Errata - Circular No. 2483 - Article 77 of the Compilation of Insurance and Reinsurance Regulations

Montevideo, December 5, 2025 Ref: ERRATA - Circular No. 2483 - Art. 77 of the Compilation of Insurance and Reinsurance Regulations

The market is informed that the Financial Services Superintendence adopted Resolution SSF No. 2025-657 on December 4, 2025.

2025-50-1-00914 Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy CHRISTIAN SALVARREY Management of Strategic and Operational Management

CIRCULAR NO. 2492

FINANCIAL SERVICES SUPERINTENDENCE – RESOLUTION FINANCIAL SERVICES SUPERINTENDENCE

VISTO: Circular No. 2483 of July 15, 2025, which modified regulations regarding clients who are politically exposed persons (PEPs) and certain aspects related to outsourcing.

RESULTING: I) That the aforementioned Circular modified Article 77 of the Compilation of Insurance and Reinsurance Regulations with the aim of no longer mandatorily considering all PEP clients as higher risk, but exclusively PEP clients from abroad. II) That previously, Circular No. 2481 of June 12, 2025, had modified said Article 77 to eliminate letter f), which referred to certain surety insurance policies, in order to adapt the regulation to what is established in Article 12 of Law No. 19.574 of December 20, 2017, contemplated in Communication No. 2020/167, which states that requirements regarding money laundering, terrorist financing, and the financing of proliferation of weapons of mass destruction (AML/CFT/Proliferation Financing) will apply only when insurance companies participate in activities related to the underwriting and placement of life insurance and other investment-related insurance. III) That an error was made in re-incorporating into Circular No. 2483, referred to in the VISTO, the aforementioned letter f).

CONSIDERING: That it corresponds to eliminate letter f) of Article 77 of the RNSR, in line with what is provided by Circular No. 2481 of June 12, 2025.

ATTENTIVE: To what is disposed in letter A) of Article 38 of Law No. 16.696 of March 30, 1995, in the wording given by Article 2 of Law No. 20.345 of September 19, 2024, and in Article 12 of Law No. 19.574 of December 20, 2017.

RESOLVES:

1. SUBSTITUTE in Chapter II – Policies and procedures for due diligence regarding clients, of Title I – Prevention of the use of insurance, reinsurance, and mutual insurance companies for money laundering, terrorist financing, and the financing of proliferation of weapons of mass destruction, of Book III – Protection of the Financial System against illicit activities of the Compilation of Insurance and Reinsurance Regulations, Article 77 with the following:

ARTICLE 77 (ENHANCED DUE DILIGENCE PROCEDURES). Companies must apply enhanced due diligence procedures for categories of clients, commercial relationships, or operations considered higher risk, according to what arises from the risk assessment carried out by the institution.

Notwithstanding, the following shall be considered as higher risk: a) transactions by persons who link with the entity through operations where personal contact is not usual, such as clients who carry out operations through operational modalities that, using new or developing technologies, may favor client anonymity. b) commercial relationships and operations with non-resident clients coming from countries that do not comply with international standards in matters of money laundering, terrorist financing, and the financing of proliferation of weapons of mass destruction. c) politically exposed persons from abroad, as well as their family members and close associates. d) all those operations that are carried out under unusual circumstances according to the uses and customs of the respective activity. e) clients who have contracted life insurance with an annual premium greater than U$S 10,000 (ten thousand United States dollars) or its equivalent in other currencies, and those with a single premium greater than U$S 200,000 (two hundred thousand United States dollars) or its equivalent in other currencies.

In application of the enhanced due diligence procedures, companies must: i. obtain approval from the main hierarchical levels of the institution when establishing or continuing a relationship with this type of client. ii. elaborate a detailed report in which the assigned activity profile will be included to adequately monitor the client's transactions, and all elements that have been considered to determine said profile will be explicit. The report must be adequately backed by documentation that allows establishing the patrimonial, economic, and financial situation or justifying the origin of the funds managed by the client. For these purposes, there must be accounting statements with a Public Accountant's report, tax returns, responsibility statements, minutes of profit distribution, sales contracts, or other documentation that allows complying with what stated above.

Notwithstanding, in all cases, copies of sworn declarations or equivalent documentation presented before the corresponding tax administration must be available, in the case of clients who have contracted life insurance under the terms of letter e).

In the case of persons included in letter c) whose annual transactions, according to their activity profile, reach amounts less than U$S 120,000 (one hundred twenty thousand United States dollars) or its equivalent in other currencies, or carry out transactions up to said amount during a calendar year, only the documentation that allows establishing the patrimonial, economic, and financial situation or justifying the origin of the funds managed by the client will be required.

For the purpose of determining said threshold, the accumulated volume of transactions will be considered. iii. increase the frequency of updating client information. iv. perform more intense monitoring of the commercial relationship, increasing the quantity and frequency of controls applied.

2. Communicate the resolution via Circular.

JUAN PEDRO CANTERA Superintendent of Financial Services