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09/01/2024

Through Resolution No. 126 dated October 16, 2023, the Secretariat for the Prevention of Money Laundering ("SEPRELAD") approved the procedures and requirements for the deregistration of Obligated Subjects without natural supervision.

Obligated Subjects without natural supervision are understood to be natural or legal persons that are not directly regulated by a government entity. These include:

  1. Pawnshops;
  2. Real estate agencies;
  3. Non-profit organizations ("NPOs");
  4. Money transfer services;
  5. Merchants of jewelry, precious stones and metals, art objects, and antiques; and,
  6. Individuals and legal entities engaged in philatelic or numismatic investment.

According to the new procedure, to deregister due to reasons such as a change in economic activity, dissolution, and/or business closure, Obligated Subjects without natural supervision must submit a request addressed to the highest authority of SEPRELAD requesting deregistration. This request should be accompanied by the Unique Taxpayer Registry ("RUC") certificate, an authenticated copy of the owner's or legal representatives' Identity Card, as well as a certificate of compliance with anti-money laundering and counter-terrorism financing measures issued by the General Directorate of Supervision and Regulation of SEPRELAD. In addition to the aforementioned documents, legal entities that are obligated subjects must submit an authenticated copy of the minutes of the assembly, whether ordinary or extraordinary, in which the suspension or cessation of activity or business closure was discussed. In the case of NPOs, the minutes mentioning dissolution and/or social change should be presented.

Within a maximum period of 10 (ten) business days, the General Directorate of Supervision and Regulations of SEPRELAD will issue the certificate, with the possibility of requesting additional documentation it deems pertinent, leading to the suspension of the stipulated period.

The regulations also consider the possibility of reinstatement for those Obligated Subjects who deregistered, provided they comply again with all the requirements established for registration in the registry of Obligated Subjects without natural supervision of SEPRELAD. 

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