At CASSAGNE Consultores, we share the most significant domestic and international developments of the month and their implications for AML/CFT/CPF compliance frameworks.

? FATF ? LIST UPDATES: Following its Paris Plenary (October 28?30), Bulgaria, Côte d?Ivoire, the Democratic Republic of the Congo, and Monaco were removed from the Grey List after successfully completing their action plans. No new jurisdictions were added, and the Black List remained unchanged (North Korea, Iran, and Myanmar).

? FATF ? VIRTUAL ASSETS: The FATF approved measures to accelerate reviews of the effective implementation of standards applicable to Virtual Asset Service Providers (VASPs), in response to the growing use of cryptoassets for money laundering, fraud, and sanctions evasion. Initial findings are expected in 2027.

? GAFILAT ? PROLIFERATION FINANCING: Its first Regional Risk Assessment examines vulnerabilities affecting financial institutions, dual-use goods trade, the maritime sector, free trade zones, Designated Non-Financial Businesses and Professions (DNFBPs), and VASPs, identifying challenges in strengthening preventive controls.

? ARGENTINA ? RePET: Joint Resolution No. 5/2026 determined that the requirements for registering five criminal organizations had been met, including the Sinaloa Cartel, the National Liberation Army (ELN), and FARC-EP. The measure seeks to prevent their operations and financing, underscoring the importance of counterparty screening.

? REAL PROPERTY REGISTRY: Disposition No. 11/2026 of the City of Buenos Aires aligned its controls with UIF Resolution No. 93/2026, limiting documentary requirements to certain specific activities performed by regulated professionals and updating the beneficial ownership framework. Effective date: November 8, 2026.

? CNV ? VASPs: General Resolution No. 1172/2026 amended the regulatory framework applicable to Virtual Asset Service Providers. Additional resolutions streamlined reporting requirements in the capital markets.

? FinCEN ? NEW ALERTS: FinCEN issued red flags to identify international transfers directed by foreign agents and the misuse of nonprofit organizations for fraud and illicit financing.

? UIF ? INTERNATIONAL COOPERATION: Argentina's Financial Intelligence Unit strengthened coordination with U.S. authorities to enhance financial intelligence sharing, investigations into criminal organizations, and asset recovery efforts.

?? The common denominator: increased scrutiny of emerging risks, the traceability of funds, and the effectiveness of AML/CFT/CPF controls.

? At CASSAGNE Consultores, we advise regulated entities on adapting and strengthening their AML/CFT/CPF compliance frameworks