At CASSAGNE Consultores, we keep our clients and followers informed of the latest developments in Anti-Money Laundering, Counter-Terrorist Financing, and Counter-Proliferation Financing (AML/CFT/CPF).
? In October 2026, GAFILAT published its first Regional Proliferation Financing Risk Assessment, a reference document aimed at strengthening preventive frameworks across Latin American countries.
?? In Argentina, the offenses of proliferation of weapons of mass destruction (WMD) and proliferation financing were expressly criminalized only in March 2024, through the enactment of Law No. 27,739, which incorporated both offenses into Article 306 of the Argentine Criminal Code.
? Key Findings of the GAFILAT Report:
?? Multi-Sectoral Analysis: Examines risk exposure and response capabilities across financial institutions, dual-use goods, the maritime sector, free trade zones (FTZs), relevant designated non-financial businesses and professions (DNFBPs), and virtual asset service providers (VASPs).
?? Regional Risk Exposure: Although the region's direct exposure is considered relatively low to moderate, the report warns against a false sense of security, given the sophisticated sanctions-evasion schemes employed by actors linked to Iran and the Democratic People's Republic of Korea (DPRK/North Korea).
?? Compliance Gaps: Identifies uneven implementation of risk mitigation measures, shortcomings in strategic export controls, and a limited number of proliferation-financing investigations and specific suspicious transaction reports (STRs).
?? Fifth Round of Mutual Evaluations: Emphasizes the need to develop, complete, and update National Proliferation Financing Risk Assessments (NRAs) and strengthen coordination among financial authorities, customs agencies, and export control authorities.
?? Red Flags: Provides relevant typologies and sector-specific indicators to assist both the private sector and competent authorities in identifying and understanding proliferation-financing risks.
?? What Does This Mean for Argentine Reporting Entities?
Although Argentina approved its National Terrorist Financing and Proliferation Financing Risk Assessment in 2022, this regional report provides valuable technical input for its forthcoming update.
It also serves as an important reference for reviewing and, where appropriate, updating institutional risk assessments, risk matrices, customer due diligence procedures, and transaction monitoring mechanisms, taking into account each entity's actual exposure to proliferation-financing risks.
? Do you need to review or update your AML/CFT/CPF compliance program? Schedule a virtual consultation with our Managing Partner, Dr. Miguel Cassagne, through our online booking system:
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