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Mining · Peru

SPLAFT for Mining Companies and Gold Trading in Peru

Peru See also: Ecuador · Colombia

AML/CTF prevention system for mining companies that trade gold

In Peru, a mining company holding a concession that buys, sells, imports or exports gold is an obligated entity. It must have an anti-money laundering and counter-terrorist financing prevention system (SPLAFT). It is supervised by Peru's Financial Intelligence Unit (UIF-Perú), under Law 29038 and article 38 of SBS Resolution 789-2018, issued by the banking and insurance regulator (SBS).

According to the UIF-Perú's analysis, between 2013 and 2023 suspicious transaction reports (ROS) with a possible origin in illegal mining totaled US$19,543 million. Each supplier's file is your first line of defense. Líderes APLA has advised mining companies in Peru and starts there: concession or REINFO (mining formalization registry) status, area and method of payment.

Yellow front loader at an open-pit mine in the Andes, with a rocky peak behind
Yellow front loader at an open-pit mine in the Andes, with a rocky peak behind.

Is your mining company required to have a SPLAFT?

Scenario Condition or threshold Supervisor Regulation
Legal entity or individual with a business, operating under concessions, that buys, sells, imports or exports raw or semi-processed gold By activity, no size threshold UIF-Perú Law 29038, art. 3; SBS Res. 789-2018, arts. 3 and 38
Mining company that does not trade gold (for example, copper or zinc) Does not fall within the definition of mining company — SBS Res. 789-2018, art. 3, item 19
Gold or precious stone trader without a concession Obligated as a precious metals dealer UIF-Perú SBS Res. 789-2018, art. 38

The US$15,000 threshold only determines which transactions are recorded.

Elements of the SPLAFT in gold mining

  • Compliance Officer: with experience in the activity or in AML/CTF, a direct relationship with the company and autonomy (art. 6). The role may be part-time. The general manager may hold it only in companies in SUNAT's MEPECO category (medium and small taxpayers) that meet art. 5.5.
  • Know your customer: for the mining company, a customer is anyone who buys gold from it, sells gold to it, or imports or exports it. The general or enhanced regime applies, with the beneficial owner identified.
  • Know your suppliers: due diligence on gold collectors and small-scale miners (art. 18), including their status in the Comprehensive Mining Formalization Registry (REINFO).
  • Transaction register (RO): gold purchases, sales, exports and imports from US$15,000, recorded on the same day. You may set lower internal thresholds.
  • Manual and code of conduct: with staff training according to their duties (arts. 20, 21 and 24).
  • Risk assessment: by customer, supplier, product and area, updated at least every three years (arts. 27 to 29).

ROS, transaction register and deadlines with the UIF-Perú

Report To whom Deadline
Appointment of the Compliance Officer UIF-Perú, via SISDEL (its online registration system) 15 business days from the appointment (art. 7.2)
Suspicious transaction report (ROS) UIF-Perú, via ROSEL (its online reporting system) Maximum 24 hours from when the transaction is classified as suspicious (art. 23)
Transaction register Kept and retained; delivered when the UIF-Perú requests it Ongoing (art. 30)
Annual Compliance Officer report (IAOC) UIF-Perú, via the PLAFT Portal By February 15 of the following year (art. 26.3)

Each gold purchase, with supplier and payment details, is documented and kept for at least five years (art. 31).

Red flags in mining and gold trading

The UIF-Perú's national typology on illegal mining points to:

  • A newly incorporated company, with minimum capital, engaged in exporting gold or trading minerals.
  • Shareholders without the financial means to explain the working capital used to buy the gold.
  • Cash payments to gold collectors in areas at high risk of illegal mining.
  • Transfers from abroad on consecutive days, withdrawn immediately or sent to people with no connection to the company.
  • The same shareholders in several companies in the sector, incorporated on consecutive dates.

Penalties for non-compliance with the SPLAFT

The Superintendency of Banking, Insurance and Private Pension Funds (SBS) publishes the list of sanctioned obligated entities: a final penalty against your mining company is there for all to see. Through the UIF-Perú, it imposes penalties under the Regulation on Infractions and Penalties (SBS Res. 8930-2012): from 7 to 100 tax units (UIT) for a very serious infraction by a legal entity (art. 17).

How Líderes APLA implements the mining SPLAFT

  1. Assessment: whether your company falls within the definition of mining company, and its gap against SBS Res. 789-2018.
  2. Matrix by area and supplier: sourcing in illegal mining areas carries more weight, with scoring of buyers, gold collectors and workers.
  3. Manual and code of conduct: supplier file (concession or REINFO, origin of the ore) and purchasing and export procedures.
  4. Due diligence and reporting: with AplaSoft you check lists, PEP (politically exposed persons) and SUNAT (Peru's tax authority) with evidence; we support you with the RO, the ROS and the IAOC.
  5. Training: for the officer and staff, with e-learning courses.

See our AML/CTF consulting in Peru, the Peruvian regulations and the glossary.

If your mining company exports gold or buys from gold collectors, let's assess your mining SPLAFT: the assessment is free.

Updated: October 2026.

Frequently asked questions

Does a copper mining company need a SPLAFT?
<p>Not as a mining company: SBS Res. 789-2018 only covers mining companies that trade gold. If it carries out another activity listed in article 3 of Law 29038, it may be obligated on that basis.</p>
Does the mining company send its transaction register to the UIF-Perú?
<p>No: according to the <a href="https://www.sbs.gob.pe/Portals/5/Listas_SO_presentar_RO_actualizada_2024_05_13.pdf">SBS's 2024 list</a>, it only keeps it, retains it and delivers it when the UIF-Perú requests it.</p>
Must a mining company have an internal and an external audit of its SPLAFT?
<p>Internal, yes, if it is a legal entity; external, only if the law requires it to have external auditors (art. 38, item 17, and art. 34). The SBS may exempt it based on a risk analysis. The internal report is prepared by its audit area or by a manager other than the officer, and is attached to the IAOC (art. 33).</p>
What if my mining company already has a manual?
<p>The free assessment starts from it and shows the gap.</p>
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