printable version | October 2021
Although the mere fact of being registered in the Registry of Providers of Specialized Services or Specialized Works, known as REPSE, does not necessarily imply the obligation to register in the Anti-Money Laundering portal, it is essential to review the type of service provided, since this is what triggers the corresponding obligation.
The above, since, according to the criteria published by the Financial Intelligence Unit, "What triggers the obligation to carry out the registration and registration process as a Vulnerable Activity is that the service provided is carried out in terms of section b) of section XI of article 17 of the LFPIORPI, that is, that the administration and management of resources, securities or any other asset of the clients is prepared for the client or is carried out on behalf of and representing the client, regardless of whether or not said administration includes the power to make decisions on the destination of said resources, securities or assets and the service provider is limited to following the instructions of the client."
Although the criteria are not binding, they do serve as a reference and guide to clarify the question that existed regarding the obligation to register. Therefore, we recommend verifying the nature and type of obligations under the service contract to determine whether or not to register on the Anti-Money Laundering portal and avoid any contingency.
***The publication of this note does not constitute legal advice, nor is it intended to be applicable to particular cases.
If you require additional information, please contact the partner responsible for your matters or one of the lawyers mentioned below:
