Argentina's Unidad de Información Financiera (Financial Intelligence Unit, known as the UIF) has issued a package of updated anti-money laundering rules that took effect in early 2025. The changes tighten know-your-customer standards, expand the range of obligated entities, and introduce stricter beneficial owner disclosure requirements. International companies operating in Argentina – or accessing Argentine banking relationships – face meaningful new obligations under this regime. Failing to act within the compliance window carries the risk of account suspension, denial of credit facilities, and formal regulatory sanctions.
Argentina's updated AML rules, effective from early 2025, require all designated obligated entities to refresh KYC files. Register beneficial owner information with the UIF. Additionally, adopt an internal prevention programme within 90 days of the rules entering force. Companies that conduct transactions above defined monetary thresholds must report suspicious activity and apply enhanced due diligence measures. Non-compliance can result in administrative penalties, restrictions on bank account opening, and barriers to correspondent banking relationships.
This alert explains what changed, which business categories are affected, and the immediate steps international companies should take to meet their compliance obligations under Argentine anti-money laundering legislation.
What changed and when it took effect
Argentina's anti-money laundering legislation has been substantially updated through a series of UIF resolutions published in late 2024 and binding from January 2025. The core changes fall into three areas.
First, the rules extend the list of sujetos obligados (obligated subjects under Argentine AML law). The new definitions capture a wider set of financial intermediaries, asset managers, virtual asset service providers, and non-financial businesses that handle significant volumes of cash or high-value assets. Companies previously outside the UIF's direct supervisory reach may now find themselves formally obligated.
Second, beneficial owner disclosure requirements have been strengthened. Any legal entity that qualifies as an obligated subject must identify and register its beneficial owner. defined as the natural person who ultimately holds or controls a participation of a defined size. Alternatively. Who exercises effective control by other means. This applies regardless of the ownership chain's length or the jurisdictions involved. Argentine corporate legislation already required beneficial ownership registers at the commercial registry level; the 2025 updates align UIF obligations more closely with that registry, creating a unified disclosure standard.
Third, enhanced due diligence triggers have been revised. The threshold criteria that activate heightened scrutiny in KYC processes have been updated to reflect current monetary values. Transactions above these revised thresholds – and relationships with clients classified as higher risk – require documented enhanced due diligence before a bank account opening is approved or a credit facility is extended. The UIF has also clarified expectations for correspondent banking relationships, requiring Argentine entities to apply proportionate due diligence to their foreign counterparties.
For companies accessing Argentine capital markets, these changes interact with parallel updates to securities regulation. Our analysis of capital markets advisory in Argentina sets out how AML obligations intersect with securities compliance for issuers and investors.
Which companies are affected and the compliance deadline
The updated rules affect a broad range of entities. The following categories face direct obligations under the 2025 regime:
- Banks, payment service providers, and other financial institutions licensed in Argentina
- Virtual asset service providers registered or operating in the Argentine market
- Real estate brokers, notaries, and professionals involved in high-value asset transfers
- Accounting firms, tax advisers, and legal professionals when acting as formation agents or nominee service providers
- Non-financial businesses – including trading companies and distributors – when transactions exceed the revised monetary thresholds
Foreign companies with Argentine subsidiaries, branches, or registered representative offices fall within the scope of the rules. The subsidiary or branch is treated as the obligated subject; its foreign parent's ownership structure must be disclosed as part of the beneficial owner registration.
The compliance deadline for updating existing KYC files, registering beneficial owners, and adopting an internal AML prevention programme is 90 days from the effective date of each relevant resolution. For the January 2025 tranche, that deadline fell in early April 2025. Companies that had not yet completed their review by that date are already exposed to supervisory risk. Those in subsequent tranches should treat their individual deadlines as firm.
To receive an expert assessment of your company's AML exposure in Argentina, contact us at info@ferrazwhitmore.com.
Immediate actions for international companies
Companies with Argentine operations or banking relationships should act on the following points without delay.
Review your entity classification. Confirm whether your Argentine subsidiary, branch, or local counterparty qualifies as an obligated subject under the expanded definitions. The classification is not always obvious for holding entities or intermediate structures. Engaging a lawyer in Argentina with experience in UIF regulation is the most reliable way to confirm your status.
Update KYC files and beneficial owner records. All obligated entities must maintain current KYC documentation for their clients and must register their own beneficial owner information with the UIF. If your ownership chain passes through multiple jurisdictions, each layer must be documented to the satisfaction of Argentine regulators. Gaps in the chain – for instance, nominee arrangements or discretionary trusts – attract specific enhanced due diligence requirements.
Adopt or update your internal prevention programme. Argentine anti-money laundering legislation requires obligated entities to maintain a written internal prevention programme, appoint a compliance officer, and train relevant staff. Existing programmes should be reviewed against the 2025 updates. Programmes that predate the new rules may no longer meet the required standards.
Assess correspondent banking and cross-border transaction exposure. Companies that rely on correspondent banking relationships for cross-border payments should verify that their Argentine bank has completed its own compliance review under the new rules. Delays or gaps on the banking side can interrupt payment flows at short notice. Similarly, companies seeking a new credit facility in Argentina should anticipate enhanced due diligence as a condition of approval.
Monitor subsequent UIF resolutions. The 2025 package is expected to be supplemented by further UIF guidance throughout the year, particularly on virtual assets and cross-border structures. A law firm in Argentina with an active AML practice will be well placed to track these developments as they emerge. For context on how comparable regulatory changes are unfolding in other jurisdictions, see our alert on AML updates in the United States.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our banking and finance practice covers AML compliance, KYC programme design, beneficial owner registration, and regulatory engagement across Latin American and Iberian markets. We advise international companies, financial institutions, and in-house legal teams on the full range of obligations arising under Argentine anti-money laundering legislation – from initial classification through to programme implementation and ongoing UIF reporting. Our attorneys have advised on cross-border banking and compliance matters across both civil law and common law systems. The firm's Lisbon base provides direct access to EU and Atlantic regulatory environments, supporting clients who manage compliance obligations across multiple jurisdictions simultaneously. For comprehensive legal support on AML matters in Argentina, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.