? NEWS: FIU Res. No. 93/26 ? New AML/CFT/CPF Framework for Real Property Registries ?

CASSAGNE Consultores informs its clients and followers that today, FIU Resolution No. 93/26 was published in the Official Gazette. The Resolution establishes a new regulatory framework for the Real Property Registries of each jurisdiction (obliged entities Section 20(19) of Law 25,246).

? What does the new Resolution establish?

It requires the implementation of an AML/CFT/CPF Prevention System designed to identify, monitor, manage, and mitigate the risks inherent in registry activities. Among other measures, the System must include:

? Risk-assessment policies based on minimum risk factors.

? Appointment of a primary and an alternate Compliance Officer.

? An AML/CFT/CPF Manual, Code of Conduct, record-retention policies, and annual training program.

? Customer and beneficial-owner identification and due-diligence policies.

? Procedures for verifying PEP and obliged-entity status.

? Screening against the RePET and UN Security Council lists.

? Policies governing monitoring, the review of unusual transactions, Suspicious Transaction Reports (STRs), and recordkeeping.

? What circumstances must be considered for monitoring purposes?

? Successive registrations involving the same property within a one-year period, where the price difference exceeds 30%.

? Multiple registrations or annotations in the name of the same person within a one-year period.

? Multiple or matching names, documents, or identification details that may reveal inconsistencies.

? What will change in systematic reporting as of November 2026?

From the 1st through the 15th day of each month, Real Property Registries must report transactions registered during the preceding calendar month involving:

?? Purchases and sales for amounts exceeding 750 Minimum, Vital and Mobile Wages.

?? Donations of real property.

?? The creation, transfer, amendment, or termination of rights in rem over real property through instruments executed abroad.

? When will the Resolution become effective?

? 90 days after its publication. On that date, FIU Res. 41/11 and Section 12 of FIU Res. 70/11 will be repealed.

? RPR will have 240 days to update their AML/CFT/CPF Manuals and technological tools and to approve a Code of Conduct.

? Pending administrative proceedings and reviews of events occurring before the new Resolution took effect will remain governed by FIU Res. 41/11.

? What are the objectives of the reform?

? To replace the formalistic compliance model with a Risk-Based Approach.

? To align the regulation of RPR with the amendments introduced by Law No. 27,739 and the new framework applicable to notaries public.

? To modernize monitoring through technological tools and registry profiles.

? If you would like to learn more about this and other UIF resolutions, schedule a meeting with our Managing Partner through our online booking platform: ? https://lnkd.in/dvikcFJX