Is your company an obliged entity before UIF-Perú?
If your company carries out certain activities, the law requires it to prevent money laundering and report to UIF-Perú. This guide explains who is obliged, what they must implement and how to get started.
Many companies find out they are an obliged entity when a bank asks for their prevention manual or when they receive a notice from UIF-Perú. Knowing it in time lets you put controls in order without rushing and avoid penalties.
What is an obliged entity?
A so-called obliged entity (sujeto obligado) is an individual or company that, because of its activity, must implement a system to prevent money laundering and terrorist financing (PLAFT) and provide information to UIF-Perú, Peru's Financial Intelligence Unit, which is part of the Superintendency of Banking, Insurance and Pension Funds (SBS).
The legal basis is Law No. 27693, which created UIF-Perú, and Law No. 29038, which sets the list of obliged entities. That list has grown over the years; for example, virtual asset service providers were added in 2023.
Which activities are obliged entities?
Besides banks, insurers and other financial institutions, the law covers non-financial activities where the risk of money laundering is higher. Among others:
- Companies in construction and real estate.
- Trading of vehicles and machinery.
- Trading of jewelry, metals and precious stones.
- Currency exchange houses and lending or pawn businesses.
- Customs agents and notaries.
- Organizations that receive donations or contributions from third parties.
- Professional firms of lawyers and accountants, when they carry out certain transactions on behalf of their clients.
- Virtual asset service providers, such as crypto-asset exchange or custody.
Each activity has its own conditions. A construction or real estate company, for example, may be obliged only for certain types of transactions. In the assessment we verify whether your company is within scope.
What must an obliged entity implement?
For obliged entities supervised directly by UIF-Perú, the main regulation is SBS Resolution No. 789-2018 and its amendments. In short, it requires:
| Obligation | What it involves |
|---|---|
| Compliance officer | Appoint the person responsible for the system and notify UIF-Perú within 15 business days. |
| Manual and code of conduct | Approve a prevention and risk management manual and a code of conduct, and keep them up to date. |
| Risk assessment | Identify and assess the money laundering risks of your activity and apply proportionate controls. |
| Due diligence | Identify and verify clients, beneficial owners, employees and suppliers, with an enhanced regime for higher-risk cases. |
| Transaction register | Record transactions above the thresholds set for your sector, completely and on time. |
| Suspicious transaction reporting | Analyze unusual transactions and report to UIF-Perú those found to be suspicious. |
| Training | Train staff at least once a year and onboard new employees within their first 30 days. |
| Annual report | Submit the compliance officer's annual report to UIF-Perú. |
Who can be the compliance officer?
The compliance officer is an individual who makes sure the system works, trains the team, evaluates unusual transactions and acts as the point of contact with UIF-Perú. They must meet suitability requirements: relevant experience, no convictions for intentional crimes and no significant overdue debts, among others.
They may work on a non-exclusive basis. In small companies, the general manager may take on the role only if the company meets certain conditions at the same time: being a micro or small business, having up to ten employees, not belonging to an economic group and carrying out a single obliged activity.
What happens if you don't comply?
UIF-Perú supervises obliged entities and can impose fines for failing to implement the system, appoint the compliance officer, record transactions or report them. There is also a business cost: more and more banks and corporate clients ask for prevention and due diligence policies before working with a company.
How to implement PLAFT in your company
- Assessment: confirm whether you are an obliged entity and what risks your activity carries.
- Design: draft the manual, the code of conduct and the due diligence procedures.
- Appointment: appoint the compliance officer and notify UIF-Perú.
- Implementation: train the team and set up the records and controls.
- Follow-up: review the system, submit the annual report and update the risk assessment.
At Grupo Spectra we support you throughout the process with our AML program (PLAFT), and if your company also runs complex projects, you can add our project management using the PMBOK methodology.
This guide is for information purposes and summarizes the regulations in force as of October 2026. Rules change; before making decisions, review your case with a specialist.
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