The BCRA and the Argentine Financial Intelligence Unit (FIU) have relaunched the FIU-BCRA Working Meeting and presented the Interpretation and Application Guide for the “Customer’s Customer” Concept, seeking to align best practices. For the BCRA, participants included Silvina Rivarola, Member of the Board, and Nathan Kogan Lewit, FIU Compliance Reporting Senior Manager; for the FIU, Matías Álvarez, President, and Patricio Michlig, Vice President. Both initiatives reinforced the inter-institutional relationship and established guidelines for managing risks associated with AML/CTF/CPF.
The meeting took place on Thursday, August 13, 2026, at the BCRA. It was intended for managers, compliance officers, and those responsible for AML/CTF/CPF at financial institutions, within the framework of FIU Resolution 96/2024. The event aimed to align operational guidelines and prevent de-risking and financial exclusion.
The technical exchange among the participating institutions included the “customer’s customer” concept, and the document—issued by the FIU, the BCRA, the National Securities Commission (CNV), the National Superintendence of Insurance (SSN), and the National Institute of Mutual Associations, Cooperatives and Social Economy (INAES)—structured it into specific pillars for a correct implementation:
Key pillars of the “Customer’s Customer” Guide
- • Cooperation among reporting parties, with defined responsibilities and scopes.
- • Risk-based approach, with measures proportional to the profile of each counterparty.
- • Due diligence and knowledge of the counterparty’s anti-money laundering program.
- • Periodic monitoring, with timely detection and treatment of unusual activities.
The BCRA consolidates its AML/CTF/CPF prevention policy through coordination with the FIU and other regulators, under standards that protect the integrity of the financial system.
