On April 28, 2023, the Secretariat for the Prevention of Money or Asset Laundering (Secretaría de Prevención de Lavado de Dinero o Bienes - SEPRELAD, by its Spanish acronym) issued Resolution No. 146/23, by which it established that the following regulated entities must submit their Suspicious Transaction Reports (STRs) as well as their negative STRs through the Integral Operations Reporting System (Sistema Integral de Reporte de Operaciones - SIRO, by its Spanish acronym): (i) real estate companies; (ii) stock exchange; (iii) mutual investment and retirement fund administrators; (iv) individuals and legal entities that carry out activities of transportation or storing of securities or cash; (v) companies which main activity is development or exploitation of electronic payment systems (Entidades de Medio de Pago Electrónico - EMPEs, by its Spanish acronym); (vi) individuals and legal entities that carry out activities associated with virtual assets (Proveedores de Servicios de Activos Virtuales - PSAV, by its Spanish acronym); (vii) individuals and legal entities engaged in activities related to the trade of jewelry, precious stones and metals; (viii) pawnshops; (ix) non-profit organizations (NPOs); (x) individuals and legal entities engaged in activities related to the operation of games of chance; and (xi) individuals and legal entities that provide safe deposit box rental services.
To correctly implement and make the necessary adjustments in the operating process of the SIRO for such regulated entities, this resolution establishes a review and contingency management period of 90 calendar days as from its effective date. Within such period, the regulated entities must communicate to the National Directorate of Information Technology and Innovation of SEPRELAD all contingencies, errors, or problems in the use of the SIRO within 72 hours from the moment in which they are identified.
The resolution also establishes that delays or errors in the production and uploading of reports through the SIRO during such period, resulting from contingencies notified by the regulated entities, will be exempted from the eventual responsibilities and sanctions that could be applied to them and their compliance officers.
For further information please contact Cynthia Fatecha (email@example.com), Carlos Vouga (firstname.lastname@example.org), Georg Birbaumer (email@example.com) or your usual Vouga contact.