Obligated entities in Peru: general and limited SPLAFT before the UIF-Perú
In Peru, article 3 of Law 29038 and its extensions require 44 activities to implement a SPLAFT. The SPLAFT is the anti-money laundering and counter-terrorist financing prevention system. These activities report to Peru's Financial Intelligence Unit (UIF-Perú), part of the Superintendency of Banking, Insurance and Private Pension Funds (SBS).
The list grows by supreme decree: Supreme Decree 008-2025-JUS added factoring and private fund managers. Supreme Decree 008-2026-JUS added financial leasing.
Is your company obligated? Obligated entities and transaction register thresholds
| Scenario | Condition or threshold | Supervisor | Regulation |
|---|---|---|---|
| Currency exchange houses | Transaction register (RO) from US$5,000 | UIF-Perú | SBS Res. 789-2018, art. 39 |
| Lending and pawn | RO from US$5,000 without collateral; US$2,500 with collateral | UIF-Perú | SBS Res. 789-2018, art. 44 |
| Machinery (subheadings 84.29, 85.02 and 87.01) | RO from US$50,000 for sales; US$10,000 for leases | UIF-Perú | SBS Res. 789-2018, art. 37 |
| Coins, art, stamps, aircraft, racetracks and lotteries | No RO; simplified due diligence | UIF-Perú | SBS Res. 789-2018, art. 42 |
| Legal or accounting services firms | RO with no threshold | UIF-Perú | SBS Res. 789-2018, art. 45 |
| Casinos, slot machines and remote betting | RO from US$2,500 | MINCETUR (Ministry of Foreign Trade and Tourism) | SBS Res. 01015-2026 and 03622-2025 |
| Customs agents | RO from US$50,000 (imports) and US$200,000 (exports) | SUNAT (Peru's tax and customs authority) | SBS Res. 4197-2016 |
| Virtual asset service providers (PSAV) | RO of all cash; other means from US$1,000 | UIF-Perú | SBS Res. 2648-2024 |
| Factoring, private fund managers and financial leasing | Not supervised by the SBS or the SMV (Superintendency of the Securities Market) | UIF-Perú | Supreme Decrees 008-2025-JUS and 008-2026-JUS |
| Limited regime | Antiques, auctioneers, travel agencies, lodging, football clubs, government entities and others | UIF-Perú | Law 29038, art. 3.2; SBS Res. 369-2018 |
The official SBS list separates 35 activities under the general SPLAFT and 9 under the limited SPLAFT. Banks, cajas (municipal and rural savings institutions), insurers and AFP (private pension fund managers) follow SBS Res. 2660-2015 before the SBS. A foreign company without a branch in Peru is not an obligated entity, even if it carries out the activity (SBS).
Elements of the SPLAFT for other obligated entities
- Compliance Officer: under the limited regime, the role need not be full-time.
- Due diligence and beneficial owner: under Legislative Decree 1372.
- Simplified regime: for art, aircraft and lotteries, simplified due diligence is sufficient (art. 42).
- One register per activity: an entity that both exchanges currency and lends money keeps one register for each activity (art. 22.3).
- Manual and code of conduct: mandatory under the general regime (art. 24).
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 its classification (art. 23.1) |
| Transaction register (RO) | UIF-Perú, via the PLAFT Portal | Frequency set by the SBS (art. 22.4) |
| Annual officer report (IAOC) | Supervisor, via the PLAFT Portal | By February 15 of the following year (art. 26.3) |
The ROS has no minimum amount, and its supporting documentation is kept for five years.
Red flags in other obligated entities
- Purchase or sale of crypto-assets ordered from abroad, with the funds withdrawn immediately (2025 typologies of the Financial Action Task Force of Latin America, GAFILAT; Peruvian case).
- Cash split into smaller amounts to stay below the RO threshold.
- Law or accounting firms that incorporate companies with front men or simulate loans between them (same report).
- Newly incorporated companies with large volumes.
Penalties for failing to comply with the SPLAFT
A legal entity risks from 7 to 100 tax units (UIT) for a very serious infraction, from 2 to 20 for a serious one, and a reprimand or from 0.5 to 10 UIT for a minor one. Penalties are imposed by the SBS, through the UIF-Perú, under SBS Res. 8930-2012, art. 17. Entities with another supervisor, such as the Ministry of Foreign Trade and Tourism (MINCETUR) or SUNAT, follow their own regime.
How Líderes APLA implements the SPLAFT for other obligated entities
We have advised other obligated entities in Peru.
- Regime assessment: your activity on the SBS list, your regime and your supervisor.
- Risk matrix and scoring: client, supplier and employee profiles, as part of our AML/CTF consulting.
- Manual and code of conduct: under the general regime; under the limited regime, the minimum ROS procedure.
- Tools: AplaSoft checks InfoGob (Peru's public officials database), SUNAT, OFAC (US sanctions list) and the UN, and keeps evidence for inspections.
- Annual training: for the officer and customer-facing staff, with e-learning courses. Your rules: Peru regulations; acronyms: glossary.
Is your activity on the SBS list and you still have no registered officer? Let's identify your regime.
Updated: October 2026.
Frequently asked questions
What is the difference between the general and the limited SPLAFT?
How does a company register as an obligated entity?
Must an art gallery keep a transaction register?
How much does it cost to find out whether my company is obligated?
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