Uruguay’s anti-money laundering law: obliged entities and duties

Uruguay tightened its anti-money laundering regime in 2017 with a comprehensive law that now reaches banks, notaries, real estate agents and almost anyone involved in transactions with money or property. This guide explains Uruguay’s AML law: who the obliged entities are, what they must do and what it means if you buy property, open a bank account or set up a company in Uruguay. For the wider picture, see financial regulation in Uruguay.

What counts as money laundering under Uruguayan law?

Conduct	Article	Penalty
Converting or transferring criminal proceeds	30	2 to 15 years
Acquiring, possessing, using or dealing with criminal proceeds	31	2 to 15 years
Concealing or altering evidence of the true origin or ownership of the assets	32	12 months to 6 years
Helping offenders secure the proceeds or evade justice	33	12 months to 6 years

• Standalone offence (Article 36): the predicate offence does not need to have been tried first.
• Self-laundering (Article 35): the person who committed the predicate offence can also be charged with laundering.
• The same law covers terrorist financing: funds suspected of financing terrorism must be reported even if their origin is lawful.

Predicate offences

• Drug trafficking, terrorism and its financing, arms trafficking and human trafficking.
• Public corruption offences.
• Smuggling above 100,000 UI.
• Tax fraud when the tax evaded in a fiscal year exceeds 400,000 UI, or with no threshold if false invoices or documents are used (wording set by Law 20.469 of March 2026).

Because tax fraud is a predicate offence, undeclared money from another country may be treated as criminal proceeds. Regularise your tax position at home before bringing it to Uruguay. See changing tax residency.

SENACLAFT and the UIAF

• SENACLAFT, the national anti-money laundering secretariat, sets national policy and supervises non-financial obliged entities.
• UIAF, the financial intelligence unit within the Central Bank, receives suspicious transaction reports from all obliged entities and supervises financial institutions.

Who are the obliged entities in Uruguay?

Group	Who	Supervisor
Financial (Art. 12)	Banks, exchange houses, financial services companies, insurers, securities brokers, investment advisers, professional trustees, fund managers and other BCU-supervised entities	BCU
Non-financial (Art. 13)	Casinos; real estate agents, developers and builders (in sales, not rentals); notaries and lawyers in certain transactions; auctioneers; dealers in antiques, art, precious metals and stones; free zone users and operators; corporate service providers; independent accountants in certain transactions; non-profits; sports companies, among others	SENACLAFT

What obliged entities must do

1. Customer due diligence (Art. 14): identify and verify the customer, understand the purpose of the relationship and monitor it. No anonymous accounts. See KYC and corporate compliance.
2. Identify the beneficial owner: the individual holding at least 15% of capital or votes, or exercising ultimate control (Art. 15).
3. Risk-based approach (Art. 16): simplified measures for low risk, enhanced for high risk.
4. Politically exposed persons (Art. 20): enhanced due diligence for anyone holding, or who held in the last five years, a prominent public role in Uruguay or abroad.
5. Keep records for at least five years after the relationship ends (Art. 21).
6. Report to the UIAF any unusual or suspicious transaction, without telling the customer.

Penalties for non-compliance

• Non-financial obliged entities: fines from 1,000 UI to 20,000,000 UI depending on severity and business volume.
• Financial institutions: the Central Bank’s sanctions regime, up to suspension or revocation of the licence.
• Criminal: the laundering penalties above, for anyone taking part.

Cash: borders and payments

• At the border (Art. 29): anyone entering or leaving with more than US$10,000 in cash, precious metals or bearer instruments must declare it.
• In payments: since Law 19.889 (2020), up to 1,000,000 UI of a transaction can be paid in cash; the rest must go through the banking system. In property purchases the notary records how the price was paid.

Family offices and wealth structures

Layered structures (a company owning another, a trust holding shares) attract the most questions from banks and notaries, because they must reach the individual behind them. Licensed family offices and professional trustees are financial obliged entities; trustees and corporate service providers must identify the beneficial owners of the structures they run. Keep a ready file documenting the family’s source of wealth (business sales, inheritances, dividends, tax returns): it will be requested again and again.

What it means for you

• Buying property: the notary and agent will ask for ID and source-of-funds documents, with more scrutiny if you are a non-resident or a PEP.
• Opening an account: the bank will ask for source of funds and your tax residency, which is also reported under the CRS.
• Setting up a company or trust: its beneficial owner must be identified and declared to the BCU.
• If your business is an obliged entity: you need a procedures manual, risk assessment, customer records and a reporting channel to the UIAF.

FAQ

Need an AML programme?

At GlobalTax we build AML manuals, risk matrices and due diligence procedures for obliged entities, and help clients and investors document their source of funds, in English, Spanish or Portuguese. See compliance and governance or contact us.