Uruguay has held a longstanding reputation as a regional financial hub, attracting substantial cash flows and investments from neighboring countries and beyond. Its offering of attractive corporate and financial products to non-resident investors has been a consistent draw. However, this very environment poses a significant risk concerning the potential depositing of illicit proceeds from crimes committed abroad, making money laundering the nation’s primary concern in this context.

The Coordinating Commission against Money Laundering and Terrorist Financing of the Central Bank of Uruguay (BCU) is entrusted with the task of coordinating anti-money laundering efforts and combating terrorist financing. It operates under the supervision of the Presidency Office of the Republic. The commission’s key responsibilities include establishing and operating a knowledge network to support various government agencies, providing data and analytical insights to assess the effectiveness of the system on a daily basis, and proposing financial countermeasures and penalties for nations identified as high-risk for money laundering.

The National Secretariat for Combating Money Laundering and Terrorist Financing (SENACLAFT) is a decentralized organization that reports directly to the President of the Republic and enjoys technical autonomy. According to the 19,574 Law, SENACLAFT is mandated to undertake the following tasks:

1. Develop national policies and strategies to combat money laundering and terrorist funding.
2. Coordinate and implement essential training programs.
3. Produce and publish regular statistics on the performance of the anti-money laundering system.
4. Enforce financial penalties in line with relevant regulations.
5. Oversee compliance with money laundering prevention regulations by non-financial entities mandated by law, including accountants, lawyers, notaries, operators of free zones, real estate companies, and others.

On January 10, 2018, the Uruguayan Parliament passed Law No. 19,574, which consolidates all anti-money laundering legislation and relevant information into a comprehensive text, specifying the consequences of noncompliance. The law defines the objectives of the Anti-Money Laundering (AML) and Terrorist Financing Commission (FTC), overseen by the government and composed of Ministers and the Presidency Secretary. The FTC collaborates with the Central Bank of Uruguay’s anti-money laundering section.

According to the provisions of Law No. 19,574, both financial and non-financial entities are required to implement the following robust consumer due diligence procedures and monitoring processes:

1. Screening against the Office of Foreign Assets Control (OFAC) and other government databases.
2. Establishing an effective mechanism for monitoring and reporting suspicious activities.
3. Developing risk-based anti-money laundering programs.
4. Implementing Customer Due Diligence (CDD) programs.
5. Validating and verifying consumer information using reliable data and credible sources.
6. Identifying and confirming the ultimate beneficiary’s name and taking reasonable steps to verify it.
7. Gathering information about the purpose of the business relationship and the nature of the companies involved, tailored to the risk associated with the client, commercial relationship, or type of transaction.
8. Conducting periodic reviews of contractual arrangements and transactions, where feasible, to ensure alignment with the client’s information and risk profile, including the source of funds.
9. Reporting any unusual activities that may indicate criminal behavior, such as money laundering or tax evasion.