SPLAFT for Notaries in Peru: Compliance Officer and UIF

Notarial SPLAFT: the AML/CTF prevention system for notaries in Peru

All notaries in Peru must implement an anti-money laundering and counter-terrorist financing prevention system (SPLAFT). They are supervised solely by Peru's Financial Intelligence Unit (UIF-Perú), part of the Superintendency of Banking, Insurance and Private Pension Funds (SBS). The governing rule is SBS Resolution 1754-2024, issued under Law 27693 and amended up to SBS Res. 01917-2026.

Each notary is part of a centralized management system run by the Centralized Prevention Body (OCP LA/FT) of the Lima Association of Notaries. The OCP is itself an obligated entity, but centralization does not transfer the obligation: your notary office is responsible for its own part. Líderes APLA helps you fulfill it.

What does the SPLAFT require of your notary office?

Notaries appear on the SBS list of obligated entities. For movable property and leases, transactions totaling US$10,000 in a month are also recorded.

Elements of the SPLAFT in notary offices

• Compliance Officer: with a direct employment or contractual relationship; the role need not be full-time. The appointment is notified to the UIF-Perú via SISDEL (its online registration system) within 15 business days, and the position cannot remain vacant for more than 30 days.
• Manual and code of conduct: they are single documents for all notaries, drafted by the OCP LA/FT. Each notary approves their own annex, and their staff sign a sworn statement of acknowledgment.
• Due diligence of the client and the beneficial owner: in every transaction. The enhanced regime is mandatory for non-residents, trusts, financial leasing and politically exposed persons (PEP), along with their relatives up to the second degree.
• Risk assessment: by client, service and geographic area, using the OCP's methodological guide. It is updated at least every three years.
• Centralized database: the notary records their transactions the same day and sends them to the OCP's centralized information database (BCI).
• Training: once a year for the notary and staff, which a third party may deliver with a certificate, plus onboarding training within 30 days.

ROS, transaction register and deadlines with the UIF-Perú

Money laundering red flags in notary offices

Notarial red flags according to the UIF-Perú's notarial due diligence guide:

• The client refuses to fill out forms or to declare the source of funds, or withdraws when asked for them.
• Acquisition or transfer of assets in favor of minors or non-residents.
• A client investigated or prosecuted, according to public media, for money laundering, predicate offenses or terrorist financing.
• Use of shell companies and purchase and sale of real estate or high-value assets (GAFILAT, the Financial Action Task Force of Latin America, 2019 mutual evaluation).

Penalties for notaries who fail to comply with the SPLAFT

As a notary and an individual, you risk up to 15 tax units (UIT) for a very serious infraction (from 4), from 0.50 to 6 UIT for a serious one, and a reprimand or from 0.15 to 3 UIT for a minor one. Penalties are imposed by the SBS, through the UIF-Perú, under the Regulation on Infractions and Penalties (SBS Res. 8930-2012), whose current text was set by SBS Res. 1754-2024.

How Líderes APLA implements the SPLAFT in your notary office

1. Assessment against SBS Res. 1754-2024: officer, due diligence, transaction register and submissions to the BCI.
2. The notary's annex to the single manual: your own policies and procedures, aligned with the OCP's manual.
3. Risk assessment report for your office: by type of act, client and area.
4. Support for the Compliance Officer: SISDEL, risk reports, transaction register and the transition to the centralized RO in 2028.
5. Annual training with a certificate: through our e-learning courses. AplaSoft supports list screening.

Part of our AML/CTF Consulting in Peru; see the regulations and the glossary.

Is your notary office preparing for the 2028 centralized register? Let's plan your office's transition: the initial assessment is free.

Updated: October 2026.