Financial Intermediation Institutions – Modification of Requirements for Opening Current Accounts – Article 390 of the RNRCSF

Montevideo, October 16, 2025 Ref: FINANCIAL INTERMEDIATION INSTITUTIONS – Modification of Requirements for Opening Current Accounts – Article 390 of the RNRCSF.

The market is informed that the Financial Services Superintendence adopted the following resolution on October 13, 2025:

JUAN PEDRO CANTERA Superintendent of Financial Services

2024-50-1-01344 Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy

CIRCULAR NO. 2487

FINANCIAL SERVICES SUPERINTENDENCE – RESOLUTION

FINANCIAL SERVICES SUPERINTENDENCE

VIEWING: The request submitted by the Association of Private Banks of Uruguay (ABPU), with the aim of modifying Article 390 of the Compilation of Regulations and Control Norms of the Financial System (RNRCSF), regarding the requirements demanded for the opening of current accounts for legal entities.

RESULTING: I) That the aforementioned Article 390 of the RNRCSF requires clients that are legal entities to present an authenticated copy of the contract or statutes, registration certificate, authorities, authorized representatives, and powers of attorney. II) That in the request referred to in VIEWING, ABPU states that the requirement is considered anachronistic and generates especially relevant costs for small and medium-sized enterprises. III) That, likewise, ABPU states that the current regulations have already relaxed this type of requirement in other provisions, such as Article 297 of the RNRCSF, applicable in matters of anti-money laundering, terrorist financing, and proliferation of weapons of mass destruction (AML/CFT/CPF), where legal entities are required to provide "documentation accrediting the legal constitution of the respective entity and its current authorities and representatives" but without requiring authenticated copies. IV) That having reviewed the opinion of other institutions regarding the proposal, one institution stated that to ensure proper representation and probative validity, the presentation in notarial testimony of exhibition corresponds, concluding that the acceptance of simple copies is not advisable.

CONSIDERING: I) That new technological tools, such as web searches and specialized platforms, allow obtaining relevant information about the background and authorities of clients in an efficient manner. II) That the proposed regulatory modification would contribute to harmonizing the requirements for opening current accounts with those for prevention in matters of AML/CFT/CPF, regarding the verification of the legal existence of companies and the identification of their authorities and representatives. III) That Article 390 establishes minimum requirements for the opening of current accounts, so that institutions that deem it appropriate may request additional documentation.

ATTENTIVE: To what is established in literal 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, the reports from the services of the Financial Services Superintendence, the opinion of the Advisory Commission on Standards referred to in RR-SSF-2025-532 Date: 10/13/2025 10:59:41 CIRCULAR NO. 2487

the Article 84 of the Administrative Regulations of the Central Bank of Uruguay, and other background in file 2024-50-1- 01344.

IT IS RESOLVED:

1. SUBSTITUTE in Chapter I – Obligations, of Title VI – Current Accounts, of Book IV – Protection of the user of financial services, Article 390 with the following:

ARTICLE 390 (REQUIREMENTS). For the opening of current accounts, financial intermediation institutions must adhere to the following requirements: a) Adequately identify their holders and orderers, obtaining, as a minimum, the following data from each of them:

1. Natural Persons a. full name and surnames; b. date and place of birth; c. marital status (if married, name of the spouse); d. address; e. profession, trade, or main activity; f. identity document.
2. Legal Entities a. name or trade name; b. date of constitution; c. main activity; d. address; e. registration number in the Single Tax Registry, if such registration applies; f. documentation accrediting the legal constitution of the respective entity and its current authorities and authorized representatives. b) Obtain information, to the satisfaction of the financial intermediation institution, regarding the moral solvency and activity of each of the holders and orderers of the current account to be opened. c) Complement the information referred to in the previous section with the background that may exist in the register of infractions in the use of checks, which the Central Bank of Uruguay makes known in accordance with Article 425.

2. COMMUNICATE the resolution via Circular.

JUAN PEDRO CANTERA Superintendent of Financial Services

RR-SSF-2025-532 Date: 10/13/2025 10:59:41 File 2024-50-1-01344 Publishable: Yes - Signatory: JUAN PEDRO CANTERA SENCIÓN CIRCULAR NO. 2487