RISK AND VIOLATIONS ASSESSMENT AND SANCTIONS PROCEDURE REGARDING BENEFICIAL OWNER INFORMATION AND BEARER SHAREHOLDERS

The Authority for the Supervision of Companies (AEMP) issued the following Administrative Resolutions:

1. RA/AEMP/DJ Nº14/2026 – March 4, 2026

Approves the Regulation on Sanctions and Infractions related to Final Beneficiary (FB) Information for noncompliance regarding the registration, updating, accuracy, and consistency of FB information before the Plurinational Service of the Registry of Commerce (SEPREC).

2. RA/AEMP/DJ Nº15/2026 – March 4, 2026

Approves the Regulation on the Submission of Information by Bearer Shareholders (TAP) to the AEMP by Corporations (Sociedades Anónimas) and Partnerships Limited by Shares (Sociedades en Comandita por Acciones) that issue or maintain bearer shares, establishing sanctions for the following infractions:

• Failure to submit the Sworn Statement containing TAP information.
• Late submission of the Sworn Statement—whether at the time of incorporation, due to changes in holder, transfers, new issuances, or capital increases or reductions.
• Submission of incorrect, inaccurate, or incomplete information in the Sworn Statement.
• Noncompliance with AEMP instructions during verification processes.
• Suspension or cancellation of the commercial registration: Applicable in cases of repeated Maximum-level violations.

A similar Sanctioning Procedure is established for both Regulations.

3. RA/AEMP/DJ Nº17/2026 – March 5, 2026

Approves the Risk Management Guide and the Sanctions Regime for FB and TAP, establishing technical procedures to identify, measure, and manage risks related to Money Laundering, Terrorist Financing, and Financing of Weapons of Mass Destruction. It also provides guidelines to standardize the application of the sanctions regime; develop risk matrices that allow the assessment of each company’s exposure and reduce discretion in sanctioning decisions.
With the issuance of the above Administrative Resolutions, the following are repealed:
• Internal Administrative Resolution RA/AEMP/Nº093/2024 of August 29, 2024.
• Internal Administrative Resolution RA/AEMP/Nº110/2023 of April 13, 2023.
• Internal Administrative Resolution Nº26/2024 of November 27, 2024.
• Administrative Resolution RA/AEMP/Nº116/2023 of April 13, 2023.

All the aforementioned Administrative Resolutions are in force as of their publication.

Contacts and further information
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