SPLAFT for the Securities Market in Peru: SAB, SAF and SAFI

SPLAFT for obligated entities in the securities market

In Peru, stock brokerage firms (SAB), securitization companies and mutual fund (SAF) or investment fund (SAFI) management companies must implement a SPLAFT. The SPLAFT is the anti-money laundering and counter-terrorist financing (AML/CTF) prevention system. These entities are supervised by the Superintendency of the Securities Market (SMV), in coordination with Peru's Financial Intelligence Unit (UIF-Perú).

The governing rule is CONASEV Resolution 033-2011-EF/94.01.1 (CONASEV being the SMV's predecessor), last amended by SMV Resolution 006-2025-SMV/01. Since 2025, due diligence also covers the clients your entity already has. Líderes APLA tailors the SPLAFT to the portfolio of each SAB, SAF or SAFI: investor type, order size and onboarding channel.

Is your company subject to the SMV's SPLAFT?

The SMV's SPLAFT depends on the activity, not on size. A newly authorized obligated entity may have a part-time Compliance Officer for six months.

Elements of the SPLAFT in the securities market

• Full-time Compliance Officer. Holds a managerial position and reports to the board. The appointment is notified to the SMV and the UIF-Perú within 15 calendar days.
• Ongoing due diligence of the client and its beneficial owner. Since 2025 it covers the entire business relationship and is enhanced for jurisdictions the FATF (GAFI) deems non-cooperative or for the OFAC (US Office of Foreign Assets Control) list.
• Countermeasures against high-risk countries. Article 7A requires applying the countermeasures set by a rule with the force of law when the FATF calls for them.
• Transaction register. It includes transactions from US$10,000 and multiple transactions by the same person totaling US$50,000 in a month. You must identify who carries out the transaction, on whose behalf, and the beneficiary.
• Manual and code of conduct. Both are approved by the board, and the code is disseminated to all staff.
• Annual training. For all staff; the officer receives at least two specialized sessions a year.

ROS, transaction register and deadlines with the UIF-Perú and the SMV

The transaction register is kept for ten years (art. 24 of Supreme Decree 020-2017-JUS). A copy is delivered to the SMV or the UIF-Perú within 48 hours.

Red flags in the securities market

Annex I of CONASEV Resolution 033-2011 includes, among others:

• Prearranged trades at off-market prices, or fictitious trades.
• Repeated trades between the same parties, with continuous gains or losses for one of them.
• Dormant accounts that suddenly move large sums without justification.
• A client who trades for a hidden principal and is unwilling to identify them.
• A client who asks, without cause, to be excluded from the transaction register.

Penalties for failing to comply with the SPLAFT

Failing to report a suspicious transaction may constitute a crime, the sector rule warns. In addition, the SMV penalizes infractions under its Penalties Regulation (SMV Resolution 035-2018-SMV/01).

How Líderes APLA implements the SPLAFT in your brokerage firm or fund manager

1. Assessment of the system against the SMV rule and its 2025 amendments.
2. AML/CTF risk matrix by product (equities, funds, securitizations) and channel, with investor scoring.
3. Manual and code of conduct for the board, with ongoing due diligence and the art. 7A countermeasures.
4. Training for the officer and staff through our e-learning courses.
5. The officer's semiannual reports and the ROS workflow, with AplaSoft to log every OFAC and UN list check.

Delivered as part of our AML/CTF Consulting in Peru. SMV rules: regulations; acronyms: glossary.

Is your SAB, SAF or securitization company already applying the ongoing due diligence required since 2025? Request a free assessment of your SPLAFT.

Updated: October 2026.