Investment advisers in Uruguay: BCU licence, portfolio managers and requirements

Uruguay is a hub for regional wealth advisers serving clients from Argentina, Brazil and beyond, so the Central Bank regulates closely who can advise on or manage investments. This guide explains the licensed roles, what an investment adviser needs to obtain BCU authorisation, the process and the ongoing obligations. For the wider picture, see financial regulation in Uruguay.

Adviser, portfolio manager, broker and fund manager

Role	What it does	Decides for the client?	Holds client assets?
Investment adviser	Recommends securities investments and may route client orders to a broker	No	No
Portfolio manager	Manages each client’s investments on a discretionary, individual basis	Yes, within the mandate	No
Securities broker	Buys and sells securities for clients	Depends on mandate	Yes
Fund manager	Manages collective investment funds	Yes, under fund rules	Through a custodian

All need BCU authorisation and sit within the securities market framework (Law 18.627).

The investment adviser

An individual or company that advises third parties on investing in, buying or selling securities. It may advise on publicly offered securities (and, as a complementary activity, private ones), route client orders to authorised brokers in Uruguay or abroad, and refer clients. It may not receive or hold clients’ money or securities, nor make investment decisions for them.

The portfolio manager

Created by BCU Circular 2,320, in force since January 2019. It manages client investments on a discretionary and individual basis within the client’s mandate. Only companies can be portfolio managers, and guarantee and structural requirements are higher than for advisers. Assets stay with a broker or bank in the client’s name.

Authorisation requirements

1. Ownership transparency: shareholders and beneficial owners identified up to individuals, with registered shares.
2. Fit and proper owners, directors and advisory staff.
3. Guarantee in favour of the BCU, set in indexed units (UI) through surety insurance or collateral.
4. Compliance officer and AML policies. See KYC and compliance.
5. Code of ethics and good practice.
6. Client agreement templates and a description of services, including outsourced ones.
7. Operational information: office, opening hours and systems.

The BCU process

1. Choose the role (adviser or portfolio manager).
2. Set up the company if needed and file its beneficial ownership declaration.
3. Prepare the file: manuals, agreements, code of ethics, background of key people.
4. Apply to the Financial Services Superintendency and answer its comments.
5. Post the guarantee and obtain registration.

There is no statutory deadline: timing depends on the quality of the file and the BCU’s comments. Plan for several months and do not start advising before registration.

Ongoing obligations

• Know your client and their investor profile; recommendations must suit it.
• AML: as a financial obliged entity under Law 19.574, due diligence, monitoring and reporting to the UIAF.
• Reporting to the BCU and notice of changes in owners, directors or key staff.
• Keep the guarantee and fit-and-proper requirements.
• Transparency with clients on costs and conflicts of interest.

Non-resident clients and activity abroad

• A Uruguayan adviser may serve foreign clients, applying the same due diligence with closer attention to source of funds and tax position at home (where their accounts are reported under CRS).
• Opening offices abroad, or acting abroad through staff, attorneys or directors, requires prior BCU authorisation.
• A Uruguayan licence does not authorise advising in other countries: each jurisdiction regulates services offered to its residents.

FAQ

Want to advise on or manage investments from Uruguay?

At GlobalTax we identify the right licence for your business and prepare the BCU file, AML manual and corporate structure, in English, Spanish or Portuguese. See financial licences and regulation or contact us.