meta_id 3404103

On August 13, 2026, Argentina's Financial Intelligence Unit (UIF) and the Financial Supervisory Organisms (OCES) published guidance on interpreting and applying the "Customer of Customer" concept. The document constitutes a guide issued with the purpose of establishing clear guidelines, in order to clarify the regulatory expectation and facilitate the proper understanding and management of the risks of money laundering/terrorist financing/financial manipulation (ML/TF/FP) in the commercial relationships of obligated entities that have as clients other obligated entities that manage or operate with third-party funds. Furthermore, the guide has the explicit objective of promoting effective risk management without generating practices of financial exclusion or indiscriminate de-risking, aligning itself with FATF standards and the risk-based approach (RBA). The guidance clarifies that operating with third-party funds does not automatically result in a high-risk classification. Instead, authorities require case-by-case evaluation based on the activity, transaction volume, and controls applied. The document emphasizes proportionate, reasonable, and documented application of identification and monitoring measures. In order to understand and mitigate the ML/TF/FP risks involved in the operations of these types of clients and to prevent their transfer to the obligated entities, it is expected that both before the start of the business relationship and during it, the obliged entities will obtain sufficient knowledge of the ML/TF/FP prevention systems adopted by their clients. In this regard, they are authorized to hold meetings with their client's Compliance Officer and/or their team to request reports and/or documents. The guidance applies to financial entities, payment operators, capital market agents, insurance companies, mutual associations, and cooperatives.