Argentina's National Securities Commission publishes joint guidance on customer of the customer risk controls

Argentina's National Securities Commission has published joint guidance clarifying how obliged entities should apply the “customer of the customer” concept when clients manage or operate with third-party funds. The guidance establishes common criteria for proportionate, reasonable and documented identification and monitoring under anti-money laundering, counterterrorist financing and counter-proliferation financing controls. The guidance specifies that handling third-party funds does not automatically warrant a high-risk classification. Entities should assess each relationship based on its activity, transaction volume and controls, and may exchange information where justified and confidential, without turning requests into a parallel audit. It applies to financial institutions, payment operators, capital markets agents, insurers, mutual associations and cooperatives, and was developed with the Financial Information Unit, the Central Bank of Argentina, the National Insurance Superintendency and the National Institute of Associations and Social Economy.