KYC and corporate compliance in Uruguay: a practical guide

In Uruguay, corporate compliance is no longer just for banks: notaries, real estate agents, accounting firms, trustees and corporate service providers must know their customers and document it, and any company opening an account or buying property goes through the same process from the other side. This guide explains KYC and entity compliance in Uruguay: who must comply, how to build a programme and what documents are required. For the wider picture, see financial regulation in Uruguay.

Compliance and KYC: what each one is

• Compliance is the set of policies and controls an organisation uses to meet the rules that apply to it: AML, tax transparency, data protection, sector regulation.
• KYC is one part of it: identifying the customer, verifying who they are, knowing who is behind them (the beneficial owner) and understanding where their money comes from.

Who must have compliance and KYC in Uruguay?

• Financial institutions supervised by the Central Bank (BCU): banks, exchange houses, insurers, brokers, investment advisers, professional trustees, fund managers and virtual asset service providers. They face the strictest rules.
• Non-financial obliged entities (Law 19.574, Article 13, regulated by Decree 379/018): real estate agents and builders, notaries, lawyers and accountants in certain transactions, casinos, auctioneers, corporate service providers, free zones and others. See the full list.
• Other companies are not obliged by law but experience KYC as customers of banks, notaries and international suppliers.

Elements of a compliance programme

1. Risk assessment of customers, products, channels and countries.
2. Written procedures manual: how customers are accepted, which documents are required, when due diligence is enhanced.
3. Compliance officer: for non-financial obliged entities this can be the owner (Decree 379/018, Article 16).
4. Customer due diligence (KYC itself).
5. Transaction monitoring to spot unusual activity.
6. Reporting suspicious transactions to the UIAF without tipping off the customer.
7. Record keeping for at least five years.
8. Regular training for staff involved in transactions.

KYC step by step

Customer	Information required
Individual	Full name, date and place of birth, ID document, address and occupation. Under enhanced due diligence, also marital status and spouse or partner details.
Legal entity	Name, date and place of incorporation, articles, shareholders with 15% or more of capital or votes, and directors with their ID. Under enhanced due diligence, information on its tax position.

1. Identify and verify using documents and independent sources.
2. Identify the beneficial owner through every layer of companies or trusts.
3. Understand the purpose and expected activity.
4. Document the source of funds where risk or amount justifies it.
5. Screen against PEP and sanctions lists.
6. Monitor and update throughout the relationship.

Simplified, standard and enhanced due diligence

Level	When
Simplified	Low-risk customers and transactions, based on the entity’s documented analysis.
Standard	The general case.
Enhanced	Politically exposed persons (current or within the last five years), high-risk jurisdictions, complex structures, unusual or cash transactions.

What a Uruguayan bank will ask your company for

• Articles of incorporation, Commerce Registry entry, and tax (RUT) and social security (BPS) registration.
• Board appointment minutes and IDs of directors and attorneys.
• Share register or ownership certificate, all the way up to individuals.
• Proof of the beneficial ownership filing with the BCU.
• Financial statements or, for a new company, a business plan and source of capital.
• CRS self-certification and, if there is a US link, FATCA forms (W-9 or W-8).

Foreign shareholders’ documents must be apostilled and translated into Spanish. See apostille and legalisation.

Other transparency obligations

• Beneficial ownership: every Uruguayan company must declare its beneficial owner to the BCU and update it when it changes (Law 19.484). See beneficial ownership in Uruguay.
• CRS: banks report accounts of foreign tax residents to the DGI, which exchanges them automatically with other countries. See FATCA and CRS in Uruguay.

FAQ

Need to build or review your compliance programme?

At GlobalTax we run the risk assessment, draft the manual, support your compliance officer and prepare your company’s KYC file for banks and partners, in English, Spanish or Portuguese. See compliance and governance or contact us.