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Anti money laundering duties in Uruguay

Last verified: 2026-10-27 · Status: Changing

Ley 19.574 makes BCU supervised firms and a long list of non financial businesses (real estate, notaries, lawyers and accountants in certain deals, company service providers, free zone operators and users, dealers in art and precious metals, non profits) report unusual or suspicious transactions to the BCU's UIAF. Obligated parties must register with SENACLAFT, run a written risk analysis, identify beneficial owners holding 15 percent or more, apply enhanced checks to non residents and politically exposed persons, and keep records for at least five years. Money laundering carries 2 to 15 years of prison and includes tax fraud above UI 400,000 (about US$66,000) as a predicate offence; administrative fines for non financial parties reach UI 20 million (about US$3.3 million).

USD figures use UYU 40.210 per US dollar, the BCU quotation for DLS. USA BILLETE on 27 October 2026; amounts in Unidades Indexadas (UI) use UYU 6.6792 per UI, the BCU quotation for 27 October 2026, both retrieved from the BCU quotations service on 27 October 2026. Amounts in Unidades Reajustables (UR) use UYU 1,940.77 per UR, the value fixed by Decreto 229/026 (IMPO lists it as the latest UR, in force for September 2026). Conversions are rounded and for orientation only.

Key facts

Beneficial owner ownership threshold for due diligence	15 %Ley 19.574 art. 15, as of 2026-10-27 · in force
Years a former public official remains a politically exposed person	5 yearsLey 19.574 art. 20, as of 2026-10-27 · in force
AML fine minimum for non financial obligated parties	1000 UILey 19.574 art. 13, as of 2026-10-27 · in force
Days for the FIU to instruct after a suspicious transaction report	3 business daysLey 19.574 art. 22, as of 2026-10-27 · in force
Maximum administrative block of suspicious operations	5 business daysLey 19.574 art. 24, as of 2026-10-27 · in force
Maximum prison term for money laundering	15 yearsLey 19.574 art. 30 and 31, as of 2026-10-27 · in force
Tax fraud as laundering predicate, annual evaded tax above	400000 UILey 19.574 art. 34, as of 2026-10-27 · in force
Casino due diligence threshold	3000 USDDecreto 379/018 art. 22, as of 2026-10-27 · in force
Due diligence threshold for dealers in art, antiques and precious metals	15000 USDDecreto 379/018 art. 64, as of 2026-10-27 · in force
Enhanced due diligence for real estate operations by bank instruments above	300000 USDDecreto 379/018 art. 35, as of 2026-10-27 · in force
Deadline to update SENACLAFT registration data	30 daysDecreto 379/018 art. 93, as of 2026-10-27 · in force

The rule

1. Besides BCU supervised entities, the duty to report unusual or suspicious transactions applies to: casinos; real estate agents, developers, builders and other intermediaries in property deals, except leases; lawyers, notaries and independent accountants when they act for clients in property deals (including those paid wholly or partly in virtual assets), manage client money, securities, bank or securities accounts, organize contributions to companies, create, run or manage legal persons or trusts, buy or sell businesses, or act for clients in financial or property operations (not for mere advice); auctioneers; dealers in antiques, art and precious metals and stones; free zone operators and direct and indirect users; company and trust service providers; associations, foundations, political parties, unions and other non profits; pension fund managers; sports corporations; non financial trustees; and offshore support service providers. Accountants are also covered when preparing audit and certain limited review reports.
Cost to do it: No fee to be an obligated party; cost of an AML programme proportionate to risk.
Example: A Punta del Este real estate agency is an obligated party for every sale it intermediates, but not for rentals. / A US law firm's Montevideo office that forms companies and acts as nominee director for clients is an obligated party under art. 13 H.Ley Nº 19.574 (Integrated AML Law), art. 12 and art. 13 as reworded by Ley Nº 20.469 art. 1, art. 12 and 13, 2026-03-19 official text · verified 2026-10-27 · changed: Ley Nº 20.469 of 19 March 2026 art. 1 reworded art. 13, adding express references to property and business deals paid in virtual assets and to the sale of legal persons and trusts, among other changes.

2. Obligated parties must adopt written customer due diligence policies covering identification and knowledge of clients, including the beneficial owner, and may not keep anonymous or fictitious accounts. Due diligence applies to all new clients, to occasional transactions above the thresholds set for each activity, and whenever there is suspicion or doubt about prior data. The beneficial owner is the natural person who directly or indirectly holds at least 15 percent of the capital or voting rights, or otherwise exercises final control over an entity, trust, fund or other structure, and also the person who provides the funds for a transaction or on whose behalf it is made. Obligated parties must be able to show authorities, through a written risk analysis, that their measures fit the risk.
Cost to do it: Cost of identity verification, beneficial ownership checks and a written risk analysis.
Example: A notary handling a share sale must identify each person who ultimately holds 15 percent or more of the buyer. / A free zone user selling to a Delaware LLC must look through the LLC to the individuals holding 15 percent or more or controlling it.Ley Nº 19.574, art. 14, 15 and 16, art. 14 to 16, 2017-12-20 official text · verified 2026-10-27

3. Enhanced due diligence is required for higher risk clients and transactions, such as non residents, especially from countries that do not meet international AML standards, non face to face operations and new technologies that favour anonymity, and in all cases special procedures apply to politically exposed persons and their relatives and close associates, legal persons (especially those with bearer shares) and trusts. Politically exposed persons are those who hold or held in the last five years important public functions in Uruguay or abroad, or senior functions in international organizations. Simplified measures are allowed only for clients, products or operations shown to be low risk.
Cost to do it: Higher cost per client for source of funds and source of wealth checks on non residents and politically exposed persons.
Example: A developer selling a unit to a former minister who left office four years ago must apply enhanced checks. / A non resident US buyer paying for an apartment from abroad without visiting is in a higher risk category under art. 19.Ley Nº 19.574, art. 17 as reworded by Ley Nº 20.469 art. 1, art. 18, 19 and art. 20 as reworded by Ley Nº 19.670 art. 31, art. 17 to 20, 2026-03-19 official text · verified 2026-10-27

4. Records of all operations and all due diligence information must be kept for at least five years after the relationship ends or the occasional transaction is completed, or longer, up to ten years, if the regulation so provides, and must allow reconstruction of individual operations. Reports to the UIAF are confidential: the obligated party may not tell the client or third parties. After a report, the UIAF may instruct how to handle the transaction and the client; if it gives no instruction within three business days the obligated party may act as it sees fit. Good faith reporting does not breach professional or commercial secrecy and creates no liability. The UIAF may order obligated parties to block suspicious operations for up to five business days, informing the prosecutor, who may seek a court freeze.
Cost to do it: Cost of record keeping systems; no fee for reporting.
Example: A real estate agency that files a report on 2 November 2026 may proceed as it sees fit from 6 November 2026 if the UIAF has given no instructions. / A free zone trader blocked by a UIAF instruction must hold the US$ transfer for up to five business days and must not tip off the client.Ley Nº 19.574, art. 21, 22, 23 and 24, 2017-12-20 official text · verified 2026-10-27

5. Non financial obligated parties must register with the Secretaría Nacional para la Lucha contra el Lavado de Activos y el Financiamiento del Terrorismo (SENACLAFT) through the online procedure on the state portal and update their data within 30 days of any change. They must appoint a compliance officer, who may be the obligated party itself, to act as liaison with the UIAF and SENACLAFT, while responsibility stays with the obligated party. Offshore administration, accounting or data processing service providers supporting businesses that carry out financial activities abroad must also register with SENACLAFT.
Cost to do it: No registration fee is set in Decreto 379/018; cost of a compliance officer function.
Example: A newly formed Uruguayan company service provider must register with SENACLAFT and report a change of address within 30 days. / A US group's Montevideo shared service centre doing accounting for affiliates that operate financially abroad must check whether art. 25 registration applies.Decreto Nº 379/018 (regulation of Ley 19.574), art. 16, 92 and 93; Ley Nº 19.574 art. 25 as reworded by Ley Nº 20.469 art. 1, Decreto 379/018 art. 16, 92 and 93; Ley 19.574 art. 25, 2018-11-20 official text · verified 2026-10-27

6. Due diligence thresholds and triggers set by regulation include: casinos, for chip purchases, account openings, transfers and currency exchange above USD 3,000; real estate obligated parties, due diligence on every operation regardless of amount, for both buyers and sellers, and enhanced due diligence for any cash operation and for operations by bank instruments above USD 300,000; auctioneers selling antiques, art and precious metals or stones above USD 15,000; and dealers in antiques, art, precious metals and stones for operations of USD 15,000 or more with a client, aggregating linked operations within a calendar year. Non profits are obligated parties when annual income exceeds UI 4,000,000 or assets exceed UI 2,500,000.
Cost to do it: Thresholds: USD 3,000 (about UYU 120,630); USD 15,000 (about UYU 603,150); USD 300,000 (about UYU 12,063,000); non profit tests UI 4,000,000 (about UYU 26,716,800, US$664,432) income or UI 2,500,000 (about UYU 16,698,000, US$415,270) assets.
Example: A jeweller selling a UYU 700,000 watch (about US$17,409) to a client is above the USD 15,000 threshold and must complete due diligence. / A US buyer paying US$350,000 by wire transfer for a Montevideo apartment triggers enhanced due diligence by the real estate agency.Decreto Nº 379/018, art. 22, 30, 35, 51, 64 and 84, art. 22, 30, 35, 51, 64 and 84, 2018-11-20 official text · verified 2026-10-27

7. Laundering offences (converting or transferring, and acquiring, possessing or using assets from listed predicate crimes) carry 2 to 15 years of penitenciaría. Predicate crimes include drug trafficking, terrorism and its financing, smuggling above UI 100,000, corruption, and tax fraud under art. 110 of the Código Tributario when the tax evaded in any fiscal year exceeds UI 400,000, with no minimum when false invoices are used. For non financial obligated parties, SENACLAFT may impose warnings, observations, fines from UI 1,000 to UI 20,000,000 graded by the case, conduct and business volume, and suspension for up to three months, and may also fine directors and senior managers who did not act with due diligence.
Cost to do it: Administrative fines from UI 1,000 (about UYU 6,679, US$166) to UI 20,000,000 (about UYU 133,584,000, US$3.32 million); tax fraud predicate threshold UI 400,000 (about UYU 2,671,680, US$66,443).
Example: A builder who fails to identify cash buyers and to report can face a fine of up to UYU 133,584,000 and suspension for up to three months. / A company that evades more than UI 400,000 (about US$66,443) of tax in a year commits a predicate offence, so moving the proceeds can be prosecuted as laundering.Ley Nº 19.574, art. 30, 31 and 34; art. 13 as reworded by Ley Nº 20.469 art. 1, art. 13, 30, 31 and 34, 2026-03-19 official text · verified 2026-10-27

Sector	Trigger	Source
Casinos	Operations above USD 3,000	Decreto 379/018 art. 22
Real estate agents, developers, builders	Every sale, buyer and seller; enhanced for cash or bank operations above USD 300,000	Decreto 379/018 art. 30 and 35
Lawyers, notaries, accountants	Listed transactions for clients, not advice	Ley 19.574 art. 13 C, D and J
Auctioneers of art and precious goods	Sales above USD 15,000	Decreto 379/018 art. 51
Dealers in antiques, art, precious metals	Operations of USD 15,000 or more	Decreto 379/018 art. 64
Free zone operators and users	Uses and activities set by regulation	Ley 19.574 art. 13 G
Company and trust service providers	Forming companies, nominee roles, domicile, trustee services, sale of companies	Ley 19.574 art. 13 H
Non profits	Income above UI 4,000,000 or assets above UI 2,500,000	Decreto 379/018 art. 84

Who must report and the main due diligence trigger

Item	Amount	Approx. UYU	Approx. USD
Minimum administrative fine	UI 1,000	6,679	166
Maximum administrative fine	UI 20,000,000	133,584,000	3.32 million
Tax fraud predicate threshold	UI 400,000 per year	2,671,680	66,443
Laundering offence	2 to 15 years penitenciaría

Sanctions and penalties (UYU and USD at the rates in the FX note)

Worked example

Property sale: a foreign buyer pays US$420,000 by wire for a house in Maldonado through a local agency and notary. Both must identify the buyer and its beneficial owners holding 15 percent or more; the agency must apply enhanced due diligence because the bank payment exceeds USD 300,000 (Decreto 379/018 art. 35), and both keep the file for at least five years (Ley 19.574 art. 21).
Tax predicate: a company that underpays VAT and income tax by UYU 3,000,000 (about US$74,608) in one year exceeds UI 400,000 (about UYU 2,671,680); the evasion is a laundering predicate and the transfer of the proceeds can be prosecuted under art. 30 (Ley 19.574 art. 34).
Reporting: a free zone user files an unusual transaction report on Monday 2 November 2026; if the UIAF gives no instruction by Thursday 5 November 2026, the user may decide how to proceed from Friday 6 November 2026, without telling the client (art. 22).

Step by step

Check whether your activity falls under Ley 19.574 art. 12 or 13; if so, register with SENACLAFT online and keep data updated within 30 days of changes.
Appoint a compliance officer and write a risk analysis classifying clients and operations as high, medium or low risk.
Identify and verify clients and beneficial owners at 15 percent or control, with enhanced checks for non residents, politically exposed persons, trusts and complex structures.
Apply the sector thresholds of Decreto 379/018 and aggregate linked operations.
Train staff to spot unusual operations, report to the UIAF and never tip off the client.
Keep records for at least five years after the relationship ends, in a form that allows reconstruction of each operation.

Common traps

Lawyers, notaries and accountants are caught when they execute listed transactions, even if they also give advice; pure advice is excluded.
Real estate due diligence applies to both buyer and seller and to every sale, whatever the amount.
Any cash real estate payment triggers enhanced due diligence, separate from the general cash payment limits.
Tax fraud above UI 400,000 is a laundering predicate, so tax planning that crosses into evasion creates criminal AML exposure.
Directors and senior managers can be fined personally for AML failures of non financial obligated parties.
Tipping off a client about a report is prohibited and sanctionable.

Sources

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