In order to prevent money laundering and terrorist financing, the Financial Information and Analysis Unit (FIAU) operating in the Central Bank of Uruguay, is responsible for receiving Suspicious or Unusual Transaction Reports (STRs) from of the obligors (from financial and non-financial sectors), in compliance with the obligation under articles 1 and 2 of Act No. 17.835 of September 23, 2004, as amended by Act No. 18.494 of June 5, 2009.
When presenting the report, a "Report Form on suspicious or unusual transactions" must be completed, where the reporting entity must provide identification information of the individuals or entities involved, their activities, the characteristics and profile of the reported transaction (type of transaction, amount, date, location, etc.) and finally, explain the reasons why the transaction is considered suspicious or unusual in the opinion of the reporter. As of August 2014, and in compliance with the provisions of Communication No. 2014/108, the obligors of the financial sector must complete an electronic form and send it through the centralized delivery system of the Superintendency of Financial Services. The rest of the obligors must present the report on paper directly to the Financial Information and Analysis Unit.
This document presents a statistical analysis, using the data contained in the forms of suspicious transaction reports (STRs) received in 2014, and classifies them in different categories and possible groupings based on the people and the characteristics of the transactions involved, as describe in the forms received in the period.
While the number of reports received annually by the FIAU is not statistically significant (286 in 2014), which is a hindrance to drawing conclusions, it is useful to analyze the type of suspicious or unusual transactions reported by the entities and their main characteristics, in order to start moving towards a better understanding of the ML/TF situation in our country, and how obligors meet their prevention obligations.
Finally, and in order to give a complete picture of the legal and regulatory framework governing the obligation to report suspicious transactions in our country, an Annex has been included describing the main duties and legal powers of the FIAU, the obligors, transactions to be reported, and predicate offenses for money laundering in Uruguay.