As of October 15, 2026, banks, finance companies and fiduciary companies must submit trust agreements, amendments and related documentation through the Financial Communication Network (RCF).

The Superintendency of Banks of the Central Bank of Paraguay (BCP) has introduced a mandatory procedure for submitting documentation related to fiduciary transactions.

Under Circular SB.SG. No. 166/2026, dated October 15, 2026, trust establishment agreements, amendments and other related documents must be submitted exclusively through the Financial Communication Network (RCF).

The measure implements Article 11(d) of Resolution No. 12, Act No. 9, dated February 15, 2011, and applies to banks, finance companies and fiduciary companies.

What changes under the new procedure?

Previously, institutions could submit this documentation through the Superintendency of Banks' document reception office.

Under the new circular, all submissions must be made through the designated RCF module, following this path:

Planinfo → Fideicomiso → Mantenimiento → Negocios Fiduciarios.

Documents must therefore no longer be submitted through the Superintendency's document reception office.

The new procedure applies from October 15, 2026, the date the circular was issued.

Implications for affected institutions

Although the circular does not substantially change the legal framework governing trusts, it introduces a change to regulatory compliance procedures.

Banks, finance companies and fiduciary companies will need to adapt their internal document-submission processes, ensure that responsible teams understand the new procedure and verify that they have the necessary system access.

Institutions should also review their internal procedures for approving, executing and submitting trust agreements, particularly when multiple departments are involved.

Considerations for fiduciary transactions

Trusts are frequently used in structured finance and project finance transactions to manage assets, cash flows and collateral.

In these transactions, coordination among the parties, legal advisers and the fiduciary institution is essential to ensure that contractual documentation is properly executed and submitted.

The digitalization of regulatory procedures also requires institutions to adapt their internal document-control and traceability mechanisms.

From a legal perspective, it is important to distinguish between the proper execution of a trust agreement and compliance with administrative obligations to submit documentation to the regulator.

Both aspects should be addressed within institutions' compliance procedures, alongside effective coordination among legal, fiduciary and compliance teams.