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Financial Integrity Monitor

Uruguay UY

Domains covered
5 of 8
Sources
136
Role actions
8
Horizon <90d
2
Jurisdiction profile
FATF status: Clean Tier: B Risk direction: Stable Enablement vs enforcement: Mixed

Uruguay's AML/CFT regime rests on Laws 17,835, 18,494 and 19,355, with a bearer-share identification registry under Law 18,930 (2012) run by the Banco Central.

MoreThe UIAF (FIU) and SENACLAFT supervise financial institutions and DNFBPs respectively. Uruguay is not FATF grey-/black-listed and was excluded from intensified GAFILAT follow-up in 2013, but its 2019/2020 MER flagged uneven DNFBP supervision maturity and it still lacks a finalized virtual-asset licensing regime.

Key deficiencies
  • Uneven risk-based supervision maturity across non-financial gatekeeper sectors (APNFD/DNFBP) per 2019/2020 MER
  • No finalized VASP/crypto-asset licensing and AML supervisory regime; framework remains under public discussion
  • Domestic prosecutorial follow-through lags international enforcement action against Uruguayan-linked transnational trafficking/laundering networks
  • Montevideo port and air corridors remain exploited as an embarkation point for cocaine bound to Europe, indicating persistent trade/logistics-based ML exposure
Recent developments (18m)
  • Capture (March 2026, Bolivia) and extradition to the US of Uruguayan national Sebastián Marset, alleged leader of the 'Primer Cartel Uruguayo' transnational cocaine/money-laundering network
  • US superseding indictment (2026) adding narcoterrorism and cocaine-trafficking charges against Marset, alleging laundering through US and European banks plus a cryptocurrency wallet
  • Paraguayan senator convicted (April 2026) for laundering/facilitating assets tied to the Marset-linked Insfrán clan network, underscoring the transnational reach of Uruguay-originated trafficking proceeds
  • FSB thematic review (Nov 2025) confirms Uruguay's crypto-asset regulatory framework remains under public discussion, alongside Brazil, Korea and Switzerland
  • EU high-risk AML/CFT third-country list update (Dec 2025) and FATF Increased Monitoring list update (June 2026) both leave Uruguay unlisted while regional neighbors Bolivia and Venezuela were added/reviewed
Brief

Lead signal

Lead Signal

Uruguay's financial-crime architecture moved on two fronts this cycle, both traceable to the same underlying dynamic: a regime built around a 2024 virtual-asset law and a long-standing anti-money-laundering statute is now working through implementation detail rather than foundational design. The Central Bank of Uruguay confirmed that providers of virtual-asset services operating before the formal licensing framework took effect may continue trading while their authorisation applications are pending, provided those applications are filed between 1 September 2026 and 31 March 2027, with a general compliance deadline of 30 June 2027 for all remaining adjustments. Separately, the national anti-money-laundering authority, SENACLAFT, approved a revised sanctions guideline for non-financial obligated entities, repealing the prior 2022 version and reclassifying certain due-diligence and beneficial-ownership failures as grave infractions.

Read full brief

Lead Signal

Uruguay's financial-crime architecture moved on two fronts this cycle, both traceable to the same underlying dynamic: a regime built around a 2024 virtual-asset law and a long-standing anti-money-laundering statute is now working through implementation detail rather than foundational design. The Central Bank of Uruguay confirmed that providers of virtual-asset services operating before the formal licensing framework took effect may continue trading while their authorisation applications are pending, provided those applications are filed between 1 September 2026 and 31 March 2027, with a general compliance deadline of 30 June 2027 for all remaining adjustments. Separately, the national anti-money-laundering authority, SENACLAFT, approved a revised sanctions guideline for non-financial obligated entities, repealing the prior 2022 version and reclassifying certain due-diligence and beneficial-ownership failures as grave infractions.

Taken together, these are not emergency interventions but scheduled maturation of frameworks already on the books. The virtual-asset transition window is a managed on-ramp, not a crackdown, and the revised sanctions guideline updates enforcement calibration rather than introducing new substantive obligations. Read architecturally, Uruguay is tightening the operational edges of regimes it had already committed to rather than reopening their design.

Other Developments

Beneficial-ownership compliance tooling saw a practical, if modest, development: the Auditoría Interna de la Nación launched four online fine-calculator simulators covering different corporate forms, intended to help filers estimate exposure for non-disclosure of beneficial owners. This is a compliance-support artefact rather than a change to the underlying registration duty, which continues to rest on the 15 percent beneficial-ownership threshold set in the corporate transparency statute.

The non-financial sanctions guideline revision is the more structurally significant item. The new guideline applies across non-financial obligated entities, including gambling operators, and treats failure to perform sector-appropriate customer due diligence, and failure to identify beneficial owners or third-party fund providers, as newly classified grave infractions. The evidentiary basis for this finding rests on secondary legal commentary rather than the regulator's own published text, so the precise sanction amounts under the revised guideline are not yet independently confirmed, though the structural fact of the repeal and replacement is well supported.

Casino-sector due-diligence thresholds remain anchored to the existing decree setting a 3,000 US dollar single-or-aggregated transaction trigger for standard customer due diligence, a rule that predates this cycle and was not itself amended, but which forms the baseline against which the revised sanctions guideline's new infraction categories will be applied.

Cross-Monitor Connections

The virtual-asset transition timeline intersects directly with the jurisdiction's digital-asset regulatory architecture: the same registration window and 30 June 2027 compliance deadline that matter for anti-money-laundering supervision also define the licensing perimeter for crypto-asset businesses operating in the country, meaning firms tracked under digital-asset market structure are the same population subject to the anti-money-laundering transition obligations described here. The revised non-financial sanctions guideline likewise has a direct read-across to commercial activity in sectors such as gambling, where customer due-diligence failures now carry a more clearly defined enforcement consequence.

Outlook

Uruguay's financial integrity posture is best read as structurally stable but administratively active: the core statutory architecture, including the anti-money-laundering law as amended in March 2026 and the virtual-asset licensing law, is not in flux, but its implementation detail is still being filled in. SENACLAFT's own leadership has signalled that a further reglamentary decree for the non-financial sector is anticipated before the end of 2026, though its content has not yet been published, so the sanctions-guideline revision may be an interim step rather than the final word. The virtual-asset transition window will remain the key date-driven item through the first half of 2027, with the 31 March 2027 application deadline and the 30 June 2027 general compliance deadline both falling due in that period. Uruguay was not on the Financial Action Task Force's list of jurisdictions with strategic deficiencies as at the most recent plenary referenced in the available evidence.

Earlier periodic briefs (3)
25 Oct 2026 · fim-2026-10-25

Lead Signal

Uruguay's financial-crime architecture moved on two fronts, both traceable to the same underlying dynamic: a regime built around a 2024 virtual-asset law and a long-standing anti-money-laundering statute is now working through implementation detail rather than foundational design. The Central Bank of Uruguay confirmed that providers of virtual-asset services operating before the formal licensing framework took effect may continue trading while their authorisation applications are pending, provided those applications are filed between 1 September 2026 and 31 March 2027, with a general compliance deadline of 30 June 2027 for all remaining adjustments. Separately, the national anti-money-laundering authority, SENACLAFT, approved a revised sanctions guideline for non-financial obligated entities, repealing the prior 2022 version and reclassifying certain due-diligence and beneficial-ownership failures as grave infractions.

Taken together, these are not emergency interventions but scheduled maturation of frameworks already on the books. The virtual-asset transition window is a managed on-ramp, not a crackdown, and the revised sanctions guideline updates enforcement calibration rather than introducing new substantive obligations. Read architecturally, Uruguay is tightening the operational edges of regimes it had already committed to rather than reopening their design.

Other Developments

Beneficial-ownership compliance tooling saw a practical, if modest, development: the Auditoría Interna de la Nación launched four online fine-calculator simulators covering different corporate forms, intended to help filers estimate exposure for non-disclosure of beneficial owners. This is a compliance-support artefact rather than a change to the underlying registration duty, which continues to rest on the 15 percent beneficial-ownership threshold set in the corporate transparency statute.

The non-financial sanctions guideline revision is the more structurally significant item. The new guideline applies across non-financial obligated entities, including gambling operators, and treats failure to perform sector-appropriate customer due diligence, and failure to identify beneficial owners or third-party fund providers, as newly classified grave infractions. The evidentiary basis for this finding rests on secondary legal commentary rather than the regulator's own published text, so the precise sanction amounts under the revised guideline are not yet independently confirmed, though the structural fact of the repeal and replacement is well supported.

Casino-sector due-diligence thresholds remain anchored to the existing decree setting a 3,000 US dollar single-or-aggregated transaction trigger for standard customer due diligence, a rule that predates and was not itself amended, but which forms the baseline against which the revised sanctions guideline's new infraction categories will be applied.

Cross-Monitor Connections

The virtual-asset transition timeline intersects directly with the jurisdiction's digital-asset regulatory architecture: the same registration window and 30 June 2027 compliance deadline that matter for anti-money-laundering supervision also define the licensing perimeter for crypto-asset businesses operating in the country, meaning firms tracked under digital-asset market structure are the same population subject to the anti-money-laundering transition obligations described here. The revised non-financial sanctions guideline likewise has a direct read-across to commercial activity in sectors such as gambling, where customer due-diligence failures now carry a more clearly defined enforcement consequence.

Outlook

Uruguay's financial integrity posture is best read as structurally stable but administratively active: the core statutory architecture, including the anti-money-laundering law as amended in March 2026 and the virtual-asset licensing law, is not in flux, but its implementation detail is still being filled in. SENACLAFT's own leadership has signalled that a further reglamentary decree for the non-financial sector is anticipated before the end of 2026, though its content has not yet been published, so the sanctions-guideline revision may be an interim step rather than the final word. The virtual-asset transition window will remain the key date-driven item through the first half of 2027, with the 31 March 2027 application deadline and the 30 June 2027 general compliance deadline both falling due in that period. Uruguay was not on the Financial Action Task Force's list of jurisdictions with strategic deficiencies as at the most recent plenary referenced in the available evidence.

18 Oct 2026 · fim-2026-10-18

Lead Signal

Uruguay's anti-money-laundering architecture is tightening its treatment of professional enablers even as its own supervisory leadership acknowledges a persistent enforcement gap elsewhere in the system. Article 33 bis of Ley 19.574, as inserted by the March 2026 reform law Ley 20.469, now expressly criminalises assisting, helping and advising money laundering, extending liability to the professional-adviser layer that structures and facilitates underlying transactions rather than only those who execute them directly. The Secretaria Nacional contra el Lavado de Activos (SENACLAFT) has confirmed the change through its own primary publication, and the statutory text is independently verifiable. At the same time, SENACLAFT's own director has acknowledged in public remarks that prosecution of fiscal-crime and cybercrime predicate offences remains persistently low despite this strengthened professional-advice offence, a signal that the gap sits in enforcement capacity rather than in the statute book.

Other Developments

Sanction-grading guidelines for non-financial obliged entities. SENACLAFT Resolución N° 61/026 of 26 June 2026 establishes new pautas for applying sanctions where non-financial obliged entities breach anti-money-laundering prevention rules, confirmed directly via SENACLAFT's own published resolution. Supervisory perimeter expansion. Resolución N° 54/2026, flowing from the same March 2026 reform law's amendment of article 13 of the comprehensive anti-money-laundering statute, moves non-financial trustees and back-office or administrative service providers from Banco Central del Uruguay supervision to SENACLAFT supervision, a standing reform rather than a new-this-cycle event but one that continues to define the current obliged-entity perimeter. Virtual-asset service provider framework. Banco Central Circular N° 2507, published 16 July 2026 according to secondary law-firm commentary, establishes a comprehensive regulatory framework for proveedores de servicios de activos virtuales, including an integral prevention system and travel-rule obligations, with an authorisation window running from 1 September 2026 to 31 March 2027.

Cross-Monitor Connections

The virtual-asset service provider framework under Circular N° 2507 connects directly to World Payments Monitor coverage of Uruguay's digital-payments infrastructure, where travel-rule and CDD obligations for crypto-asset operators bear on cross-border settlement and corridor dynamics tracked separately by that monitor. The professional-advice criminalisation under article 33 bis also has implications for Advennt's enforcement-theory tracking of Uruguay's licensed sectors, insofar as professional advisers structuring transactions for any licensed activity now face direct criminal exposure under the amended statute, though that application has not itself been evidenced this cycle.

Outlook

The central question for Uruguay's AML/CFT trajectory is whether the strengthened article 33 bis offence translates into actual prosecutions of fiscal-crime and cybercrime predicates, an area SENACLAFT's own director has flagged as structurally under-prosecuted. With GAFILAT's next mutual evaluation on the horizon toward 2030, the gap between statutory strength and enforcement capacity will likely remain a point of scrutiny. No FATF plenary document or GAFILAT intersessional communication specific to Uruguay was located this cycle to independently confirm or update grey-list status, and this remains a standing gap in the evidentiary record rather than a resolved question.

11 Oct 2026 · fim-2026-10-11

Lead Signal

Uruguay finalised a comprehensive virtual-asset service provider authorisation and AML regime this cycle. Banco Central del Uruguay Circular N° 2507, published 16 July 2026, incorporates a definitive regulatory framework for Proveedores de Servicios de Activos Virtuales (PSAV) into the Recopilación de Normas del Mercado de Valores, covering authorisation, corporate governance, compliance and AML/CFT. This moves Uruguay from an ambiguous, consultation-stage posture to a developed capital, custody and AML regime, positioning it as a comparatively advanced VASP jurisdiction within South America, though still short of a fully bespoke statute comparable to the EU's MiCA. A registration window running from 1 September 2026 to 31 March 2027 allows existing operators to regularise while continuing to operate, with general compliance due by 30 June 2027.

Other Developments

AML obligated-entity scope widened structurally. Ley N° 20.469, dated 19 March 2026, amended Ley N° 19.574 article 13 to bring permutas, daciones en pago and virtual-asset-linked operations into the AML control perimeter, and amended article 6 to widen the reportable-operation universe. SENACLAFT, the national AML secretariat, separately replaced its sanctions-grading framework for non-financial obligated entities via Resolución N° 61/026, dated 26 June 2026, which supersedes Resolución 016/022 and establishes new infraction definitions and sanction-grading criteria. Non-financial obligated entities affected include casino operators under the widened article 13 scope. Read together, the widened reportable-operation scope and the replaced sanctions framework constitute a structural tightening of Uruguay's AML architecture rather than an episodic enforcement event.

No grey-list exposure. As confirmed at the FATF June 2026 Plenary, Uruguay does not appear on FATF's 22-jurisdiction increased-monitoring list.

Commercial funding event in the digital-asset-adjacent sector. Infinia, a Montevideo-headquartered company connecting traditional banking rails to stablecoin and digital-asset infrastructure, closed an oversubscribed US$13.5 million Series A led by Bain Capital and Variant Fund, announced between 9 and 16 July 2026.

Cross-Monitor Connections

The PSAV authorisation regime under Circular N° 2507 is a direct crossover with world-payments, which tracks the same instrument from the stablecoin-and-digital-money infrastructure angle; this brief's framing is the AML/financial-integrity architecture reading of the same underlying development. The Infinia funding round is likewise a shared commercial-activity fact between financial-integrity and world-payments, reflecting the same underlying evidence viewed through different lenses.

Outlook

The PSAV registration window closing 31 March 2027 and the general compliance deadline of 30 June 2027 are the two operative dates to watch for whether Uruguay's definitive VASP framework is actually absorbed by incumbent operators rather than remaining aspirational. On the AML side, the practical question is how quickly non-financial obligated entities, including casinos, adapt internal controls to the widened article 13 reportable scope and the new Resolución N° 61/026 grading criteria, both already in force.

Domain intelligence (D1–D8)

D2 Beneficial Ownership

stable

AIN launched BO fine-calculator simulators on 7 October 2026.

D3 Enabler Jurisdictions

no_changestanding position

Enabler Jurisdictions

Uruguay's standing as an enabler jurisdiction this cycle is defined less by a new structural opening than by a structural tension within its own supervisory apparatus. SENACLAFT has strengthened the statutory tools available against professional enablers: article 33 bis of Ley 19.574, as inserted by Ley 20.469 (promulgated 19 March 2026), now expressly criminalises assisting, helping and advising money laundering, closing a gap through which professional advisers structuring laundering-adjacent transactions might previously have avoided direct liability. This is confirmed via SENACLAFT's own primary publication and represents a genuine hardening of the professional-enabler offence architecture.

Continue reading

Yet the same cycle surfaces, through SENACLAFT's own director, an acknowledgement that prosecution of fiscal-crime and cybercrime predicate offences remains persistently low. This is a materially significant signal under an architecture-over-incident reading: a jurisdiction can possess a robust statutory offence against professional facilitation while still functioning as a practical enabler if the predicate offences that would trigger investigation of that facilitation are rarely pursued. The gap, as characterised by SENACLAFT's own leadership, appears to be one of enforcement capacity and prioritisation rather than a deliberate policy of permissiveness, which is itself a relevant distinction for assessing Uruguay's enabler-jurisdiction profile: a resourcing gap is a different risk than a designed loophole, but it produces a similar practical effect for predicate-offence accountability in the near term.

The supervisory perimeter itself continues to widen. Resolución N° 54/2026, flowing from the same March 2026 reform's amendment of article 13 of the comprehensive anti-money-laundering statute, moved non-financial trustees and back-office or administrative service providers from Banco Central del Uruguay supervision to SENACLAFT supervision. This is a standing development rather than new this cycle, but it remains the operative description of which entities sit inside SENACLAFT's direct supervisory reach as professional-services enablers, and it is relevant context for assessing which categories of facilitator the new article 33 bis offence can realistically be applied against.

Outlook

The trajectory to watch is whether the article 33 bis offence generates actual prosecutions of professional advisers tied to fiscal-crime or cybercrime predicates, or whether it remains a statutory tool rarely invoked in practice, consistent with the under-prosecution pattern SENACLAFT's own director has acknowledged. Uruguay's 2030 GAFILAT mutual evaluation will likely test this gap between statutory architecture and enforcement outcomes directly. No independent FATF or GAFILAT documentation specific to Uruguay was located this cycle to corroborate or update this assessment, which remains a gap in the evidentiary record rather than a resolved finding.

D5 Crypto / Digital Assets / Financial Innovation

watch

Crypto / Digital Assets / Financial Innovation

Uruguay's digital-asset regime, built on the virtual-asset services law and the Central Bank's implementing circular, has entered a scheduled transition phase rather than a period of design uncertainty. Firms already providing virtual-asset exchange, custody, transfer or administration services before the licensing framework came into force are permitted to continue operating while their authorisation applications are under Central Bank review, on the condition that those applications are submitted within a defined window running from 1 September 2026 to 31 March 2027. A broader compliance deadline of 30 June 2027 applies to all remaining adjustments firms must make to align fully with the new regime. This structure is a deliberate grandfathering mechanism: it allows the incumbent virtual-asset industry to keep operating during the shift from an unregulated or lightly regulated environment to a formally licensed one, rather than forcing an abrupt cessation of services while applications are processed.

Continue reading

The anti-money-laundering dimension of this transition is inseparable from the licensing dimension. Virtual-asset service providers sit within the population of obligated entities under Uruguay's anti-money-laundering statute, and the same registration and compliance timeline that governs their prudential and operational licensing also governs the point at which they become subject to the full preventive system for money laundering, terrorist financing and proliferation financing. A firm that has not completed registration within the stated window faces the prospect of being treated as operating outside both the licensing perimeter and the anti-money-laundering preventive system simultaneously, which is a materially different position from a firm that has filed on time and is merely awaiting a licensing decision.

The evidentiary basis for the transition-window dates is reasonably solid, but the full text of the Central Bank circular establishing the virtual-asset provider framework has not been directly retrieved in the course of this research; the applicable dates and the broad contours of the transition period rest on secondary reporting rather than the primary regulatory text itself. This is a meaningful caveat for compliance teams relying on precise obligations, since secondary commentary can compress or simplify nuance present in the underlying circular, particularly around what counts as a qualifying application versus a mere expression of intent to register.

Outlook

The two dates that matter through the first half of 2027 are 31 March 2027, when the window to file a transitional application closes, and 30 June 2027, when the general compliance deadline for all remaining adjustments falls due. Firms that miss the first date lose the benefit of continuing to operate while awaiting authorisation; firms that miss the second face the prospect of being out of compliance with a framework that has, by that point, been in force for close to a year. Because the evidentiary record for the precise substance of the regulatory circular remains incomplete, further confirmation of the primary text would meaningfully sharpen understanding of edge cases, including how the regime treats virtual-asset businesses that are only partially within scope, such as those whose activity is limited to non-payment-function tokens. Absent new developments, the next structurally significant date for this regime is the March 2027 application deadline itself.

Baseline-Tracked Domains with No Current-Cycle Escalation (3 of 8)
  • D1 Sanctions: Standing coverage — no activity this cycle.
  • D4 Conflict Finance: Standing coverage — no activity this cycle.
  • D6 Compliance Technology & Active Defence: Standing coverage — no activity this cycle.
Regulatory horizon
In Force2026-H2 · ±half_year

Next European Commission high-risk third-country list biannual update

Uruguay continued unlisted status will be re-tested at the next Commission update; low but non-zero probability of listing given regional drug-trafficking-linked laundering exposure documented this cycle.
Source
Proposed2026-Q4 · ±quarter

SENACLAFT new reglamentary decree for non-financial sector expected

A new reglamentary decree for the non-financial AML sector is anticipated before year-end 2026 per SENACLAFT's own director.
Source
In Force Pending2027-Q2 · ±quarter

PSAV general compliance deadline

The general PSAV compliance deadline under Circular 2507 falls on 30 June 2027.
Source
3 dated · 3 pending date · baseline fim-2026-07-05
Role action cards
MLRO

SENACLAFT revised the sanctions guideline applied to non-financial obligated entities, reclassifying certain due-diligence and beneficial-ownership failures as grave infractions.

Non-financial obligated entities under Uruguayan anti-money-laundering supervision, including gambling operators, now face a more serious infraction classification for failures in customer due diligence and beneficial-ownership identification, under a guideline that replaced the prior 2022 version.

2 evidence refs
Compliance

Virtual-asset service providers operating before Uruguay's licensing framework took effect have a defined window to file for authorisation while continuing to operate.

Firms must file transitional applications between 1 September 2026 and 31 March 2027 to retain the ability to keep operating pending a licensing decision, with full compliance required by 30 June 2027.

1 evidence refs
Board

Uruguay's anti-money-laundering and virtual-asset frameworks are maturing on schedule rather than undergoing structural redesign.

The developments this cycle reflect implementation detail within already-committed regimes, including a revised sanctions guideline and a confirmed transition timeline for virtual-asset licensing, rather than new statutory risk.

2 evidence refs
CTO

Virtual-asset businesses operating in Uruguay face a defined registration and compliance timeline running through 30 June 2027.

Technical and platform compliance work tied to licensing requirements under the virtual-asset framework should be sequenced against the 31 March 2027 application deadline and the 30 June 2027 general compliance deadline.

1 evidence refs
Risk

The revised non-financial sanctions guideline sharpens enforcement consequences for due-diligence failures without changing the underlying due-diligence duty.

Entities that were previously exposed to the 2022 sanctions guideline now face reclassified, more serious infraction categories for the same underlying customer due-diligence and beneficial-ownership identification failures.

1 evidence refs
Operations

A new fine-calculation tool is available for estimating beneficial-ownership non-disclosure exposure.

The launch of online simulators by the Auditoría Interna de la Nación gives filers a practical reference point for estimating potential fines tied to beneficial-ownership non-disclosure, without altering the underlying registration obligation.

1 evidence refs
Audit

The evidentiary basis for the revised non-financial sanctions guideline rests on secondary legal commentary rather than the regulator's own published text.

Internal audit should treat the precise sanction figures under the revised guideline as provisional pending confirmation from SENACLAFT's own published resolution text.

1 evidence refs
Scenario sketches

Illustrative pathway from national supervision toward a hybrid EU-level model, and its distant read-across for non-EU transparency regimes

Illustrative orientation only: as the European Union moves its anti-money-laundering supervisory architecture from a purely national model toward one combining the directly applicable AML Regulation, a transposed sixth directive, and a new Authority exercising direct and indirect supervision of certain cross-border obliged entities, non-EU jurisdictions with their own beneficial-ownership and corporate-transparency registries could face indirect pressure to demonstrate equivalent rigour in registry accuracy and disclosure-failure sanctions, as correspondent banks and cross-border counterparties increasingly calibrate their own due diligence against the EU's hybrid standard. This is a structural illustration of a possible dynamic, not a prediction about Uruguay or any other jurisdiction, and not a statement that any such pressure has in fact materialised.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_change
T2 · EU AML Package / AMLAno_change
T3 · FATF Grey Listno_change
T4 · Beneficial-Ownership Register Statusno_change
T5 · Crypto & Digital-Asset Integritywatch
T6 · Sanctions Regime Divergenceno_change
Registers

Enforcement actions

  • 13 Mar 2026
  • 8 Apr 2026
  • 11 Apr 2026
  • A dawn raid in Santa Cruz, Bolivia captured long-fugitive Uruguayan drug lord Sebastián Marset, who was extradited to the United States within hours to face money-laundering and narcotics-related charges tied to a multi-ton cocaine trafficking and laundering network operating across Bolivia, Paraguay, Uruguay and Brazil. 13 Mar 2026
  • U.S. prosecutors filed a second superseding indictment against Marset adding narcoterrorism conspiracy and cocaine-trafficking-aboard-vessel charges, alleging drug proceeds were moved via bulk cash, cryptocurrency, and wire transfers by Paraguay-based money launderers on his behalf. 8 Apr 2026
  • A Paraguayan senator was convicted of money laundering and criminal association for providing operational and financial support to the Marset-linked Insfrán clan network, including a $1 million cash property sale to a frontman and use of a soccer club to disguise illicit proceeds as legitimate receivables. 11 Apr 2026

Sanctions changes

  • 4 Dec 2025
  • The European Commission's December 2025 update to the EU list of high-risk AML/CFT third countries added Bolivia and the British Virgin Islands while delisting Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania. Uruguay was not added to, nor previously present on, this list. 4 Dec 2025
  • FATF's Jurisdictions under Increased Monitoring list, as updated through the June 2026 plenary, continued to exclude Uruguay while reviewing and/or newly listing regional peers including Bolivia, Venezuela, Bosnia and Herzegovina, and Iraq. 19 Jun 2026

Regulatory horizon (register)

  • Next European Commission high-risk third-country list biannual update
  • BCU VASP authorisation applications window opens
  • PSAV general compliance deadlines (BCU Circular 2507)
  • SENACLAFT new reglamentary decree for non-financial sector expected
  • PSAV general compliance deadline
  • Uruguay virtual-asset/crypto regulatory framework finalization
  • Uruguay's next FATF/GAFILAT 5th-round mutual evaluation
  • Next EU high-risk third-country list biannual update
  • Uruguay UNTOC peer-review mechanism conclusion

Active schemes

  • [HIGH] Primer Cartel Uruguayo transnational cocaine-laundering network
  • Montevideo port and air cocaine transshipment corridor
  • Residual bearer-share and nominee opacity under Law 18,930
  • Crypto-asset regulatory gap exploited for laundering, contested status
Sources
  1. El Departamento del Tesoro emite históricas órdenes bajo una nueva y poderosa facultad para combatir el fentanilo | FinCEN.gov
  2. IMPO
  3. International Monetary Fund
  4. FATF
  5. SENACLAFT / GAFILAT
  6. Ferrere
  7. https://www.gub.uy/secretaria-nacional-lucha-contra-lavado-activos-financiamiento-terrorismo/institucional/normativa/resolucion-n-61026-del-26062026
  8. https://www.gub.uy/presidencia/comunicacion/noticias/senaclaft-sumo-su-fiscalizacion-dos-nuevos-sujetos-obligados-financieros
  9. https://www.dentons.com/es/insights/articles/2026/july/29/uruguay-ya-tiene-regulacion-definitiva-para-los-proveedores-de-servicios-de-activos-virtuales
  10. https://www.bcu.gub.uy/Comunicaciones/Paginas/Detalle-Noticia.aspx?noticia=527&title=El-BCU-aprueba-normativa-para-proveedores-de-servicios-de-activos-virtuales
  11. https://www.fatf-gafi.org/en/countries/detail/Uruguay.html
  12. https://complyadvantage.com/insights/fatf-plenary-june-2026-outcomes/
  13. https://www.elobservador.com.uy/cafe-y-negocios/startup-uruguaya-que-conecta-la-banca-tradicional-los-activos-digitales-capto-inversion-us135-millones-acelerar-su-expansion-n6050120
  14. https://www.jpdamiani.com/post/ley-integral-contra-el-lavado-de-activos-y-financiamiento-del-terrorismo-en-uruguay-principales-mod
  15. https://www.elobservador.com.uy/nacional/secretaria-antilavado-pide-que-aumenten-las-condenas-lavado-y-advierte-la-baja-persecucion-delitos-fiscales-y-ciberdelitos-n6060616
  16. https://www.gub.uy/secretaria-nacional-lucha-contra-lavado-activos-financiamiento-terrorismo/comunicacion/noticias/ley-20469-fecha-19032026
  17. https://www.gub.uy/secretaria-nacional-lucha-contra-lavado-activos-financiamiento-terrorismo/tematica/antilavado?page=1
  18. https://www.brumcosta.com/es/notes/modificacion-de-las-pautas-para-la-aplicacion-de-sanciones-a-los-sujetos-obligados-no-financieros-por-parte-de-la-senaclaft
  19. https://www.rsm.global/uruguay/es/news/fue-aprobado-decreto-que-reglamenta-ley-integral-contra-el-lavado-de-activos
  20. https://www.criptonoticias.com/regulacion/uruguay-activa-registro-empresas-criptomonedas/
  21. https://www.pymenoticias.com/post/uruguay-simulador-multas-beneficiarios-finales-sas
  22. Mutual Evaluation of Uruguay
  23. Uruguay
  24. Assessments
  25. Financial Action Task Force of Latin America (GAFILAT)
  26. Uruguay's measures to combat money laundering and terrorist financing
  27. FATF Annual Report 2024-2025
  28. The 2022 and 2013 Methodologies for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT/CPF Systems
  29. New Zealand's progress in strengthening measures to tackle money laundering and terrorist financing
  30. Japan's progress in strengthening measures to tackle money laundering and terrorist financing
  31. Mutual Evaluations
  32. The FATF Recommendations
  33. Sanctions Programs and Country Information | Office of Foreign Assets Control
  34. Anti-money laundering and countering the financing of terrorism at international level - Finance
  35. "Black and grey" lists
  36. Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov
  37. What Latin America's Crypto Surge Means for Compliance Teams | TRM Blog
  38. Public Statement on Pandora Papers
  39. About the Pandora Papers - ICIJ
  40. Pandora Papers: An offshore data tsunami - ICIJ
  41. Cyprus, Ghana and Kenya join growing list of countries to create beneficial ownership registries - ICIJ
  42. FAQ: About the Pandora Papers | OCCRP
  43. Pandora Papers reporting from across Europe - ICIJ
  44. Switzerland aims to track corporate ownership in attempt to curb money-laundering - ICIJ
  45. ICIJ releases new Pandora Papers data from two offshore service providers - ICIJ
  46. Guidance on Beneficial Ownership of Legal Persons
  47. ICIJ publishes final batch of Pandora Papers data on more than 9,000 offshore companies, trusts and foundations - ICIJ
  48. Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs
  49. 2025 Crypto Regulatory Round-Up
  50. 2025 LATAM Crypto Adoption: Latin America Emerges as Crypto Powerhouse
  51. FATF urges stronger global action to address Illicit Finance Risks in Virtual Assets
  52. Crypto-assets - Finance - European Commission
  53. How crypto regulation changed in 2025: a global review
  54. Digital Assets in Digital Finance Regulatory Standards and Law
  55. FSB thematic review 2025: Global crypto regulation remains fragmented despite market growth
  56. Quick guide on assessing the Money Laundering risks of virtual assets (VA) and virtual asset service providers (VASP)
  57. Virtual Assets
  58. Uruguay Emerges as New Center of International Drug Trade | OCCRP
  59. Uruguay Emerges as New Center of International Drug Trade
  60. Uruguay: UNTOC Review Mechanism
  61. UNODC in Partnership with Argentina, delivers an Advanced Training Course on Strengthening the Capacities of Criminal Justice Institutions along the Cocaine Route in Latin America and Caribbean
  62. The Long Trial of the Balkan 'Cocaine King' | OCCRP
  63. ARGENTINA - Data - European Union
  64. Overseas business risk: Uruguay - GOV.UK
  65. Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and An Individual | Office of Foreign Assets Control
  66. Venture capital firm hit with $216 million penalty for ‘egregious’ violations of US sanctions against Russian billionaire - ICIJ
  67. Issuance of Amended Russia-related Frequently Asked Questions | Office of Foreign Assets Control
  68. Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control
  69. Russia-related Sanctions Programs | Office of Foreign Assets Control
  70. Ukraine-/Russia-related Sanctions | Office of Foreign Assets Control
  71. Recent Actions | Office of Foreign Assets Control
  72. Russia-related Designations; Issuance of New and Amended Russia-related General Licenses | Office of Foreign Assets Control
  73. Transnational Criminal Organizations Designations; Issuance of Amended Russia-related General Licenses; Publication of Updated Russia-related Frequently Asked Questions | Office of Foreign Assets Control
  74. THEMATIC COMPILATION OF RELEVANT INFORMATION SUBMITTED BY URUGUAY
  75. Informe de Seguimiento Regular y Recalificación de ...
  76. Mutual Evaluation Report of the Eastern Republic of Uruguay
  77. 1 INFORME DE EVALUACIÓN MUTUA DE URUGUAY INFORME DE EVALUACIÓN MUTUA DE LA
  78. Documento del Presidente del GAFI Antilavado de activos y contra el
  79. INFORME DE EVALUACIÓN MUTUA DE LA REPÚBLICA ...
  80. Country policy and information note: Organised criminal groups, Brazil, March 2025 (accessible) - GOV.UK
  81. Primeiro Comando da Capital | OCCRP
  82. Primer Comando da Capital | OCCRP
  83. Primeiro Comando da Capital
  84. EUA irão classificar PCC e CV como organizações terroristas - Bloomberg
  85. Países lusófonos compõem novas rotas de tráfico de cocaína, aponta relatório | ONU News
  86. US to Name PCC, Comando Vermelho as Terrorist Groups: Brazil Prosecutor - Bloomberg
  87. Portuguese-speaking countries renew commitment to strengthen cooperation against crime
  88. Drug Laws/Individual Listing for URUGUAY
  89. World Drug Report 2025
  90. News: August 2018 - Uruguay: Early Warning Systems in Latin America and the Caribbean address health risks of drug use
  91. UNODC-WCO Container Control Programme reports record high cocaine seizures in Latin America and the Caribbean
  92. World Drug Report 2025 - Statistical Annex
  93. UN-backed programme logs record high cocaine seizures at seaports in Latin America and the Caribbean | UN News
  94. Crypto-assets: how the EU is regulating markets - Consilium
  95. Reglamentación y supervisión
  96. DIRECTRICES PARA UN ENFOQUE BASADO EN RIESGO MONEDAS VIRTUALES JUNIO 2015
  97. Blockchain - legal and regulatory framework | Shaping Europe’s digital future
  98. Digital finance: agreement reached on European crypto-assets regulation (MiCA) - Consilium
  99. Activos Digitales 101: regreso a lo básico | Bloomberg
  100. ¿Cómo controlar el influjo de las criptomonedas en los países en desarrollo? No es oro todo lo que reluce | Noticias ONU
  101. Bolivia Captures One of South America’s Most Wanted Drug Lords, Extraditing Him to U.S. | OCCRP
  102. U.S. Adds Narcoterror Charge Against Uruguayan Trafficking Suspect | OCCRP
  103. US Prosecutors Hint at More Charges for Alleged South American Drug Baron Sebastián Marset | OCCRP
  104. EXCLUSIVE: Fugitive Alleged Drug Trafficker Sebastián Marset Secretly Owned Colombian Concert Company | OCCRP
  105. Bolivia Captures $2 Million DEA Fugitive, Cartel Boss Marset - Bloomberg
  106. Accused Drug Lord Claims US Feds Tried to Shake Him Down for $4M in Crypto | OCCRP
  107. Spain Arrests 24 People Tied to Online Pedophile Ring | OCCRP
  108. Paraguayan Senator Convicted of Aiding International Cocaine Trafficker | OCCRP
  109. Spain Cracks Down on Anabolic and Sexual Enhancer Trafficking | OCCRP
  110. Cocaína y banano: traficantes de los Balcanes usaron cargamentos de fruta de la empresa familiar del presidente de Ecuador para enviar drogas | OCCRP
  111. European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance
  112. EU methodology for the identification of high-risk third countries - Finance
  113. High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission
  114. Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance
  115. High-risk and other monitored jurisdictions
  116. Jurisdictions under Increased Monitoring - 19 June 2026
  117. Anti-money laundering: the Commission updates its list of high-risk third-country jurisdictions to strengthen the international fight against financial crime - Finance
  118. Commission adds Russia to list of high-risk jurisdictions to strengthen international fight against financial crime
  119. Common EU list of third country jurisdictions for tax purposes - Taxation and Customs Union
  120. Reglamento de la Ley Contra el Lavado de Dinero u Otros ...
  121. Ley Contra el Lavado de Dinero u Otros Activos
  122. PREVENCIÓN DEL LAVADO DE DINERO Una Guía para Empresas de Servicios Monetarios
  123. La República Bolivariana de Venezuela
  124. Reglamento de la Ley contra el Lavado de Dinero y de Activos
  125. Articulo 6
  126. El Departamento del Tesoro emite históricas órdenes bajo una nueva y poderosa facultad para combatir el fentanilo | FinCEN.gov
  127. FATF / GAFILAT
  128. UNODC (hosting Uruguay's own national submission)
  129. UK Foreign, Commonwealth & Development Office
  130. OCCRP
  131. OCCRP
  132. OCCRP
  133. Elliptic (summarizing FSB thematic review)
  134. European Commission
  135. FATF
  136. OCCRP
Coverage gaps
fim-int-2026-07-07-G001: Direct Tier 1 verification (Banco C…
fim-int-2026-07-07-G001: Direct Tier 1 verification (Banco Central del Uruguay regulation text or official gazette) confirming or denying the current operative status of Law 20.345 VASP licensing is absent, leaving the D5 contested-status finding unresolved. [resolved]
fim-int-2026-07-07-G002: No source located explicitly confir…
fim-int-2026-07-07-G002: No source located explicitly confirming that Uruguayan authorities have not filed domestic charges against Sebastian Marset, so the domestic-prosecutorial-gap claim rests on absence-of-evidence reasoning rather than a direct confirming source. [resolved]
fim-int-2026-07-07-G003: Direct verification of the current …
fim-int-2026-07-07-G003: Direct verification of the current UK MLR Schedule 3ZA notice for Uruguay is absent; the UK high-risk third-country status is presently inferred from historical FATF and EU alignment only. [resolved]
fim-int-2026-07-07-G004: No FATF or GAFILAT mutual evaluatio…
fim-int-2026-07-07-G004: No FATF or GAFILAT mutual evaluation newer than the 2019 on-site visit exists for Uruguay, limiting the ability to assess whether DNFBP supervision and beneficial-ownership verification deficiencies identified in 2019 have since improved or worsened. [resolved]
fim-int-2026-07-07-G005: No Research-collected evidence exis…
fim-int-2026-07-07-G005: No Research-collected evidence exists this cycle on Uruguay-linked conflict-finance flows (D4) or compliance-technology and RegTech developments (D6); both domain rows are carried forward quiet pending future-cycle evidence. [resolved]
fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Full text of BCU Resolution SSF No. 2026-444 was not independently retrieved this cycle; only law-firm summaries (Ferrere, ECIJA) were used as corroborating evidence. [resolved]
fim-int-2026-09-28-G002: No UY-specific nexus identified thi…
fim-int-2026-09-28-G002: No UY-specific nexus identified this cycle for D1 (Sanctions), D2 (Beneficial Ownership), D3 (Enabler Jurisdictions), D4 (Conflict Finance), or D6 (Compliance Technology); this dispatch was scoped to the single bound jurisdiction UY per the union DR binding directive. [resolved]
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No D2 (Beneficial Ownership and Corporate Transparency) UY-specific development found this cycle; coverage gap, not an asserted absence of activity. [resolved]
fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): No D3 (Enabler Jurisdictions) UY-specific development found this cycle; coverage gap. [resolved]
fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D4'}): No D4 (Conflict Finance) UY-specific development found this cycle; coverage gap. [resolved]
fim-int-2026-10-18-G001: Tier-D jurisdiction watch (Cambodia…
fim-int-2026-10-18-G001: Tier-D jurisdiction watch (Cambodia, Laos, Mexico, Colombia) could not be actively searched this cycle; pooled budget directed at bound UY jurisdiction. [open]
fim-int-2026-10-18-G002: No SENACLAFT statistical publicatio…
fim-int-2026-10-18-G002: No SENACLAFT statistical publication substantiating the claimed enforcement gap in fiscal-crime/cyber predicate prosecution was located; the enforcement-gap narrative rests on a single T3 interview. [open]
fim-int-2026-10-18-G003: No FATF plenary document or GAFILAT…
fim-int-2026-10-18-G003: No FATF plenary document or GAFILAT intersessional communication specific to Uruguay was located to independently confirm grey-list status. [open]
fim-int-2026-10-25-G001: Tier-D jurisdiction watch (KH, LA, …
fim-int-2026-10-25-G001: Tier-D jurisdiction watch (KH, LA, MX, CO) not reached this cycle; search budget was pooled across all five consumers for the bound jurisdiction (Uruguay). [open]
fim-int-2026-10-25-G002: Full text of BCU Circular N.2507 wa…
fim-int-2026-10-25-G002: Full text of BCU Circular N.2507 was not directly retrieved; fine-scale and prudential-capital figures rest on T3 law-firm commentary only. [open]
FIM-GAP-001 (D3): Despite extensive US, Paraguayan and Boliv…
FIM-GAP-001 (D3): Despite extensive US, Paraguayan and Bolivian enforcement action against Uruguayan national Sebastián Marset and his 'Primer Cartel Uruguayo' network, Uruguayan authorities have not, per OCCRP reporting, filed formal domestic charges against him even though Uruguayan police have linked him to criminal enterprises within the country.
FIM-GAP-002 (D5): Uruguay has no finalized VASP licensing, r…
FIM-GAP-002 (D5): Uruguay has no finalized VASP licensing, registration, or AML/CFT supervisory regime for crypto-asset service providers; the FSB's November 2025 thematic review places Uruguay among jurisdictions where such a framework remains only 'under public discussion.'
FIM-GAP-003 (D3): No FATF/GAFILAT mutual evaluation more rec…
FIM-GAP-003 (D3): No FATF/GAFILAT mutual evaluation more recent than the 2019 on-site visit (published 2020) is available for Uruguay; consequently, all technical-compliance and effectiveness ratings referenced in this baseline predate the FATF's 2022 Methodology and the 18-month enforcement window under review.
FIM-GAP-004 (D3): Montevideo port and airport screening capa…
FIM-GAP-004 (D3): Montevideo port and airport screening capacity has historically been characterized as insufficiently equipped relative to the volume and sophistication of trafficking exploiting the corridor, per OCCRP/Deutsche Welle reporting on Uruguay's emergence as a European-bound cocaine embarkation point.

Evidence

Confidence-tiered claims

BCU Circular N° 2507 (16/07/2026) incorporates a definitive regulatory framework for virtual-asset service providers into the Recopilación de Normas del Mercado de Valores. [Source 1]
Probable · 1 source
Registration window 1 September 2026 to 31 March 2027 for existing operators; general compliance deadline 30 June 2027. [Source 1]
Probable · 1 source
Ley 20.469 (19/03/2026) amended art. 13 to bring permutas, daciones en pago and virtual-asset-linked operations into scope, and amended art. 6 to widen the reportable universe. [Source 1]
Probable · 1 source
Resolución N° 61/026 (26/06/2026) replaces Resolución 016/022, establishing new infraction definitions and sanction-grading criteria for non-financial obligated entities. [Source 1]
Probable · 1 source
Uruguay does not appear on FATF's 22-jurisdiction 'increased monitoring' list as confirmed at the June 2026 Plenary. [Source 1]
Probable · 1 source
US$13.5M Series A led by Bain Capital and Variant Fund, announced 9-16 July 2026. [Source 1]
Probable · 1 source
Expressly criminalises assisting, helping and advising money laundering, extending professional-enabler liability [Source 1]
Probable · 1 source
Comprehensive AML/CTF/CPF reform law promulgated 19 March 2026 [Source 1]
Probable · 1 source
New sanction-grading guidelines for breaches by non-financial obliged entities [Source 1]
Probable · 1 source
Moves non-financial trustees and back-office/administrative service providers from BCU to SENACLAFT supervision [Source 1]
Probable · 1 source
Comprehensive regulatory framework for virtual-asset service providers (PSAV), published 16 July 2026 [Source 1]
Probable · 1 source
Amends Ley 19.574 art.13, widening the scope of AML-obligated non-financial entities [Source 1]
Probable · 1 source
Repeals Resolución 16/2022 and classifies failure to perform CDD per sector rules, and non-identification of beneficial owners/third-party fund providers, as new grave infractions for non-financial obligated entities including casinos [Source 1]
Probable · 1 source
US$3,000 single-or-aggregated transaction threshold triggers standard CDD for casinos [Source 1]
Probable · 1 source
Incumbent virtual-asset firms may continue operating pending BCU authorisation if they file between 1 Sept 2026 and 31 Mar 2027; general compliance deadline 30 June 2027 [Source 1]
Probable · 1 source
AIN launched four online fine-calculator simulators (SA, SAS, SRL, other entities) for non-disclosure of beneficial owners on 7 October 2026 [Source 1]
Probable · 1 source
Art. 33 bis (Ley 19.574, as amended by Leyes 20.361/20.469, 2026) criminalises assisting, helping and advising money laundering where done to obstruct justice, evade consequences or secure gains; simplified due diligence for bank-sourced funds is no longer automatic. [Source 1]
Probable · 1 source
Uruguay risks regression toward increased monitoring if effectiveness indicators ('resultados inmediatos') are not improved before the next mutual-evaluation round; under-prosecution of tax crimes and cyber-enabled laundering was named as a weakness. [Source 1]
Probable · 1 source
PSAV authorisation window under Circular 2507 continues (opened 1 Sep 2026, incumbent filing closes 31 Mar 2027); no new AML-specific crypto instrument issued this cycle. [Source 1]
Probable · 1 source