This February 15, 2024 is the deadline to submit the IAOC, here are the main aspects that must be considered:

WHAT IS THE IAOC?

It is the report that includes compliance with the policies and procedures of the Money Laundering and Terrorism Financing Prevention System -SPLAFT that the Obligated Subject has implemented during the year prior to its presentation.

WHO SHOULD SUBMIT THE IAOC?

Those natural and legal persons who, in accordance with the regulations, have the status of Obligated Subjects, including the following:

• Companies in the financial system and the insurance system.
• Credit card issuing companies.
• Savings and credit cooperatives.
• Those dedicated to the purchase and sale of vehicles, boats and aircraft.
• Those who are dedicated to construction activity and/or real estate activity.
• Real estate agents.
• Those dedicated to the exploitation of casino games and/or slot machines, and/or remote games using the Internet or any other means of communication, in accordance with the regulations on the matter.
• Those who are dedicated to the exploitation of remote sports betting using the internet or any other means of communication, in accordance with the regulations on the matter.
• Those dedicated to the exploitation of lottery games and similar.
• Customs agents.
• Notaries.
• Mining companies.
• Those dedicated to the trade of jewelry, precious metals and stones, coins, art objects and postage stamps.
• Laboratories and companies that produce and/or market chemical inputs and controlled goods.
• Companies that distribute, transport and/or market chemical inputs that can be used in illegal mining, under the control and supervision of SUNAT.
• Virtual Asset Service Providers (PSAV).

WHAT DOES THE IAOC CONTAIN?

The IAOC must contain the following information:

• General Information of the Obligated Subject
• Annual Operations Statistics
• Main activities carried out to comply with the regulations relating to the Registry of Operations (RO)
  SPLAFT Policies and Procedures
• Training on issues related to SPLAFT
• ML/TF Risk Prevention and Management Manual and Code of Conduct for ML/TF Prevention.
• Others

WHAT SHOULD I DO BEFORE SUBMITTING THE IAOC?

The IAOC must be reported to the Board of Directors or equivalent body, or to the General Manager.

TO WHOM SHOULD THE REPORT BE SENT?

It must be sent to the FIU through the Portal for the Prevention of Money Laundering and Financing of Terrorism – PLAFT.

In the case of Obligated Subjects that have other supervisory bodies, a copy of the report may be sent to them.

WHAT HAPPENS IF I DO NOT COMPLY WITH SUBMITTING IT?

Failure to send the IAOC is considered a serious infraction that can lead to a fine of up to 20 UIT (S/103,000.00 one hundred three thousand soles).

For more information contact:

Mario Pinatte | CPB Partner | mpinatte@cpb-abogados.com.pe