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? NEW FIU RESOLUTION No. 3/26 ? FINANCING OF PROLIFERATION OF WEAPONS OF MASS DESTRUCTION (WMDPF) ?


On January 8, 2026, FIU Res. No. 3/26 was published in the Official Gazette, regulating the reporting mechanisms and the procedures for the administrative freezing of assets linked to the WMDPF.


? This regulation complements FIUF Res 207/25, which had updated the asset-freezing regime and reporting obligations related to the financing of terrorism (repealing FIU Res 29/2013). Resolution No. 6/26 now extends that regime to cases associated with WMDPF, an activity that was only recently classified as a criminal offense in March 2024, through the incorporation of Article 306, subsection (f), into the Argentine Criminal Code.


? Objective: This regulation seeks to address the observations made to Argentina during the 4th mutual evaluation carried out by FATF, and to ensure the effectiveness and efficiency of the reporting system and asset-freezing mechanisms related to WMDPF.


? It applies to all Obligated Entities under Law 25,246, and establishes the obligation to:


Strengthen their KYC processes. As of January 8, 2026, in addition to continuing to verify that their clients (and their beneficial owners) are not included in the RePET List (individuals associated with terrorism or representing a threat to Argentina?s national security), they must also verify that such persons:


(a) are not included in the lists of the United Nations Security Council (UNSC) of individuals or entities designated in connection with nuclear programs, other weapons of mass destruction programs, or ballistic missile programs of the Democratic People?s Republic of Korea (Resolution 1718), and nuclear programs of the Islamic Republic of Iran (Resolution 1737); and/or


(b) are not included in the registries created for such purposes in Argentina in order to implement UNSC resolutions.


? Submit reports to FIU, within 24 hours, as a Suspicious WMDPF Operation, in relation to any completed or attempted transaction when it is verified that the assets involved: (a) belong to individuals or entities designated by the UNSC in connection with nuclear or missile programs of the DPRK or Iran; (b) are under the direct or indirect control of such persons or entities; (c) are intended to benefit the listed subjects; and/or (d) may be linked to the offense of WMDPF as defined in Article 306, subsection (f), of the Criminal Code.


?? Freeze present or future assets: immediately and ex parte immobilizing them when a match is detected with international lists or the local registries referred to above.


?? ? These measures require Obligated Entities to update their policies and manuals in order to avoid the severe sanctions established under the sanctioning regime of Law No. 25,246.


? Learn about the changes to be implemented. Schedule a meeting at:

https://lnkd.in/dvikcFJX