
CASSAGNE Consultores informs its clients and followers that last Friday, September 18, 2026, UIF Resolution No. 109/2026 was published in the Official Gazette. The Resolution amends UIF Resolution No. 78/2023, applicable to the Capital Markets sector, and introduces specific treatment for Labor Assistance Funds (FAL).
? What changes?
Mandatory contributions made to FALs are exempt from the applicable AML/CFT/CPF measures, controls, procedures and other obligations. The exemption also extends to voluntary contributions, donations, bequests and other income, subject to the conditions established by the regulation.
? Why?
The UIF applies a Risk-Based Approach (RBA) and identifies several risk-mitigating factors, including: identification of the employer through its CUIT and of the vehicle through its FAL ID; the fact that most contributions are channeled through ARCA; traceability of funds; investments restricted to the domestic market; CNV supervision; a specific statutory purpose; and restrictions on unrestricted redemption.
?? Important: the agents and entities covered by the regulation do not cease to qualify as Obliged Subjects, nor are their remaining AML/CFT/CPF obligations eliminated. The exemption is limited to the funds and transactions expressly covered by the Resolution.
? UIF Resolution No. 109/2026 has been in force since September 18, 2026.
? Another concrete example of the Risk-Based Approach in practice: fewer controls where the objective risk is lower, without dismantling the preventive framework.
? To learn more about the impact of this and other UIF regulations, schedule a meeting with our Managing Partner through our online booking page: https://lnkd.in/dvikcFJX
#UIF #UIFResolution109 #AML #CFT #CPF #CapitalMarkets #FAL #LaborAssistanceFunds #RBA #FATF #CassagneConsultores