Implications of the circular UNIF-DG-DSU-04409, for the subjects obliged to report suspicious activities (SARs)

Abstract

Suspicious activity reports (SARs) are a tool to stop and combat money laundering and terrorist financing. As of
November 10, 2023, with the publication of circular UNIF-DG-DSU-04409, parameters were established on these
reports. However, among the noteworthy points of the circular we find the subjects obliged to report suspicious
activities, among which are lawyers, accountants, administrators and financiers, a situation that generates some
controversy because, in certain careers, such as law, accounting or medicine, there is the obligation to maintain
professional secrecy when it comes to confidential information of their clients or patients. This essay will delve into
the content of the circular and establish certain considerations on the feasibility of its application in subjects who carry
out non-financial professional activities.