Argentina AML Obligations for Accountants: UIF Resolution 42/2024

Argentina names matriculated public accountants (contadores públicos) as obliged subjects of its anti-money-laundering regime, but only when they act for clients in a defined list of specific activities. This guide summarises the financial intelligence unit's resolution that sets out what those accountants must do: assess risk, identify clients, report suspicion, and keep records for ten years. For the general ideas, see our guide to KYC and customer due diligence for accountancy practices.

Where this guide comes from

We read Resolución UIF 42/2024, issued by the Unidad de Información Financiera (UIF), sanctioned on 14 March 2024 and published in the Boletín Oficial on 18 March 2024. The copy we read notes that it includes modifications from Resolución UIF 56/2024, but those modifications are not shown in the text. It repeals Resolución UIF 65/2011. Article numbers below are from the resolution. This is general information, not legal advice.

When an accountant is an obliged subject

Article 2(o) covers matriculated public accountants only when, in the name of or on behalf of their clients, they prepare or carry out specific activities. Article 2(a) lists those activities and, for several, a threshold in Salarios Mínimos, Vitales y Móviles (SMVM), a minimum wage unit:

• real estate purchases or sales above 700 SMVM;
• administration of goods or assets above 150 SMVM;
• administration of bank, savings or securities accounts above 50 SMVM;
• organising contributions for, creating, operating or administering legal persons, and buying or selling businesses or shares, with no threshold stated in the text we read; and
• audit reports on financial statements for certain entities named in article 20 of the law, or entities with ordinary revenues of at least 4,000 SMVM.

Risk self-assessment and procedures manual

Under article 5, the obliged subject must produce a technical report assessing its own risk. The report must be updated every two years, the methodology reviewed every four years, and it must reach the UIF before 30 April of the relevant year. Article 29 sets the first self-assessment for before 30 April 2026, so it should already have been filed. Article 8 requires a manual for the prevention of money laundering and terrorist financing, reviewed every two years and available to the UIF at all times. The text we read does not mention a compliance officer, which is unusual, so check whether another resolution deals with the role.

Identifying clients and beneficial owners

Under article 12, identity must be verified before the professional relationship begins. Article 13 sets the requirements for natural persons and article 14 for legal persons. The resolution defines the beneficial owner only by reference to the UIF resolution currently in force on the subject, so no ownership percentage appears in the text we read. Our guide to ultimate beneficial ownership explains the concept in general terms. Politically exposed persons are handled under a separate UIF resolution, but the text treats foreign politically exposed persons as high-risk clients (article 19) and requires the decision to accept or reject them to be justified (article 7(g)). Article 21 adds that when dealing with other obliged subjects, the accountant must confirm they are registered with the UIF, and the relationship cannot start if they are not.

Reporting suspicious transactions

Article 26(c) sets the timing. For money laundering, the report is due within 24 hours of concluding that the operation is suspicious, and no later than 90 calendar days after the operation. For terrorist financing and the financing of weapons proliferation, the report is due within 24 hours of the operation. Reports are confidential (article 26(d)), and the resolution says no report is required when the information is covered by professional secrecy. Our guide to suspicious activity reports and tipping off explains the confidentiality principle.

Record keeping and sanctions

Under article 10, transaction documents must be kept for at least ten years from the date of the transaction, and client documents for at least ten years from disengagement or the last specific activity, whichever is later. Article 28 says breaches are subject to the penalties in Chapter IV of Law 25.246. The resolution itself does not list amounts.

Practical steps (our suggestions)

• Check each engagement against the activity list and the SMVM thresholds before deciding whether the regime applies.
• Put the 30 April deadline for the risk report in your compliance calendar.
• Set a ten-year retention date for transaction and client files.
• Write down the route for a 24-hour decision on suspicion, and who makes it.
• Keep the team current. Our CPD courses include financial crime topics.

What we could not confirm

We could not see the changes made by Resolución UIF 56/2024, and we did not read later UIF resolutions on beneficial owners, politically exposed persons or the compliance officer role. We also did not read the sanctions chapter of Law 25.246 or the professional accountancy federation's own guidance, so we cannot give penalty amounts or confirm any 2025 changes. The SMVM values change over time, so look up the current amount before applying a threshold. Check the current UIF resolutions before relying on this guide.

Frequently asked questions

Are all accountants in Argentina covered?

No. Article 2(o) covers matriculated public accountants only when they carry out the specific activities listed, for clients.

How fast must a suspicious transaction be reported?

For money laundering, within 24 hours of concluding the operation is suspicious, and no later than 90 calendar days after the operation.

How long must records be kept?

At least ten years, counted as described above.

Who receives the reports?

The UIF, Argentina's financial intelligence unit.

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