Entry into Force of the New Organic Law on the Prevention, Detection, and Combating of Money Laundering and the Financing of Other Crimes

Today, July 29, 2025, the new Organic Law on the Prevention, Detection, and Combating of Money Laundering and the Financing of Other Crimes came into force. This law replaces the former 2016 legislation and aims to strengthen the regulatory framework in this area, aligning it with the international standards set by the FATF.

What are the most relevant changes compared to the 2016 Law?

1. Expansion of Scope: The financing of weapons of mass destruction is now included as a conduct to be prevented.

    2. Updated Definitions: The regulatory glossary has been expanded to include terms such as virtual assets and ultimate beneficial owner, providing greater clarity on obligations.

    3. Creation of CONCLAFT: A National Council for Coordination Against Money Laundering (CONCLAFT) is established as a collegiate body for inter- nstitutional coordination.

    4. New Obligated Entities: The definition of obligated entities has been revised and expanded to include actors such as virtual asset service providers, among others.

    5. Cash Use Prohibition: The use of cash, precious stones, and precious metals is prohibited for transactions equal to or exceeding USD 10,000, promoting the use of the financial system.

    6. Compliance Programs: Obligated entities must implement internal risk prevention and management programs, which will be independently audited.

    7. Strengthening of the UAFE: The Financial and Economic Analysis Unit (UAFE) will have expanded powers, including the ability to regulate and sanction obligated entities.

    In addition, the law maintains the obligation to identify and report suspicious transactions, now with stricter due diligence criteria—especially for politically exposed persons (PEPs). Companies must adapt their internal policies, train staff, and establish reporting mechanisms to comply with these new standards. Proper preparation is crucial to avoid sanctions and reputational risks.

    Abstract

    The entry into force of the new Anti-Money Laundering Law introduces a stricter framework aligned with international standards. The regulation expands the scope of oversight, strengthens institutional coordination through CONCLAFT, and grants UAFE broader sanctioning powers. It also redefines and expands the range of obligated entities, prohibits the use of cash for significant transactions, and incorporates a risk-based approach across all policies and procedures. Proper preparation is key to avoiding sanctions and reputational risks.

    Key Points

    Immediate Effect: The new law comes into force on July 29, 2025.
    Expanded Scope: Includes financing of weapons of mass destruction and virtual assets.
    New Institutions: Establishment of CONCLAFT and strengthening of UAFE.
    Broadened Obligated Entities: More actors under oversight, including virtual asset service providers, lawyers, accountants, and notaries.
    Cash Prohibition: Transactions equal to or exceeding USD 10,000 must be conducted through the financial system.
    Enhanced Compliance: Internal programs must adopt a risk-based approach, with stricter penalties for non-compliance.

    For more information, contact us at the following email addresses:

    María Rosa Fabara: mrfabara@bustamantefabara.com
    Diego Ramírez: dramirez@bustamantefabara.com
    Daniel Castelo Guerrero: dcastelo@bustamantefabara.com
    María Cristina Alvaracín: malvaracin@bustamantefabara.com