Reporting Suspicious Transactions in Argentina: A Comprehensive Guide

Argentina has implemented robust measures to prevent money laundering and terrorism financing. As a result, financial institutions and other obligated entities must report suspicious transactions or activities to the relevant authorities. In this article, we will outline the necessary steps for reporting suspicious transactions in Argentina.

Conducting Customer Due Diligence (CDD)

Step 1: Verify Customer Identity

• The obligated entity must verify the identity of customers and, in some cases, their beneficial owners.
• This is a crucial step in identifying potential risks associated with a transaction or activity.

Documenting and Recording Suspicious Transactions

Step 2: Maintain Records and Supporting Documentation

• Maintain records of the suspicious transaction or activity, as well as any supporting documentation.
• These records will be essential for submitting a detailed report to the UIF.

Internal Review and Analysis

Step 3: Assess Grounds for Suspicion

• Evaluate the consistency of the transaction with the customer’s profile, source of funds, and purpose of the transaction.
• This assessment will help determine whether the transaction or activity warrants further investigation.

Reporting to the Financial Information Unit (UIF)

Step 4: Submit a Report to the UIF

• Submit a report to the UIF, which is the designated authority responsible for receiving, analyzing, and disseminating information related to suspicious transactions and SARs.
• The report should include detailed information about the suspicious transaction or activity.

Key Components of the Suspicious Activity Report (SAR)

Step 5: Include Detailed Information in the SAR

• Include detailed information about the suspicious transaction or activity, such as:
  • Date and time of the transaction
  • Amount involved
  • Customer’s name and identification details
  • Beneficial owner’s name and identification details (if applicable)
  • Source of funds and purpose of the transaction

Urgency and Timeliness

Step 6: Report Promptly and Without Delay

• Report to the UIF promptly and without delay once the suspicious transaction or activity is identified.
• Delays in reporting can compromise the effectiveness of anti-money laundering efforts.

Confidentiality and Immunity

Step 7: Confidentiality Provisions Under Argentine Law

• Reporting entities are protected by confidentiality provisions under Argentine law, and their identities are generally kept confidential to prevent potential retaliation.
• This protection ensures that obligated entities can report suspicious transactions without fear of reprisal.

Cooperation with Law Enforcement

Step 8: Cooperate with Law Enforcement Agencies

• Cooperate with law enforcement agencies and provide additional information or assistance in investigations related to the reported suspicious activity.
• Collaboration between reporting entities and law enforcement is crucial for preventing and investigating money laundering and terrorism financing.

Ongoing Monitoring

Step 9: Continue Monitoring the Situation

• Continue monitoring the situation and take any necessary actions to mitigate risks associated with the suspicious transaction or activity.
• Ongoing monitoring ensures that obligated entities can respond promptly to emerging risks and prevent further suspicious activities.