AML/CTF Glossary — Peru

Using AML/CTF prevention terms precisely makes communication with the SBS and the UIF-Peru easier, and strengthens regulatory compliance.

The system

• SPLAFT — Money Laundering and Terrorist Financing Prevention System. It is the set of policies and procedures that the obligated entity must implement while managing its risks.
• Risk-based approach — The principle of allocating more controls where the risk is greater, instead of applying the same measures to all counterparties.

Authorities

• SBS — Superintendency of Banking, Insurance and Private Pension Funds. It issues the regulation and supervises.
• UIF-Peru — Financial Intelligence Unit, part of the SBS. It receives and analyzes STRs.
• GAFILAT — Financial Action Task Force of Latin America, which evaluates the country against FATF standards.

Roles and obligations

• Obligated entity — An individual with a business or a legal entity that carries out any of the activities listed in article 2 of the regulation.
• Compliance Officer — Responsible for the SPLAFT. Since Resolution 2351-2023, the position may be held on a non-exclusive basis, while still supervising the system.
• Due diligence — The customer knowledge process. It has three levels: simplified, standard and enhanced, depending on the risk.
• Ultimate beneficial owner — The individual who ultimately owns or controls the customer.
• PEP — Politically Exposed Person. Requires enhanced due diligence because of their risk profile.
• ROS (STR) — Suspicious Transaction Report filed with the UIF-Peru. It is confidential: disclosing it to the customer is prohibited.
• Transaction register — Mandatory record of transactions that exceed the thresholds set by the regulation.
• Red flag — A pattern of behavior that, without being proof of a crime, requires the transaction to be analyzed in greater detail.

Do you have any questions about how a term applies to your organization? Contact us.