SPLAFT for Savings and Credit Cooperatives (COOPAC) in Peru

AML/CTF prevention system for COOPACs supervised by the SBS

In Peru, savings and credit cooperatives not authorized to take deposits from the public (COOPACs) are obligated entities that must implement a SPLAFT. The SPLAFT is the anti-money laundering and counter-terrorist financing prevention system. Tier 2 and tier 3 cooperatives are supervised by the Superintendency of Banking, Insurance and Private Pension Funds (SBS). Tier 1 cooperatives are supervised by Peru's Financial Intelligence Unit (UIF-Perú).

The governing regulation is SBS Resolution 5060-2018, issued under Law 27693 and Law 29038. Its requirements depend on the modular tier, which is set by total assets: the officer's dedication, risk assessments and reports. If your COOPAC moves to a different tier, its obligations change. That is why Líderes APLA starts with the modular tier.

Is your COOPAC obligated under the SPLAFT, and what does its tier require?

The tiers, expressed in tax units (UIT), are those published by the SBS for the COOPAC system.

Elements of the SPLAFT in savings and credit cooperatives

• Compliance Officer: appointed by the Board of Directors, reports to it and holds senior management rank. The appointment is notified to the UIF-Perú via SISDEL (the electronic system for registering Compliance Officers) within 15 business days.
• Knowing the member and the beneficial owner: screening against OFAC and UN lists. Enhanced due diligence applies to politically exposed persons (PEPs), their relatives and members whose balances exceed 10% of the cooperative's effective equity.
• Risk assessment: at the frequency set for each tier. New products and new areas require a prior risk report.
• Transaction records: single transactions from US$5,000 and multiple transactions totaling US$20,000 in a month. Cash transactions require a sworn statement on the source of funds.
• Training: for new staff within their first 30 days, and two specialized sessions a year for the officer and the officer's team.

ROS and deadlines with the UIF-Perú and the SBS

The record of single transactions is submitted to the SBS through the electronic channel it designates and kept for ten years (art. 44).

AML/CTF red flags in COOPACs

They come from Annex 5 of SBS Res. 5060-2018:

• Large loans paid off suddenly, especially in cash, with no explanation of the source of funds.
• Loans secured with deposits from third parties with no apparent connection to the member.
• Disbursements requested in another province or country with no employment or business reason.
• Repeated deposits or withdrawals just below the transaction record threshold.
• Members who ask to be left out of the record or press staff so they do not have to fill out forms.
• Employees whose lifestyle does not match their income or who avoid taking vacations.

Penalties for COOPACs

A very serious infraction can cost your cooperative from 100 to 150 UIT, and the responsible directors or employees from 5 to 10 UIT. The SBS applies its Regulation on Infractions and Penalties to COOPACs (SBS Res. 2755-2018, amended by SBS Res. 1310-2019).

How Líderes APLA implements the SPLAFT at your COOPAC

1. Tier-based assessment: your system measured against what SBS Res. 5060-2018 requires for your tier.
2. Risk matrix and member scoring: by member, product, channel and geographic area.
3. Manual and code of conduct: for the Board, including the source-of-funds declaration for cash.
4. Officer reporting: SISDEL, transaction records, ROS and reports according to your tier.
5. Training: for the Board, the officer and the branches, with e-learning courses. AplaSoft supports list screening and due diligence.

This is a service of our AML/CTF Consulting in Peru; see the regulations and the glossary.

If your COOPAC changed modular tier, its requirements changed too. Let's assess your SPLAFT: the initial assessment is free.

Updated: October 2026.