The Central Bank of the Argentine Republic, together with the Financial Information Unit, published guidance for AML/CTF/CPF obligated entities on how to apply a risk-based approach to customers’ use of US dollars in cash and to adjust controls in light of the changes introduced by Law 27,799 and its implementing Decree 93/2026. The note highlights that, given Argentina’s macroeconomic context, holding foreign currency in cash may be economically rational and is not, on its own, an indicator of illicit activity. It reiterates that AML rules do not prohibit cash deposits regardless of amount and do not require asking for source-of-funds information at the teller as a condition for accepting a deposit, with the identification obligation limited to cases where the amount exceeds 40 times the Minimum, Vital and Mobile Salary (SMVM). Obligated entities are encouraged to treat a taxpayer’s enrolment in the Simplified Income Tax Return Regime as a favourable factor in risk assessments, to revisit thresholds and documentary demands where transactions align with the customer’s declared activity and economic profile and fall below the updated criminal tax-evasion threshold, and to update risk matrices and alert systems under Resolution 14/2023 (as amended) while maintaining obligations under AML Law 25.246 (as amended).
Central Bank of Argentina 2026-02-18
Central Bank of the Argentine Republic issues risk-based AML guidance on cash USD holdings and deposits following tax reform
The Central Bank of the Argentine Republic and the Financial Information Unit issued guidance for AML/CFT/CPF obligated entities on applying a risk-based approach to customers’ cash use of US dollars under Law 27,799 and Decree 93/2026. The note clarifies that holding or depositing foreign currency in cash is not inherently suspicious, that source-of-funds information at the teller is required only for deposits above 40 times the Minimum, Vital and Mobile Salary, and that enrolment in the Simplified Income Tax Return Regime may be treated as a favourable risk factor. Obligated entities must recalibrate thresholds, documentation requirements, risk matrices and alert systems under Resolution 14/2023 while maintaining compliance with AML Law 25.246.