On July 29, 2019 the Financial Information Unit (“FIU”) issued Resolution No. 76/2019 (the “Resolution”), establishing the guidelines for preventing money laundering and terrorist financing (“ML/TF”), which shall be applicable to all operators in the credit and purchasing card sector, as well as to travelers checks issuers.

The Resolution adopted guidelines similar to those previously established by FIU Resolution No. 30-E/2017, applicable to financial institutions. Consequently, credit and purchasing card operators, and travelers checks issuers, must develop a self-assessment risk system, in compliance with the risk factors and risk mitigation determined by the Resolution. They shall also comply with the “know your client’s profile policy” as well as be in possession of detailed records reflecting a deep knowledge and profile of their clients.

Additionally, the obliged subjects shall (i) maintain a procedures manual in order to prevent ML/TF, as well as with appointing a compliance officer; and (ii) provide the requiring clients all their information and documentation concerning their identification and the origin of the funds.

Regarding to its enforcement, the Resolution establishes a progressive implementation schedule, starting on December 31, 2019, so as to complete with all requirements on February 28, 2020.

Finally, within 10 days of publication of the Resolution, the obliged subjects must report the FIU with the appointment of a person responsible to address urgent matters.

For further information, please do not hesitate to contact Eugenia Pracchia or compliance@trsym.com.