Registration and compliance officer
Register with the UAF (art. 40) and appoint an officer responsible for dealing with it (art. 3). Circular No. 62 requires a senior position with independence, resources and access to every transaction (ch. B).
For banks, insurers, brokers, pension fund administrators, cooperatives, fintechs, notaries, real estate brokers, car dealers and every other article 3 entity: what the law and UAF Circular No. 62 require, what is at stake if you fall short, and how Snap Compliance turns it into a program backed by evidence.
At a glance
What it governs
It creates the Financial Analysis Unit, requires reporting suspicious transactions and recording cash transactions, and makes money laundering a crime (art. 27).
Who must comply
From the financial system to notaries, registrars, real estate brokers, casinos, car dealers, jewelers and the firms in the Fintech Law registers: 55 economic activities, according to the UAF.
Who supervises
The UAF issues the instructions, supervises with a risk-based approach and imposes sanctions. The CMF adds its own rules for the entities it oversees; its Circular No. 2368 of February 2026 aligned those for banks, non-bank card issuers and cooperatives with Circular No. 62.
Key milestone
Circular No. 62 came into force, bringing the UAF's instructions into a single rule and repealing 24 earlier circulars, including No. 49. The law itself has been in force since December 2003.
What it requires
The law sets the duties and UAF Circular No. 62 explains how to meet them. These obligations apply to every article 3 entity; the CMF adds its own for the entities it supervises.
Register with the UAF (art. 40) and appoint an officer responsible for dealing with it (art. 3). Circular No. 62 requires a senior position with independence, resources and access to every transaction (ch. B).
Identify and know the client before or during the relationship, in occasional transactions from USD 3,000 and whenever there is suspicion, with a client file updated at least once a year and enhanced measures for high risk (Circular No. 62, ch. F).
Ask every legal person or arrangement client to declare its beneficial owners: whoever holds 10% or more of the capital or votes, or exercises effective control. A 40-business-day delay is a red flag (ch. G).
Determine whether the client or its beneficial owner is a PEP, until at least one year after leaving office and including close family, and apply senior management approval, source of wealth and funds, and enhanced monitoring (ch. H).
Report to the UAF, as soon as possible and with no minimum amount, any unusual transaction or one with no apparent justification, without telling the client (arts. 3 and 6). A match with UN Security Council lists is reported immediately (art. 38 and ch. C).
Record cash transactions above USD 10,000 (art. 5) and report them: monthly for banks, quarterly for the rest of the financial sector and every six months for the non-financial sector, with a nil report if there were none (ch. D).
Keep the records of cash transactions, suspicious transactions —including those ruled out—, due diligence, PEPs and transfers for at least five years after the relationship ends, available to the UAF (art. 5 and ch. E).
A Prevention and Detection Manual approved by the highest governing body, updated at least every two years and given to all staff, plus annual training for every employee, with an attendance record (chs. J and L).
Consequences
The UAF Director sets sanctions according to the offender's economic capacity and the seriousness and consequences of the act (art. 19): a warning or a fine of up to 800 UF for breaching its instructions; up to 3,000 UF for failing to keep the cash transaction record; and up to 5,000 UF for breaching article 3, such as failing to report suspicious transactions, or for withholding information the UAF requests (art. 20). If a breach of the same kind is repeated within twelve months, the fine can triple, and it can also reach the directors or representatives involved (art. 21). Tipping off a client about a report is a crime: imprisonment and a fine of 100 to 400 UTM (arts. 6 and 7).
How we help
Due Diligence builds each client's file with document checklists and configurable forms, and scales the depth of diligence to its risk. Scan Agent checks clients and beneficial owners against sanctions lists —including the UN Security Council list—, PEPs and adverse media, and rescreens the portfolio periodically. AML Monitoring analyzes transactions daily against each client's profile, segments the portfolio by risk, keeps the full alert history with no limit and produces reports for the regulator, including the STR. Compliance Agent manages the obligations of Circular No. 62 as controls, assessments and action plans. Approving the manual and running the annual training remain your institution's job: Snap keeps the evidence in order.
Snap Compliance modules
Twelve risk-matrix closings in a single view: how many clients moved to high risk, how many keep escalating without stepping back, and from which closing a new methodology applies.
Every client with their twelve closings and a pattern that sets the priority: sustained escalation, recent deterioration, oscillating, or stable at the high level, a candidate for enhanced due diligence. The list exports to Excel in one click.
The score at every closing, the subfactor that changed the level, and in which month. Each move opens its justification in Client Reclassification.
Snap Compliance screens with fictitious data.
We review with you where your institution stands against these rules and what it still needs to demonstrate compliance.
Talk to a specialistLucia
Virtual assistant · Snap Compliance
Before we start
I'm Lucia. I'll be assisting you here and helping you with whatever you need from Snap Compliance.
We process your data in accordance with the applicable laws and regulations.