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Observance of Standards and Codes on Anti-Money Laundering and Combating the Financing of Terrorism for Uruguay

This detailed report, prepared by the International Monetary Fund (IMF) with the Financial Action Task Force (FATF), was presented in July 2006. Its action points are now in the process of being implemented.

The report made 40 recommendations for Anti-Money Laundering (AML) and nine recommendations on Combating the Financing of Terrorism (CFT).

Main Findings

Although the current Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) regime is largely underdeveloped there is political commitment to introduce reforms to meet the FATF recommendations. The new Uruguay Government took office in March 2005 and considers AML efforts one of its priorities. While Uruguay has put in place basic legal elements for an AML and CFT regime, much remains to be done to meet the FATF recommendations.

The Uruguayan authorities have addressed the weaknesses in the AML and CFT regime. These include:
  • New legislation
  • A multi-agency group to coordinate AML and CFT activities at national level
  • The Directorate for State Intelligence (Ministry of Defence) is responsible for gathering intelligence on terrorism at national and international levels, while the Directorate of Information and Intelligence (MOI) is responsible for the prevention and fight against terrorism. These agencies are also involved in tackling organized crime
Uruguay is vulnerable to money laundering and the financing of terrorism as although its local crime rates are considered low, it is an offshore financial centre. Deficiencies in the implementation of anti-money laundering and combating the financing of terrorism in key sectors increase risks. A key concern is the potential use of bearer-share corporations for illicit purposes as corporate law and the registration system do not provide adequate transparency of ownership and control of legal persons. No systemic review of ML and FT risks in the jurisdiction has been conducted to date.

During the mission there was one ML prosecution underway, but before then there has been no ML prosecutions in Uruguay.

Amongst the summary of recommendations to strengthen the AML and CFT regime was to “Cover missing elements of the Designated Non-financial Business and Professionals (DNFBP) sectors in the AML and CFT legislation and prioritise implementation in the company services and sectors”. ILS’s South American office in Uruguay is keeping abreast of developments in this regard.

Further information from Diego Martinez.