Regulatory Alerts2025-07-15
Added · Updated
Circular No. 2483: Regulatory Modifications Regarding PEP Clients and Outsourcing
Resolution SSF No. 2025-336 amends the Norms Compilation to introduce differential treatment for local and foreign Politically Exposed Persons (PEPs), requiring enhanced due diligence for foreign PEPs and high-risk local PEPs, while mandating senior management approval and intensified monitoring for non-high-risk local PEPs. The resolution authorizes the outsourcing of account and transaction monitoring subject to express authorization by the Superintendency of Financial Services and permits investment advisors to outsource client due diligence. It also establishes specific documentation requirements and a USD 120,000 annual transaction threshold for certain foreign PEPs, while updating the regulatory framework for third-party service outsourcing.
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