• Several governmental agencies are included as competent authorities responsible for money laundering detection and prevention, such as the Financial Analysis Unit, the Monetary Board, the Insurance Superintendence, the Securities Superintendence, the Pension Fund Superintendence, the Private Security Superintendence, the General Customs Directorate, the Casinos and Gaming Directorate, the Credit Cooperative and Development Institute.
• The new term “preceding or determinant infraction” is created for infractions that constitute money laundering such as child pornography, traffic of influences, crimes committed by public officials while in office, transnational bribes, tax evasion, aggravated fraud, smuggling, counterfeiting, copyrights infringement, crimes against intellectual property, forgery of public documents, medicine, food and beverage falsification and adulteration, illicit traffic of merchandise, arts, jewelry and sculptures, aggravated robbery, financial crimes, technological crimes and felonies, improper use of confidential or privileged information, and market manipulation.
• There is a broader definition of money laundering and higher standards of compliance by the government, private corporations and their employees.
• New guidelines for financial regulated parties that must be complied with by trust companies, savings and loan cooperatives, reinsurance companies, investment funds, securitization companies, broker/dealers, depository trust corporations, issuers of public offerings that distribute securities directly to the public, lotteries and sports betting companies and concessionaries, factoring companies, pawn houses, and construction companies.
• There are also compliance obligations for non-financial parties such as lawyers, notaries, and accountants, who will also be bound to the provisions of the Law when participating in transactions on behalf of their clients by performing one of the following activities: (i) purchase, sale or remodeling of real estate; (ii) asset management; (iii) bank or brokerage account management; (iv) organize contributions for the creation, operation or administration of companies; (vi) incorporation, operation or administration of companies and other legal entities, and purchase and sales of companies; (vii) the incorporation of companies, any capital modifications, merger, acquisitions or stock sales; (viii) act as agent for the incorporation of companies; (ix) act as director, authorized person or shareholder or other similar position in a company; (x) provide a registered, commercial, postal or administrative domicile for a company or any other legal entity; (xi) act or arrange for a person to act as a nominal stockholder for other parties.
• All regulated parties (financial and non-financials) must adopt, develop and execute a compliance program focused on a risk based approach, with policies and procedures to: (i) evaluate money laundering and terrorist financing risks; (ii) manage and mitigate risk; (iii) practice client due diligence or enhanced due diligence; (iv) continued monitoring; (v) maintain transaction registries; (vi) designate a compliance officer and determine its functions; (vii) report unusual transactions to the Financial Analysis Unit; among others.
• In certain cases, the obligated parties must implement a due diligence process prior to initiating a commercial relationship with a client. The term of one year was granted to update the records of current clients.
• In the case of clients identified as Politically Exposed Persons, an extended due diligence must be performed.
• The Law establishes limits on payments in cash for the transfer, acquisition, participation, and use of real estate, motor vehicles, airplanes, cargo ships, watches, jewelry, lottery and sports betting tickets and prizes, and stocks or shares; unless, reliable proof is provided with regards to the payment method.
• Cash transactions from USD 10,000.00 to USD 15,000.00 trigger registration and reporting obligations by the regulated parties to the anti-money laundering authorities.
• There is a 5-days maximum deadline to file an unusual transaction report before the anti-money laundering authorities.
• A new catalog of infractions is created with different sanctions depending on the severity of the infraction.

In order to comply with the Law, regulated parties will need to create new compliance programs or enhance their current programs to make sure those contain sufficiently robust policies, procedures and controls.

The Tax Agency is the institution appointed to oversee the enforcement of the Law for non-financial obligated parties. For each sector of the non-financial obligated parties, the Tax Agency has published specific sectoral rulings of mandatory compliance.