Knowing the customer is where AML starts, not where it ends.

What AML requires in Argentina

AML stands for anti-money laundering, and in Argentina it translates into the regime for preventing money laundering and terrorist financing. It is established by Law 25,246 and its enforcement authority is the UIF, which issues the obligations of each type of obligated party, oversees them and receives the reports.

The regime does not end at sign-up. It is organized as a cycle that starts before the customer is onboarded and continues for as long as the relationship lasts.

• Self-assessment and internal policy — the obligated party analyzes the risk of its customers, its products and its channels, and appoints a compliance officer on the basis of that analysis.
• Customer identification and knowledge — KYC, which is the entry point of the cycle and the one that produces the evidence on which everything else rests.
• Beneficial ownership — when the customer is a legal entity, the analysis has to reach the individuals who ultimately control it or benefit from it. A corporate structure cannot be the end of the analysis.
• Monitoring, lists and reporting — ongoing tracking of transactions against the declared profile, screening against restricted lists and reporting to the UIF of what monitoring detects, with the customer file retained for the supervisor.

All of that runs on a risk-based approach: the intensity of each measure is scaled by each customer's risk, and the obligated party has to be able to explain the scaling it applied. Customers who qualify as a politically exposed person receive enhanced diligence.

The Argentine framework was not written in a vacuum: it follows the international standard set by the FATF for anti-money laundering, the same one from which the regimes in the rest of the region derive. That is why a team already operating under the Colombian or Mexican regime recognizes the structure, even though the bodies, deadlines and forms are different.

What VU automates in AML

It is worth starting with the limit, because on this topic it is larger than the contribution.

What VU does not do:

• It does not do transaction monitoring. Tracking a customer's transactions against their profile and detecting deviations is a control over business data that lives in the obligated party's systems.
• It does not generate or file the suspicious transaction report. The suspicious transaction report (ROS, its Spanish acronym) is a human decision with regulatory consequences, and it is signed by someone with a name and responsibility.
• It does not determine the beneficial owner. Unwinding a corporate structure down to the individuals who control it is documentary and corporate analysis, not identity verification.
• It does not classify the customer's risk or replace the compliance officer.

What it does handle is the identification link on which all the others depend: if the sign-up did not establish with certainty who that person is, later monitoring is following a name and not someone.

• Identity verification at sign-up — reading of the Argentine document, biometric matching and liveness detection. VU can provide technical evidence of the identity process depending on the configuration implemented.
• Evidence of the process — the record of how that person was identified, available later without reconstructing it from three different systems.

• Identification of the individuals behind a company — once the KYB process has defined who has to be identified, verifying each of those people is the same flow.

Use cases in Argentina

Where this problem shows up in the real operation of the Argentine market.

• Virtual asset service providers. The newest category of obligated party, with the greatest reputational exposure and no legacy process to copy from.

• Financial institutions under dual supervision. They answer to the UIF and the BCRA at the same time, and the two look at different evidence from the same process.

• Companies that discover their obligated-party status late. They have to set up self-assessment, a manual, a compliance officer and monitoring over a portfolio that is already live.

• Portfolios onboarded under old standards of evidence. The duty to keep information up to date forces a return to customers whose file does not withstand a current review.

• Multi-layered corporate structures. Reaching the beneficial owner when companies control companies is where the process becomes manual and slow, and where the risk concentrates.