RISK AND VIOLATIONS ASSESSMENT AND SANCTIONS PROCEDURE FOR APNFD

The Authority for the Supervision of Companies (AEMP) issued Administrative Resolutions to regulate the procedures for determining administrative sanctions applicable to Designated Non‑Financial Professional Activities (APNFD), detailed below:

1. Administrative Resolution RA/AEMP/DJ Nº 13/2026 – March 4th, 2026

Approves the Regulation on the Application of Sanctions for Administrative Infractions applicable to DNFBPs registered with the UIF that carry out real estate, legal or juridical, and accounting activities, whereby the ‘Obligated Subjects’ are the natural or legal persons engaged in the following activities:

• Real estate companies dedicated to the purchase/sale of real estate.

• Legal or juridical firms and/or accounting firms that carry out for their clients and/or advise their clients on the purchase/sale of real estate, and the administration of assets, accounts, or corporate structures.

This Regulation establishes the sanction associated with each type of infraction, as well as the types of sanctions.

2. Administrative Resolution RA/AEMP/DJ Nº16/2026 – March 5, 2026

Approves the Risk and Sanctions Guide applicable to companies and to legal and natural persons engaged in real estate, legal or juridical, and accounting activities within the framework of DNFBPs, and establishes a standardized methodology to identify, analyze, and assess the risks of Money Laundering, Terrorist Financing, and Financing of Weapons of Mass Destruction. It also provides guidelines for the development of risk matrices and for determining sanctions based on technical criteria.

3. Administrative Resolution RA/AEMP/DJ Nº18/2026 – March 5, 2026

Approves the new Supervision Manual for Obligated Subjects engaged in DNFBP activities, aimed at establishing guidelines for identifying, assessing, and mitigating the risks of Money Laundering, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction, implementing a Risk Based Approach (RBA) in accordance with international standards, UIF regulations, and applicable legislation. It also regulates the mechanisms for verifying compliance with Remedial Measures, the handling of audits, the execution of initial, regular, and special supervision processes, and the coordination of the entire technical operational process to ensure supervision that is efficient, consistent, and proportional to the level of risk identified for each Obligated Subject.

With the issuance of the above Administrative Resolutions, the following are repealed:

• Internal Administrative Resolution RA/AEMP/DJ/Nº042/2024 of March 27, 2024.
• Internal Administrative Resolution RA/AEMP/DJ Nº025/2023 of December 8, 2023.

All the aforementioned Administrative Resolutions have been in force since their publication.

 

Contacts and further information
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