Changes to anti-money laundering rules in Uruguay

On 19 March 2026, Uruguay enacted Law No. 20,361, which introduces significant changes to the anti-money laundering and counter-terrorist financing regime set out in Law No. 19,574.

The main changes include the following:

• The institutional framework of the anti-money laundering system is reinforced by strengthening the role of the National Secretariat for Combating Money Laundering and Terrorist Financing (SENACLAFT), whose powers to access information are extended. The composition and functioning of the Coordinating Committee against Money Laundering and Terrorist Financing are also adjusted, and it now reports directly to the Office of the President.
• Clarifications are introduced regarding non-financial obliged entities, defining the scope of certain categories, including non-financial trustees.
• The administrative penalty regime applicable to obliged entities is expanded.
• In criminal matters, money laundering is confirmed as an autonomous offence.
• A significant change is made to the cases in which simplified due diligence may be applied. The automatic legal recognition of certain circumstances as indicating lower risk is removed. In particular, the provision whereby the use of electronic means of payment, on its own, allowed simplified measures to be applied is eliminated, reinforcing the need for a specific, case-by-case assessment by obliged entities.
• The list of predicate offences for money laundering is extended. It now includes cybercrimes with an actual or estimated value above 100,000 Indexed Units, the environmental offence related to the introduction of toxic waste, and fraud in entities of the financial system. The economic threshold required for certain property offences is also lowered and standardised.
• The restriction on the use of cash under Financial Inclusion Law No. 19,210 is amended. From now on, transactions may be paid in cash up to 200,000 Indexed Units (approximately USD 32,500), or up to 5% of the total value of the transaction, provided that amount does not exceed 450,000 Indexed Units (approximately USD 73,000); both criteria remain valid grounds for cash payment.

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