Since 2023 Bolivia’s Financial Intelligence Unit (Unidad de Investigaciones Financieras, UIF) has asked the country’s lawyers, accountants and real estate providers to register as reporting entities, first when they qualified as large taxpayers and, from December of that year, across the board. The deadlines passed and the sectors did not fully comply. Administrative Resolution UIF/075/2026 of 8 September takes a different route. The UIF has published a list of 14,763 tax identification numbers (NIT), entered them in its CARONTE platform and given each one 90 days to say whether it belongs there. Those who say nothing stay on the list.
A list, not a definition
The list comes from an internal study built on the records of the Servicio de Impuestos Nacionales (SIN). It counts 6,185 entries from the legal sector, 7,699 from accounting and 879 from real estate, and it is attached to the resolution as Annex 2, one NIT after another. The UIF itself calls it a baseline and states that appearing on it does not by itself determine reporting-entity status. That sentence deserves attention. The list does not decide who is covered. It decides who must respond.
There are only two possible responses. One is to confirm registration as an Active Reporting Entity and obtain a Registration Certificate. The other is to apply for an exemption through an electronic sworn statement, on the basis that the applicant does not carry out the activities listed in Recommendation 22 of the Financial Action Task Force (FATF), and obtain an Exemption Certificate. For lawyers and accountants, those activities include buying and selling real estate for a client, managing client money, securities or accounts, organising contributions to set up or run companies, and creating or administering legal persons. For real estate providers, they involve participation in property purchases and sales. A litigation boutique that never handles client funds or incorporates companies has a clear case for exemption. A corporate practice almost certainly does not.
The list does not decide who is covered. It decides who must respond—and silence now counts as registration.
Silence counts as registration
What sets this instrument apart from its 2023 predecessors is Article 13 of the Regulations. Ninety calendar days after the resolution is published in a national newspaper, anyone who has neither confirmed registration nor applied for exemption is automatically registered as an Active Reporting Entity. Article 9 closes the loop. If the professional has not appointed a Compliance Officer (Funcionario Responsable) within that period, the UIF appoints one and issues the credentials for its reporting systems.
The burden has been inverted. In 2023, inaction cost the system, which was left without registrations. From now on it costs the professional, who is left with obligations. An active reporting entity must keep its details current in CARONTE, maintain a compliance officer, answer information requests and file Suspicious Transaction Reports under the UIF’s instructions. For a sole-practitioner accountant keeping the books of three shops, that is not paperwork. It is a compliance programme.
The price of an exemption
Exemption looks like the natural exit for those outside Recommendation 22, and it probably is for a large share of the 14,763. It carries two costs worth weighing before the sworn statement is signed. The first is evidentiary. The applicant answers for the truth, authenticity, completeness and accuracy of the statement, and the UIF keeps its powers of subsequent verification. Article 12 adds six-monthly monitoring of exemptions granted, counted from the end of the 90-day window. If the UIF finds that an exempted professional carries out covered activities, it registers them of its own motion and notifies them. Anyone applying should be able to show, from their service offering and engagement letters, why they fall outside the perimeter.
The second cost is upkeep. Certificates remain valid only while the conditions behind them persist. An exempted professional who begins covered activities has 10 calendar days to register; an active one who ceases them has 10 days to apply for exemption. In a growing or changing practice, someone will have to watch that threshold.
The calendar
The Regulations set three stages. The resolution takes effect on the first business day after publication in the national press. From that publication, the 90 days for registration or exemption begin to run. Once they end, active reporting entities have a further 180 calendar days to adapt to the UIF’s Specific Instructions, and only then do they fall under the supervision, control and sanction regime of the competent authority. In practice, a professional who confirms registration has roughly nine months from publication before facing sanctions for breaching preventive duties. One who lets the 90 days lapse without responding uses up that margin without ever having made a decision.
Why now
Supreme Decree No. 5665 of 27 July 2026 declared the fight against money laundering and terrorist financing a national priority, ordered compliance with FATF standards and gave the UIF 30 business days to regulate the registration and exemption of reporting entities. The Mutual Evaluation Report on Bolivia published by GAFILAT in 2024 had noted that lawyers, accountants and real estate providers outside the large-taxpayer category had no anti-money-laundering guidelines. This resolution is the institutional answer to that finding. For 14,763 taxpayers, it is also an outstanding task with an expiry date.
What to do
- Check on the UIF’s website whether your NIT, or your firm’s, appears in the Universe Delimitation.
- Decide, with the Recommendation 22 activities in front of you, whether registration or exemption applies, and document the reasoning.
- In either case, appoint the compliance officer before the UIF does it for you.
For businesses that buy these services, the question runs the other way. Their external counsel, accountant or real estate provider will start asking for due-diligence information they did not request before. It would be wise to have it ready.
