AML/CTF prevention system for NGOs and foundations in Peru
In Peru, NGOs, foundations and other non-profit organizations (OSFL) that raise, transfer or disburse funds for charitable purposes are obligated entities with a duty to report. So are those that carry out international technical cooperation, under article 3.2 of Law 29038, as amended by Law 32301 of April 2025. They apply a limited-scope anti-money laundering and counter-terrorist financing prevention system (SPLAFT).
Supervision falls to the Peruvian International Cooperation Agency (APCI), the Foundations Oversight Council (CONSUF) or Peru's Financial Intelligence Unit (UIF-Perú). If the OSFL grants loans or microloans, the general regime applies and the UIF-Perú is the sole supervisor. If your NGO raises or delivers charitable funds, it is already obligated. Líderes APLA has advised Peruvian foundations and NGOs, and follows the money: from the cooperation partner or donor to whoever receives the aid.
Is your NGO or foundation obligated under the SPLAFT?
| Scenario | Condition or threshold | Supervisor | Regulation |
|---|---|---|---|
| OSFL registered with the APCI (as an ONGD, ENIEX or IPREDA: development NGO, foreign cooperation entity or private donation-receiving institution) or with the CONSUF | Funds for charitable purposes or international technical cooperation; no threshold | APCI or CONSUF | Law 29038, art. 3.2; SBS Res. 369-2018 |
| Unregistered OSFL, or one that receives funds those entities do not supervise | Same activities; no threshold | UIF-Perú | SBS Res. 369-2018, art. 2, item 9 |
| OSFL that grants loans, microloans or other financing | General SPLAFT; transaction records from US$5,000 | UIF-Perú only | SBS Res. 789-2018, art. 43 |
Carrying out international technical cooperation requires registration with the APCI (Law 27692, as amended by Law 32301).
Elements of the limited-scope SPLAFT in NGOs and foundations
- Non-exclusive Compliance Officer: even the general manager may hold the role. The officer needs a direct employment or contractual relationship with a single organization (SBS Res. 369-2018, arts. 6 and 7).
- Designation via SISDEL (the electronic system for registering Compliance Officers): the UIF-Perú assigns the officer secret codes to report confidentially (art. 8).
- List screening: OFAC, UN Security Council and European Union lists, and immediate enforcement of any freezes ordered by the SBS (Superintendency of Banking, Insurance and Private Pension Funds) (art. 14).
- Detection and ROS: document the analysis of unusual transactions and report suspicious ones through a suspicious transaction report (ROS), whatever the amount (art. 15).
- Record retention: system documentation, for at least five years (art. 16).
If the NGO grants loans, the general SPLAFT adds a manual, a code of conduct, due diligence and transaction records. SBS Res. 789-2018 treats both the donor and the recipient of the donation as customers.
Reports and deadlines with the UIF-Perú
| Report | To whom | Deadline |
|---|---|---|
| Suspicious transaction report (ROS) | UIF-Perú | Within 24 hours of being classified as suspicious |
| Designation of the Compliance Officer | Supervisor and UIF-Perú, via SISDEL | 15 business days from designation |
| Transaction records (only if it grants loans) | UIF-Perú | Loans and donations from US$5,000; prepayments from US$2,500 |
| Compliance Officer's annual report (only if it grants loans) | UIF-Perú, via the PLAFT portal (the UIF-Perú's online reporting portal) | By February 15 of the following year |
Red flags in NGOs and foundations
They are based on Recommendation 8 of the GAFI (the Financial Action Task Force, FATF), as set out by GAFILAT, its Latin American regional body, and on the requirements of Peruvian regulations:
- Donations from unidentifiable sources, or donors who will not provide their details.
- Funds coming from or going to conflict zones or high-risk areas.
- Resources directed to purposes, locations or beneficiaries other than those of the project.
- Donors, directors or beneficiaries who match UN or OFAC lists.
- Prepaid microloans with no explanation of where the money came from.
Penalties for non-compliance
An association or foundation risks from 7 to 100 tax units (UIT) for a very serious infraction, from 2 to 20 for a serious one and from 0.5 to 10 for a minor one. This is set by the Regulation on Infractions and Penalties of SBS Res. 8930-2012 (art. 3 of SBS Res. 369-2018). Separately, the APCI can impose fines of up to 500 UIT for infractions related to international technical cooperation (Law 32301).
How Líderes APLA implements the SPLAFT at your NGO or foundation
- Regime assessment: limited-scope or general regime, and your supervisor.
- Risk matrix: by funding source, cooperation partner, program, geographic area and beneficiary.
- Donation acceptance policies: donor identification, list screening and use of funds; if you grant loans, a manual and code of conduct.
- Officer onboarding: SISDEL and the ROS workflow; if you grant loans, transaction records and the annual report. AplaSoft supports list screening.
- Training: for the board of directors, the officer and the project team, with e-learning courses.
We provide this service through our AML/CTF Consulting in Peru; see the regulations and the glossary.
Does your NGO receive international cooperation funds or plan to offer microloans? Request a free assessment of your organization.
Updated: October 2026.
Frequently asked questions
Is every NGO in Peru an obligated entity before the UIF-Perú?
Who supervises a foundation's SPLAFT?
Does my NGO need to keep transaction records?
What does the foundation do if a donor matches the UN list?
How much does it cost to find out which regime applies to my NGO?
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