Argentina AML/KYC and customer due diligence
Argentina UIF Resolution No. 14/2023 sets out risk-based requirements for regulated entities to manage money-laundering, terrorist-financing and proliferation-financing risks. Minimum identification information for individual customers includes name, identity document, nationality, birth details, applicable tax identification number, address, telephone number, email address and principal occupation; it also requires the handling of politically exposed persons and terrorist-financing matters under current rules. These are the applicable Argentine regulatory baseline requirements; BNA’s internal risk classifications, review thresholds and document follow-up requirements for each account are not disclosed on the product pages reviewed.
Source:Argentina — UIF Resolución 14/2023, texto original ↗
Corporate Ultimate Beneficial Owners, Control, and Source of Funds
Article 23 of UIF Resolution No. 14/2023 requires identification and verification of corporate customers, collection of information on registration identity, applicable tax identification number, current formation documents, registered address, representatives, management, capital ownership and ultimate beneficial owners, and application of the relevant PEP and counter-terrorist financing rules. In a risk-based review, a bank may request explanations of transactions or the source of funds, but the BNA pages reviewed do not publish a source-of-funds evidence threshold, required format or fixed amount for this product. Applicants should provide truthful information and should not seek to circumvent review through an intermediary service or structural arrangements.
Source:Argentina — UIF Resolución 14/2023, texto original ↗
Tax Residency Information, CRS, and FATCA
ARCA's official microsite explains the information-reporting regime applicable to Argentine financial institutions under the international CRS/FATCA framework. The Argentine government also confirms that Argentina signed a FATCA agreement in 2022. Information exchange relating to the US should be described under the bilateral FATCA framework; this does not mean the US has joined CRS. The specific practices of BNA regarding individual tax-residency self-certification forms, foreign tax identification numbers and reportable-account determinations were not fully explained on the account-opening pages reviewed. Applicants should truthfully declare their actual tax-residence status when opening an account.
Source:ARCA — Información financiera CRS/FATCA ↗;Argentina.gob.ar — Intercambio automático de información con EEUU ↗
Counter-terrorist financing and sanctions screening
Argentina UIF’s banking AML/CFT rules require regulated entities to incorporate terrorist-financing risks and related customer identification into their compliance management; corresponding rules also apply to corporate beneficial owners. BNA has not published on its account-opening product page its screening lists, matching thresholds, lists of sanctioned jurisdictions or procedures for determining account restrictions. The bank conducts specific reviews under applicable law; this does not support an inference that any particular applicant will necessarily be accepted or rejected.
Source:Argentina — UIF Resolución 14/2023, texto original ↗
Personal information and privacy
BNA’s privacy policy lists identity, contact, financial, commercial, technical, and biometric data that may be collected; explains that data may be processed for purposes such as providing services, meeting legal obligations, and preventing fraud; and states that data may be shared with suppliers or Grupo Nación companies in circumstances such as legal obligations or service provision. The policy also lists data-subject rights and contact channels. Applicants should review the full privacy terms applicable to the product. The materials reviewed did not verify the scope or amount of applicable deposit protection, so no statement is made about coverage limits.
Source:BNA — Política de privacidad y protección de datos ↗