Argentina's FIU Digitized the Registration of Obligated Entities: What Changes with Resolution 37/2026
Argentina's Financial Intelligence Unit (Unidad de Información Financiera, or UIF) published Resolution 37/2026 in the Official Gazette today, establishing the full digitization of the registration process for obligated entities listed in Article 20 of Law 25,246. From its effective date, all supporting documentation must be uploaded exclusively through the Operations Reporting System (SRO+), the UIF's digital platform. Paper-based submissions are eliminated.
The resolution amends the procedure that had been in force under UIF Resolution 50/2011 and its amendments (including Resolution 47/2024, which had already introduced additional requirements for criminal background checks and beneficial owners). The stated objective is to streamline processes, improve traceability, and optimize the agency's resources.
What Changes in Practice
The core operational change is that all registration documentation must be uploaded to SRO+ in PDF format. The UIF will review and validate documentation through the same platform, and observations or requests for missing items will be communicated through SRO+. There is no longer a physical window or paper documentation for this procedure.
For individuals, the required documentation includes a note addressed to the UIF President (signed by the obligated entity or its attorney-in-fact) with identification data, electronic domicile, activity, and other information detailed in the resolution. For legal entities, additional data on governing bodies, shareholding or corporate composition, term start and end dates, and a sworn statement with beneficial owner data (name, ID number, domicile, nationality, ownership percentage, PEP status) are required. The UIF may request additional information to verify the identity of beneficial owners.
Cure Period and Consequences
When the UIF identifies deficiencies or requires corrections, the obligated entity has 15 administrative business days to comply. Failure to do so within that period results in automatic blocking of the SRO+ registration. Blocking is not a mere formality: an obligated entity with a blocked registration is exposed to the sanctions under Law 25,246, which may include fines of up to ten times the value of the assets involved in the transaction, warnings, and suspension from registries.
The UIF's Supervision Directorate is authorized to require already-registered obligated entities to update their documentation under the new digital standards. This is not limited to new registrations: those already registered may receive an update request and must respond within the same terms and deadlines.
Beneficial Owners: Mandatory Reporting
Any change in the composition of beneficial owners must be reported to the UIF and the corresponding oversight body. For companies whose majority ownership belongs to an entity that makes a public offering of securities on an authorized market (domestic or international) and is subject to transparency requirements, the resolution provides a partial exception to the obligation to declare beneficial owners, provided timely access to the information is guaranteed.
What Obligated Entities Should Do Now
For those about to register, the procedure is exclusively digital starting today. They must have access to SRO+, prepare all documentation in PDF, and ensure that beneficial owner data is complete and current before initiating the upload. For those already registered, the practical recommendation is to review the status of their registration documentation in SRO+ and anticipate a potential update request from the Supervision Directorate. Having digitized and current documentation reduces the risk of blocking due to missed deadlines.
For Compliance Officers, the resolution reinforces that their own registration with the UIF is also subject to the digitized regime. Failure to comply with update obligations may result in sanctions for both the obligated entity and the Compliance Officer personally.
This note is for informational purposes only and does not constitute legal advice. For a specific analysis, please contact our team at contact@jfcattorneys.com.