By Miguel Cassagne

Head of CASSAGNE Consultores

I. Introduction

The National Risk Assessment (NRA) constitutes one of the most relevant instruments within a country?s system for the prevention of money laundering and terrorist financing (ML/TF). Although the FATF does not expressly require its implementation as a mandatory legal obligation, the organization recognizes it as an essential methodological tool for the application of the Risk-Based Approach (RBA) and for demonstrating effectiveness in complying with Recommendation 1 and its Interpretive Note.

In the case of Argentina, the most recent NRA related to money laundering was approved by Decree 653/2022 and covered the assessment period from January 2017 to December 2020, while the one related to Terrorist Financing and the Proliferation of Weapons of Mass Destruction was approved by Decree 652/2022 and covered the period from January 2019 to May 2022. Three years after those publications, the economic, political, and technological context has substantially changed in terms of inflation, the growth in the use of virtual assets, the expansion of the informal economy, and a new political cycle characterized by deregulation measures.

All of this makes it necessary to urgently review the NRA in light of the Money Laundering National Risk Assessment Toolkit (ML NRA Toolkit), updated by the FATF in August 2025.

II. The FATF Toolkit: General Guidelines

The ML NRA Toolkit is not intended to serve as a rigid standard, but rather as a flexible guide that allows countries to adapt the methodology for identifying threats and vulnerabilities to their own context. Among its most relevant contributions for Argentina, the following stand out:

·       Modular approach: the Toolkit allows for the conduct of both general assessments (NRA) and thematic or sectoral studies (e.g., on corruption, virtual assets, the informal economy, or the use of legal persons).

·       Recognition of data limitations: the absence of reliable statistics does not invalidate the NRA; instead, it must be explicitly acknowledged as a weakness that should guide future action plans.

·       Public-private participation: the Toolkit recommends the inclusion of regulators, law enforcement agencies, the FIU, and the Central Bank, but also banks, real estate businesses, financial service providers, and professional associations.

·       Iterative nature: the NRA is not a one-time exercise but a living process that must be periodically updated and serve as the basis for supervision and policy formulation.

This framework is particularly pertinent for Argentina, where the main challenge lies in harmonizing international standards with a domestic reality marked by informality, structural corruption, and macroeconomic volatility.

III. Argentine Context: Persistent and Emerging Risks

Before delving into the concrete factors that condition the risk of money laundering in Argentina, it is necessary to pause for a broader reflection. What makes one country more vulnerable than another to this type of crime? Is it solely its laws and oversight agencies, or do the structural characteristics of its economy and its compliance culture also weigh heavily?

Indeed, international experience demonstrates that the most robust risk assessments are not limited to describing threats, but rather begin with a candid acknowledgment of the weaknesses that allow those threats to flourish. The FATF, through its new Toolkit, emphasizes precisely this perspective: a national risk assessment is not a mere catalogue of problems, but rather a map of vulnerabilities that, once recognized, can begin to be mitigated.

In Argentina, the exercise becomes even more relevant. Our country combines a high degree of sophistication in certain regulated sectors with chronic deficits in others; notable regulatory advances in the field of virtual assets coexist with persistent shortcomings in the fight against corruption and informality. All of this compels us to conceive of the NRA as an exercise in strategic realism: to face our strengths and weaknesses directly, and then to construct a plan that is credible, progressive, and achievable.

With this framework in mind, let us proceed to identify the main risk factors that currently condition Argentina?s ability to prevent money laundering and terrorist financing, and the importance of considering these factors when the country undertakes the drafting of a new and updated NRA.

1.     Informal economy: According to estimates from the National Institute of Statistics and Census (INDEC) and recent academic studies, more than 40% of the Economically Active Population (EAP) participates in informal activities. This level directly impacts the traceability of operations and constitutes a risk vector recognized in the Toolkit itself.

2.     Structural corruption: Argentina ranks 98th out of 180 countries in Transparency International?s Corruption Perceptions Index (2024), with a score of 37/100, which reflects a high level of risk. The FATF recognizes corruption as one of the main predicate offenses for money laundering in countries across the region.

3.     Intensive use of cash: The weight of cash in retail transactions remains high, despite progress in digital payment methods. According to the Central Bank of Argentina (BCRA), in 2024 more than 80% of low-value transactions were carried out in cash, which limits the application of preventive controls.

4.     Virtual assets (adjusted to the regulatory framework in force since 2024): Until 2023, the absence of a comprehensive regulatory framework regarding virtual assets and Virtual Asset Service Providers (VASPs) constituted one of the main weaknesses of the Argentine system. However, as of 2024 the country undertook a profound regulatory shift that aligned it more closely with the FATF?s international standards.

This change materialized, in the first place, with the enactment of Law No. 27,739, which incorporated VASPs into the registry administered by the National Securities Commission (CNV), thereby establishing for the first time a formal and specific supervisory framework for their activity. At the same time, that law amended Article 20 of Law No. 25,246, providing, among other aspects, for the inclusion of VASPs within the roster of Obliged Entities required to report to the Financial Intelligence Unit (FIU), thereby equating their preventive duties with those of traditional entities such as banks, exchange houses, and other obliged subjects.

Finally, with the publication of UIF Resolution No. 49/2024?which establishes the minimum requirements that Virtual Asset Service Providers (VASPs) must meet to identify, assess, monitor, manage, and mitigate the risks associated with money laundering, terrorist financing, and the proliferation of weapons of mass destruction?the regulatory framework of the sector, which until then had been pending, was completed. Among the requirements set forth by this regulation are the duty of registration, the implementation of compliance programs in the field of ML/TF prevention, the application of customer due diligence procedures (KYC), the monitoring and systematic reporting of suspicious transactions, as well as the obligation to conduct periodic training and audits.

With this regulatory framework, Argentina managed to overcome one of the historical weaknesses of its system and move towards a more balanced regulatory model, in line with FATF Recommendation 15.

This framework places Argentina among the countries in the region that have taken a qualitative leap in the supervision of the crypto ecosystem, consistent with Recommendation 15 of the FATF and with the regulatory trend observed in the European Union (MiCA Regulation) and in more advanced markets.

Nonetheless, the rapid social adoption of cryptocurrencies and the existence of peer-to-peer operations outside the regulated perimeter continue to represent residual risks that must be monitored.

IV. Comparison between the FATF Toolkit (2025) and Argentina?s 2022 NRA

National risk assessments are not immutable documents, but rather snapshots of a historical moment that, over time, lose clarity if they are not updated in light of new economic, political, and technological contexts. The NRAs on ML and on TF/FP, approved in 2022, undoubtedly represented a significant step forward insofar as they made it possible to systematize dispersed information and to offer an initial shared diagnosis.

However, the subsequent years introduced transformations that compel a reassessment of that effort: a more robust legal framework was consolidated in the area of virtual assets, international pressure to demonstrate effectiveness in supervision increased, and structural phenomena such as informality deepened.

In this scenario, the Money Laundering National Risk Assessment Toolkit published by the FATF in August 2025 proposes a higher and more methodologically demanding standard. This is not to disparage what was accomplished in 2022, but rather to acknowledge the need to enrich it with new inputs, broader sources of data, and even more active participation from the private sector.

One of the first points of contrast appears in the consideration of the informal economy and corruption.

The 2022 NRA identified informality as a cross-cutting risk, although that diagnosis was not translated into a concrete action plan or into indicators that would allow its future evolution to be measured.

Corruption, for its part, was treated merely as a predicate offense, and it will be necessary in the future to deepen the analysis of the phenomena associated with it.

The 2025 Toolkit, in contrast, dedicates specific sections to these issues, proposes comparative methodologies, and recommends the use of international sources?such as the World Bank, UNODC, and Transparency International?that facilitate the quantification of the phenomenon.

For Argentina, the challenge lies in moving from general description to the design of an inter-institutional system of dynamic indicators that would allow for monitoring progress and setbacks over time.

A second axis of comparison relates to virtual assets and Virtual Asset Service Providers (VASPs).

Whereas the 2022 NRA merely mentioned these instruments as an emerging risk without further development, the FATF Toolkit requires a thorough analysis of their threats and vulnerabilities, even suggesting specific sectoral assessments and direct consultations with the industry.

In this regard, it must be acknowledged that Argentina has made notable progress since 2024, with the incorporation of VASPs as obliged entities under Article 20 of Law No. 25,246, the creation of a registry under the CNV (Law No. 27,739), and the regulation issued by the FIU, as detailed in the preceding section.

These changes mark a clear alignment with international standards, although there remains the need to expand coverage to areas that are still insufficiently regulated, such as peer-to-peer operations or regulatory arbitrage at the regional level.

The issue of legal persons and legal arrangements also reveals substantial differences.

The 2022 NRA acknowledged the risk that corporations and trusts might serve as vehicles for laundering, but it would now be necessary to deepen the evaluation of the effectiveness of the Beneficial Ownership Register.

The 2025 Toolkit suggests more exhaustive studies on the timing and modalities of entity incorporation, the accessibility of corporate information, and the risks arising from the lack of interoperability among registries.

In Argentina, while there have been regulatory advances in this area, practical difficulties persist in integrating provincial and national databases, which reduces actual transparency.

Finally, with regard to methodology and stakeholder participation, the 2022 NRA was led by the FIU and the Ministry of Justice, with some participation from the private sector.

The Toolkit emphasizes, in this regard, the need for the private sector not to be merely consulted, but to act as a true co-producer of inputs and statistics for the assessment. It also recommends integrating international sources and comparative methodologies.

In Argentina?s case, this implies the advisability of expanding the call to include the so-called Designated Non-Financial Businesses and Professions (DNFBPs) ?real estate brokers, notaries, accounting and legal professionals?as well as fintech companies and technology firms, whose exclusion in 2022 reduced the scope of the assessment.

In short, the contrast between the 2022 NRA and the 2025 Toolkit does not reveal failures, but rather the need to deepen, refine, and update an exercise that, by definition, must be iterative.

Where previously there was a general diagnosis, today a more precise approach is expected, with comparable metrics and greater integration of sectors.

V. Possible Suggestions for Argentina?s Next National Risk Assessment

In light of recent regulatory developments and of the methodological guidelines contained in the Money Laundering National Risk Assessment Toolkit 2025, the updating of Argentina?s NRA should not be conceived merely as a formal compliance exercise vis-à-vis international commitments.

On the contrary, it ought to constitute an opportunity to deepen the understanding of local risks, to strengthen inter-institutional cooperation, and to enhance the effectiveness of the prevention system.

The guiding spirit of this process should be that of a technical and collective undertaking, far removed from grandiloquence, and firmly anchored in the humility of recognizing that it is a path of continuous improvement.

The need to consolidate a common database

One of the main deficits identified in the 2022 NRA was the dispersion of information.

The FIU, the Central Bank, the National Securities Commission, the tax authority (AFIP), and law enforcement agencies all possess valuable data, and yet these must converge in order to generate a homogeneous system that would allow them to be integrated and analyzed dynamically.

The new assessment should prioritize the creation of an inter-institutional repository, serving not only for the elaboration of diagnoses but also for guiding supervision and the formulation of public policy.

The Toolkit underscores that even the acknowledgment of statistical limitations constitutes a valid input: recognizing what is not known is a first step toward improvement. In this sense, it is not indispensable to aspire to a perfect system from the outset; it would suffice to begin with simple indicators?for example, the evolution of suspicious transaction reports in each sector?and progressively expand the complexity of the records.

Such a gradual approach would allow for firm steps without falling into the paralysis that often results from the pursuit of overly ambitious solutions.

Informal economy and corruption as structural axes

The informal economy and corruption cut across the Argentine system and condition any risk analysis in the field of money laundering. The 2022 NRA acknowledged their existence but did so in a general manner, without delving deeply into specific studies that would allow the measurement of their impact on the generation and channeling of illicit assets.

The Toolkit proposes a deeper approach: not only to identify the existence of these phenomena, but also to quantify them, to link them with money laundering typologies, and to assess their impact on the various sectors of the economy.

To this end, Argentina should rely on statistics from international organizations such as the World Bank, the United Nations Office on Drugs and Crime (UNODC), and Transparency International, as well as on national academic research.

The elaboration of thematic studies on informality and corruption should not fall solely to public authorities. It would be advisable to convene universities, research centers, and civil society organizations, integrating diverse perspectives that would enrich the diagnosis.

This collaborative approach would make it possible to overcome a sectoral vision and to recognize that no single actor, on its own, holds a monopoly on knowledge of such complex phenomena.

Virtual assets and VASPs: from emerging threat to regulated challenge

One of the most significant changes since the 2022 NRA has been the consolidation of a specific regulatory framework for virtual assets and their service providers.

The next NRA should reflect this new scenario, acknowledging that the country has advanced in line with international standards. However, the challenge is not exhausted in the formalization of the regulated sector: significant risks persist in peer-to-peer operations and in spaces that still escape the regulatory perimeter.

Here, a balanced approach will be key?one that, far from criminalizing innovation, seeks to integrate VASPs as allies in prevention.

Experience shows that the most effective solutions arise when regulation is constructed hand in hand with the regulated sector itself, and not in opposition to it.

Transparency in legal persons and beneficial ownership

Corporate and fiduciary structures have been identified in multiple international assessments as common vehicles for concealing illicit assets.

Although Argentina has a Beneficial Ownership Register administered by ARCA (formerly AFIP), difficulties persist in integrating information with provincial registries and with dispersed corporate databases.

The Toolkit recommends specific evaluations of the actual functioning of these registers, addressing issues such as the speed with which companies can be incorporated, the quality and accessibility of the declared information, and the verification mechanisms in place.

The new NRA should move in this direction, proposing realistic and progressive goals that prioritize the most exposed sectors?such as the real estate and fiduciary sectors?before aspiring to total coverage immediately.

The participation of the private sector

Finally, the methodology of the next NRA should aim to broaden even further the participation of the private sector, especially of the so-called Designated Non-Financial Businesses and Professions (DNFBPs) or Actividades y Profesiones No Financieras Designadas (APNFD).

The Toolkit is emphatic in pointing out that the private sector must not be a mere recipient of public policies, but rather an active participant in the generation of information and in the identification of vulnerabilities.

This requires deepening a cultural change: moving from ad hoc consultations to the construction of permanent dialogue forums in which regulators and supervised entities share experiences, concerns, and proposals.

The inclusion of fintech companies and technology firms, moreover, is unavoidable in a country where financial innovation is growing at an accelerated pace and poses both opportunities and risks.

VI. Conclusions

The updating of Argentina?s National Risk Assessment on ML/TF/PF should not be seen merely as an external requirement imposed by the FATF, but rather as an internal opportunity to improve financial governance, strengthen transparency, and build trust in institutions.

The FATF Toolkit updated as of August 2025 is not a rigid standard for carrying out the NRA, but rather a flexible guide that must be adapted to the local context. Its application will allow the country to have a more precise diagnosis, to strengthen cooperation between the public and private sectors, and to enhance the effectiveness of the prevention system.

In this respect, the true value of this FATF instrument will lie in how Argentina manages to adapt it to its own reality: a country with high levels of informality, persistent challenges in the area of corruption, a strong culture of cash usage, and a growing dynamism in virtual assets, which as of 2024 already enjoys a strengthened legal and regulatory framework.

For this reason, more than an international requirement, the NRA itself should be understood as an opportunity for collective learning.

Ultimately, risk assessments are not mere formal exercises, but rather the expression of a country?s willingness to look at itself with honesty, to acknowledge its limitations, and to move forward on a path of continuous improvement.

The next NRA should be, in short, a collective exercise in humility and realism, in which each sector contributes its perspective and all recognize that the fight against money laundering and terrorist financing is a shared responsibility.