Governance & ManagementFinancial Control
Changes under the 2026 UAF rules for remittance providers and payment instrument issuers
Resolution UAF-N-027-2026 consolidates two 2019 regulations and changes specific governance, due diligence and reporting requirements. Identifying those differences allows businesses to prioritize adjustments to their Prevention Programs and implementation.
Managing Partner | Corporate & Commercial | Dispute Resolution
Regulatory, corporate governance and financial services
Published on November 5, 2026, the regulation took effect that day and repealed Resolutions UAF-N-019-2019 and UAF-N-020-2019. It establishes no general transition period. A compliance review should distinguish amended requirements from continuing obligations and matters to be developed through UAF circulars or directives (Articles 61 and 62).
Confirm the scope first
Article 2 covers payment instrument issuers and administrators, remittance and similar service providers, and currency trading or exchange providers incorporated as legal entities, subject to the supervision and financial affiliation conditions specified in the regulation. It also covers casinos and gaming establishments, real estate brokers, precious metals or stones dealers, and dealers and distributors of new or used vehicles.
The scope of Article 2 differs from that of the 2019 regulations. Those regulations also listed activities such as factoring, financial leasing and trust services, which do not appear in Article 2 of the new resolution. For those activities, the current sector framework and supervisor should be verified before concluding that preventive obligations have ended.
A more explicit position for the compliance function
The appointment of Compliance Officers was already regulated, including under the separate Resolution UAF-N-024-2024. Article 6 now expressly requires a managerial or equivalent position, functional independence and direct access to senior management or the highest governing authority.
Where the entity has no distinct managerial level, the officer must hold a position that provides sufficient authority, independence and direct access to the highest authority. Businesses should review organizational charts, responsibilities, access to information and resources alongside the formal appointment.
The principal thresholds continue
The amounts highlighted in the new regulation were already included in 2019: USD10,000 for occasional transactions by financial institutions; USD1,000 for specified casino services and precious metals or stones transactions; and USD5,000 for vehicle sales or distribution. Remittances already required due diligence regardless of value, and the covered real estate sale transactions were also subject to no monetary threshold.
Changes concern other triggers and clarifications. Article 13 expressly includes electronic and non-face-to-face transactions. Article 14 includes sports betting and requires real estate brokers to apply due diligence to both buyer and seller. Suspicion or doubts about identification continue to require attention regardless of transaction value.
Changes to incorporate into schedules and procedures
| Area | Previous framework compared | 2026 regulation and practical action |
|---|---|---|
| Risk assessment | Both 2019 regulations already required biennial assessments, filed within the first ten days of April (Article 4). | The biennial cycle continues; the report is due October 31 and covers the preceding two calendar years. Update filing and internal approval schedules (Article 10). |
| External audit | Already biennial. Filing was due in April for financial institutions and in its first ten days for DNFBPs (Articles 60 and 47). | At least every two years; report due July 31. Engage the auditor early and review scope, including the period since the last audit (Article 58). |
| Officer annual report | For financial institutions, Article 10 of the 2019 regulation required a forward-looking Annual Operating Plan filed in January. | The Compliance Officer’s Annual Report (IAOC) reports the previous year’s results, requires management approval and filing through SIREL by January 31. Prepare implementation evidence (Article 9). |
| Report corrections | The compared 2019 provisions did not include this rejection and correction mechanism for IAOC and risk assessment reports. | Three business days to correct an IAOC and seven for a risk assessment report, from notification. Assign responsibility for monitoring SIREL (Articles 9 and 10). |
| Audit scope | Review of the actual detection, analysis and suspicious transaction reporting process was excluded (IF Article 60.3; DNFBP Article 47.3). | Sufficient information must allow assessment of those procedures’ effectiveness, without auditor access to the STR module, filed STRs or supporting records (Article 58). |
The risk reporting cycle does not replace updates when material changes occur. The new regulation also expressly requires consideration of the risk of non-compliance with, failure to implement, or evasion of targeted financial sanctions related to proliferation financing (Article 10).
Prioritize a compliance gap review
- Compare the Prevention Program and Manual against the components in Article 5, documenting what remains, what changes and who will implement each adjustment.
- Review the Compliance Officer’s position and adapt procedures to the due diligence triggers applicable to the sector.
- Update reporting and audit schedules, including internal deadlines for preparation, approval, filing and corrections.
- Monitor the circulars and directives envisaged for the IAOC, risk assessment, Manual and other components. Determine upcoming deadlines according to each entity’s applicable cycle.
The result should be an updated, approved and implemented Program, with assigned responsibilities and verifiable evidence. At ARCA, we structure this review by connecting regulatory requirements with corporate governance, financial control and operating processes.
Sources
This content provides general information and business perspectives. Its application should be assessed in light of each organization’s circumstances.
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