The Financial Investigation Unit (UIF) announced an update to its registry of Obligated Entities, carried out on January 30, 2026, as a result of the new Special Law for the Prevention, Control and Punishment of ML/TF/PF coming into effect.
The update was made on the UIF's own initiative and resulted in the deregistration of those sectors that are no longer listed as Obligated Entities in Article 7 of the new law.
For companies and professionals, this makes it necessary to review their current situation and confirm whether they remain subject to the obligations set out in the law.
What changed with the update?
The UIF changed the number of activities and professions registered in its system.
Those no longer listed in Article 7 were deregistered from the Registration System.
However, deregistration does not mean that every obligation related to client information disappears.
One obligation remains
Deregistered entities must keep records of their clients and of the transactions carried out for a period of no less than 15 years.
The UIF also stated that it will send an email notifying affected entities of their deregistration.
Who remains an Obligated Entity?
The new law keeps a range of sectors and activities within its scope.
Financial institutions
These include banks, insurance companies, pension fund administrators, currency exchange houses, electronic money providers, securitization firms, investment fund managers and other entities linked to the financial system.
Credit associations and entities
It also covers associations, companies, credit unions, federations and confederations regulated by the relevant law, as well as certain savings and credit companies.
Lending companies
Legal entities engaged exclusively in the systematic granting of loans are also included.
Casinos and gambling
The law includes casinos and companies engaged in operating games of chance.
Real estate sector
Individuals or legal entities that carry out real estate brokerage in the purchase and sale of property for their clients remain on the list.
It also covers certain professionals
One of the key points is that the law includes lawyers, notaries, accountants and auditors when, due to the nature of the services they provide, they carry out certain activities for their clients.
These include:
- Buying and selling real estate.
- Managing money, securities or other assets.
- Managing bank, savings or securities accounts.
- Organizing contributions for the creation, operation or management of companies.
- Creating, operating or managing legal entities or other legal structures.
- Buying and selling business entities.
The obligation therefore depends on the activities the professional carries out within the client relationship.
Other sectors included
The article also covers:
Precious metals and stones
Merchants engaged in these activities.
Transport of cash or valuables
Individuals or legal entities engaged in this activity.
Digital assets and bitcoin
Digital asset service providers and bitcoin service providers.
Political parties
Political parties are also listed among the Obligated Entities.
What should your company do?
First, don't assume that deregistration means there is no longer any obligation.
If your company still falls within the activities covered by the law, it must keep up with the corresponding compliance obligations. If it was deregistered, it must keep client and transaction records for the required period.
That's why it's advisable to:
01. Verify your status
Confirm whether your activity is still listed as an Obligated Entity or whether it was deregistered.
02. Review your obligations
Identify which compliance measures apply based on your company's line of business and activities.
03. Document your situation
Keep evidence of your status and of the measures adopted to support compliance in future reviews or requests.
04. Review your internal policies
If you remain obligated, make sure your policies, procedures, records and due diligence mechanisms are up to date.
Compliance starts with understanding what applies to you
The UIF update doesn't mean the same thing for every company. The first step is to determine whether your activity falls within the scope of the new law and which obligations apply to your case.
A proper review can help you avoid non-compliance and keep the processes needed to respond to a potential review documented.
Not sure whether your company is still an Obligated Entity?
At CENTR4L we help you review your situation and determine which ML/TF/PF obligations apply to your operations.
Let's talk about your company.
