SPLAFT for Cash and Valuables Transport and Custody in Peru

SPLAFT for cash and valuables transport and custody companies

Every company that transports or holds cash and valuables in custody in Peru must implement an anti-money laundering and counter-terrorist financing prevention system (SPLAFT). Cash transport, custody and management companies (ETCAN) supervised by the Superintendency of Banking, Insurance and Private Pension Funds (SBS) are governed by SBS Res. 2660-2015. The rest, which operate under Legislative Decree 1213 on private security, have been obligated entities before Peru's Financial Intelligence Unit (UIF-Perú) since Supreme Decree 004-2025-JUS.

The decree, dated March 1, 2025, follows the recommendations of the FATF (GAFI). If your company moves or holds cash, the obligation arises from that activity, not from its size. Líderes APLA, in Peru since 2022, reviews each service from the pickup point to the vault: who hands over the money, how much and with what backing.

Is your valuables transport company an obligated entity?

According to the SBS announcement, companies under Legislative Decree 1213 are supervised on AML/CTF matters by the UIF-Perú. SBS Res. 789-2018 applies to them, unless a special rule provides otherwise (art. 1).

Elements of the SPLAFT in valuables transport

• Compliance Officer: appointed by the board or, if there is none, by management, and reported via SISDEL (the UIF-Perú's online registration system) within 15 business days (SBS Res. 789-2018, art. 7.2). In an ETCAN with more than 100 employees, the role must be full-time (SBS Res. 2660-2015, art. 13).
• Prevention manual and code of conduct: know your employees and suppliers, and red flags specific to the service.
• AML/CTF risk assessment: by client, route, area, type of valuable and channel.
• Know your client and beneficial owner: source of the money and consistency between the amount and the declared business.
• Transaction register (RO): in an ETCAN it includes transport and custody of valuables from US$10,000 (SBS Res. 2660-2015, art. 49).
• Record retention and training: at least five years under the UIF-Perú regime and ten under the SBS regime, with periodic staff training.

ROS and transaction register with the UIF-Perú

The ROS is confidential and is filed regardless of the amount.

Red flags in valuables transport and custody

SBS Res. 2660-2015 includes these red flags:

• An amount transported that is unrelated to the client's business.
• Small packages frequently transported in the name of one person, or of several people with the same address.
• Orders on behalf of a company with no proof that the money belongs to it.
• Occasional transport for clients not supervised by the SBS, with pickup and delivery outside an office.
• A difference of more than 10% between the declared amount and the recount.
• Amounts that exceed a regular client's average for the last three months by 10% or more.

Penalties for failing to comply with the SPLAFT

The SBS, through the UIF-Perú, can fine your transport company up to 100 tax units (UIT), under SBS Res. 8930-2012 (art. 17), if it operates under Legislative Decree 1213 and fails to comply with Law 29038, its regulations or SBS Res. 789-2018 (art. 32.2).

How Líderes APLA implements the SPLAFT in your company

1. Regime assessment: ETCAN before the SBS or obligated entity before the UIF-Perú, and your gaps.
2. Compliance Officer: appointment and registration via SISDEL.
3. AML/CTF/CPF risk matrix: with client and custodian scoring.
4. Manual and code of conduct: client profile, proof that the money belongs to the client, and recount procedure.
5. Training: for the officer, management and custodians.

Part of our AML/CTF consulting in Peru; AplaSoft logs list checks and our e-learning courses train custodians. See the regulations and the glossary.

Does your company move or hold cash? Let's coordinate the launch of your SPLAFT, starting with your Compliance Officer.

Updated: October 2026.