??? NEW FIU RESOLUTION 78/2025 ? END OF CONTROLS? NOT AT ALL. ??
? CASSAGNE Consulting informs clients and followers about the new FIU Res. No. 78/2025 (Official Gazette 06/05/2025), which has been subject to confusion or misinterpretation regarding its scope and implications.
? What does the regulation actually do?
? It reduces specific administrative burdens and updates reporting thresholds, but does not eliminate the structural obligations of the AML/CFT system.
? LIMITED SCOPE:
It does not apply to all Reporting Entities, but only to:
- Real Estate Registries,
- Automotive Registries,
- Financial Institutions,
- Notaries.
? What about real estate brokers, trustees, brokerage firms, and other reporting entities? They remain fully subject to all existing AML/CFT obligations.
? The amendments do not eliminate the obligation to:
- Conduct Due Diligence (CDD),
- Determine the Transaction Profile,
- Monitor operations,
- Address unusual transactions,
- File Suspicious Activity Reports (SARs),
- Maintain AML/CFT Manuals, conduct audits, provide staff training, etc.
? What changes for the entities affected by the regulation?
?? Real Estate Registries:
- Updates the threshold for systematic reporting (RSM) of property sales to FIU: from 200 to 750 Minimum Living and Mobile Wages (SMVM).
? Automotive Registries:
- Raises the threshold for systematic reporting of vehicle acquisitions: now above ARS $50,000,000, subject to automatic updates in January and July based on ACARA data.
- Eliminates the requirement of a tax affidavit (DDJJ) for client profiling.
- Retains the obligation to collect supporting documentation for source of funds (e.g., deeds, bank documents, previous sales).
- Some payment methods (own account transfers or checks, bank loans) may exempt the need for full client profiling if thresholds are not exceeded.
? Financial Institutions:
- Doubles the threshold for enhanced identification and systematic reporting of cash transactions: from 20 to 40 SMVM.
- Adjusts provisions related to transaction profiles and cash deposits.
- Maintains risk-based due diligence and documentation requirements, but no longer requires tax affidavits (DDJJ).
?? Notaries:
- Updates the threshold for reporting domain transfers made in cash to UIF via RSM: from 700 to 750 SMVM.
- Maintains the obligation to verify source of funds (clarifies acceptable documentation and removes DDJJ requirement).
? Scan the QR code in the image to access the full text of the Resolution.
? Request a virtual meeting at https://lnkd.in/dvikcFJX to understand whether and how these changes impact your compliance policies?and how we can assist you in adapting to the new regulation.
? Visit us at https://lnkd.in/dV4B9EBQ for more information.