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On October 22, 2026, the Superintendence of Companies, Securities and Insurance (SCVS), through Resolution No. SCVS-INC-DNCDN-2026-0014, published in the Official Gazette on October 27, 2026, introduced significant changes to the anti-money laundering and other crime prevention obligations applicable to certain companies under its supervision.
These changes require companies to strengthen their internal prevention mechanisms, review controls over customers and suppliers, and enhance risk management and oversight. Companies must adapt their procedures to the new requirements and comply with the applicable deadlines.
Does Your Company Operate in a Regulated Sector?
The new provisions apply to companies subject to SCVS supervision that engage in, among others, the following activities:
- Real Estate and Construction: Real estate development, investment and brokerage, as well as construction activities.
- Commercial Activities: Trading in vehicles, machinery, vessels, aircraft, precious metals and precious stones.
- Legal and Accounting Services: Activities such as the purchase and sale of real estate, management of money, securities and bank accounts, and the formation, operation or administration of legal entities.
- Corporate and Trust Services: Activities such as acting as an agent in the formation of legal entities, serving as a director or attorney-in-fact of a commercial company, and providing registered office, business address or physical premises services.
- Financial and Related Services: Money transfers and remittances, factoring, financial leasing, courier services and vehicle armoring.
What Are the Main Changes and What Do They Mean for Your Company?
- Updates to the Prevention System: Companies must update their prevention manual, methodology and risk matrix. These must be reviewed annually and approved by the administrative body designated in the company’s bylaws.
- Compliance Officer and Compliance Committee: Requirements governing the appointment, qualification, independence and oversight of the compliance officer have been strengthened. The compliance officer’s term of office will be five (5) years. The new provisions also establish operating requirements for the Compliance Committee, including monthly meetings.
- Due Diligence: Identification and due diligence controls are being strengthened in relation to customers, suppliers, employees, shareholders, beneficial owners (individuals holding, directly or indirectly, at least 10% of the company’s share capital) and politically exposed persons (PEPs).
- Reporting and Audits: Mandatory reporting to the Financial and Economic Analysis Unit (UAFE) remains in place. The new provisions also establish periodic controls, compliance audits, and documentation and record-retention requirements.
- Payment Restrictions: Companies must ensure compliance with the prohibition on using cash, precious stones or precious metals as a means of payment in transactions that, individually or cumulatively over a one-month period, equal or exceed USD 10,000.00.
Key Dates to Keep in Mind
- April 27, 2027: Deadline to update, approve and submit the prevention manual and risk prevention system to the SCVS.
- January 31 of each year: Approval of the Annual Compliance Report (IAC) and the Annual Compliance Plan (PAC).
- May 30 of each year: Submission of the external compliance audit report.
- Monthly: Compliance Committee meetings.
What Are the Risks of Non-Compliance?
Failure to comply with these requirements may result in administrative sanctions and fines, as well as observations being recorded in the Certificate of Compliance with Obligations (CCO).
What Should Companies Do Now?
Companies engaged in activities subject to these regulations should begin a review process as soon as possible to:
- Confirm whether they qualify as regulated entities subject to mandatory compliance obligations.
- Verify that their compliance officer meets the applicable requirements.
- Assess whether they have an appropriate organizational structure and Compliance Committee in place.
- Identify any gaps between their current procedures and the new requirements.
- Plan the update and approval of their manuals, policies and risk matrices.
At TOBAR ZVS, we are here to guide you through this process. Taking proactive steps to address regulatory changes is the best way to prevent potential exposure and protect your company.
© TobarZVS
This publication contains information of general interest and does not constitute legal opinion on specific issues. Any analysis will require legal advice from the Firm.