transactions and identify the ultimate beneficiaries of real estate and corporate services.

Strengthened Regulations for Public Notaries

As of November 2018, public notaries in Bolivia are subject to strict regulations governing their services. The new rules, outlined in Administrative Resolution No. UIF/084/2018, stipulate that notaries must:

• Verify the identities of clients and employees prior to providing any services
• Screen clients against international sanctions lists, including those maintained by:
  • United Nations Security Council
  • Financial Action Task Force (FATF)
  • Organization for Economic Cooperation and Development (OECD)
  • Other recognized bodies

Transactions involving individuals or entities listed on these sanctions lists will be deemed suspicious and must be reported accordingly.

Criteria for Identifying Suspicious Transactions

The resolution sets out specific criteria for identifying suspicious transactions, including:

• Large-scale real estate purchases without apparent purpose
• Rapid succession of purchase-sale transactions
• High-value property acquisitions by individuals with no clear economic capacity to do so
• Corporate entity formations with similar names to established entities
• Creation of multiple corporations within a short timeframe

Strengthening Anti-Money Laundering Framework

These new obligations are designed to strengthen Bolivia’s anti-money laundering framework and prevent illicit activities such as:

• Terrorism financing
• Tax evasion

The Financial Investigation Unit has emphasized its commitment to working closely with public notaries to ensure effective implementation of these regulations and detect and prevent suspicious transactions.