VOVE ID Compliance Research

Chile KYC & AML compliance checklist

A practical, source-linked checklist for implementing KYC, KYB and AML requirements in Chile.

Chile KYC, KYB and AML compliance checklist cover

Direct answer

What does the Chile compliance checklist cover?

The Chile checklist translates primary KYC, KYB and AML rules into 11 control areas and 45 implementation checks. It identifies the relevant authorities, customer and beneficial-owner controls, reporting duties, recordkeeping expectations and evidence teams should retain.

Key regulatory facts

National FIU: Unidad de Analisis Financiero (UAF)
Core AML law: Law 19,913, latest consolidated version reviewed 1 August 2026
Current UAF rule: Circular 62 of 19 March 2025, effective 1 June 2025
Suspicious report: To UAF in the shortest possible time; no periodicity or monetary threshold
Cash report: Cash operations exceeding USD 10,000 equivalent; monthly, quarterly or semiannual by sector, including negative reports
General CDD trigger: Permanent relationship, linked occasional transactions of USD 3,000 or more, or suspicion; sector-specific Annex 2 thresholds may override
Beneficial owner: Natural person with at least 10% capital or voting rights, or effective control below that level
Wire information: For covered domestic and cross-border fund or asset transfers of USD 1,000 or more
Retention: At least 5 years from relationship end or the last occasional operation for Circular 62 registers
Fintech licensing: CMF registration and, for applicable services, authorization under Law 21,521 and consolidated NCG 502
Privacy transition: Current Law 19,628 applies through 30 November 2026; Law 21,719 reforms take effect 1 December 2026
FATF status: GAFILAT member; not on FATF public call-for-action or increased-monitoring lists reviewed 1 August 2026

Implementation detail

Chile compliance requirements and actions

Open each control area to review the requirement, recommended implementation action, evidence to retain and the primary-source citation used by the research team.

01Scope, authorities and licensingChile's UAF perimeter is activity-based. Sector supervision, CMF authorization and BCCh payment rules can apply in addition to UAF registration and reporting.4 items+

Persons and entities carrying on an activity listed in article 3 of Law 19,913 must register as reporting entities, appoint the UAF contact and comply with the law and current UAF instructions.
Implementation action
Classify every Chilean legal entity and service against the current article 3 list, register each covered entity in the UAF Reporting Entities Register and maintain the legal-representative and compliance-officer records.
Evidence to retain
Perimeter memorandum, entity and activity map, UAF registration, appointments, portal access and change log.
Primary citation
Law 19,913 art. 3; UAF Circular 62/2025 ch. B
A change to the compliance officer or legal representative registered with UAF must be requested through the UAF site within 10 business days.
Implementation action
Trigger a portal update from corporate HR and governance events and preserve the submission and accepted profile.
Evidence to retain
Change event, approval, 10-business-day tracker, portal request and UAF acknowledgement.
Primary citation
UAF Circular 62/2025 para. b.6
Professional provision of services listed in article 2 of Law 21,521 requires entry in the CMF Financial Service Providers Register and, where article 7 applies, CMF authorization before service begins.
Implementation action
Map crowdfunding, alternative trading, advice, custody, order routing and intermediation features to Law 21,521; obtain the required CMF registration and authorization under the consolidated NCG 502.
Evidence to retain
Service analysis, CMF application, register extract, authorization, conditions, governance and launch approval.
Primary citation
Law 21,521 arts. 2-7; CMF NCG 502, consolidated
Non-bank issuance or operation of payment means with provision of funds is governed by Law 20,950, BCCh rules and CMF supervision.
Implementation action
Determine whether the product is stored value, card issuance, card operation or another regulated payment function; obtain and maintain the required status and comply with the applicable BCCh Financial Regulations Compendium chapter.
Evidence to retain
Payment perimeter opinion, CMF status, BCCh rule map, funds-protection design and launch sign-off.
Primary citation
Law 20,950 arts. 1-3; BCCh Financial Regulations Compendium chs. III.J.1-III.J.3

02Governance and risk assessmentCircular 62 expects an organised risk-based prevention system, documented in a manual, supported by an accountable compliance officer and annual training.4 items+

Each reporting entity must maintain a Prevention and Detection Manual covering governance, CDD, beneficial owners, PEPs, risk policy, suspicious reporting, sanctions-list review and higher-risk jurisdictions.
Implementation action
Approve a manual tailored to the entity's products, customers, geography, channels and legal perimeter; map every mandatory topic and assign owners.
Evidence to retain
Approved manual, mandatory-topic cross-reference, risk assessment, owners, review history and staff access.
Primary citation
UAF Circular 62/2025 ch. J
The AML/CFT/CPF risk policy must use UAF national risk assessments and sector approaches where issued and classify exposure as high, medium or low.
Implementation action
Assess threats, vulnerabilities and impact across customers, products, services, transactions, geography and delivery channels; document control responses and residual risk.
Evidence to retain
Risk method, official inputs, assessment, scoring, control mapping, approvals and remediation register.
Primary citation
UAF Circular 62/2025 paras. f.8-f.12 and ch. J
The compliance officer controls UAF reporting and must have secure and timely access to the information needed for the role.
Implementation action
Define authority, direct escalation, deputies, portal credentials, confidentiality and access to customer, transaction and screening systems.
Evidence to retain
Appointment, role charter, access matrix, escalation records, credential review and continuity test.
Primary citation
Law 19,913 art. 3; UAF Circular 62/2025 chs. B-C
All staff must receive AML/CFT/CPF training at least annually, with the manual and UAF alert guide as minimum content.
Implementation action
Deliver annual entity-wide training plus role-specific modules, test understanding and remediate missed or failed completion.
Evidence to retain
Training plan, materials, date, attendance and participation record, test results and follow-up.
Primary citation
UAF Circular 62/2025 ch. L

03Natural-person identification and failed CDDCDD is continuous and must explain who the customer is, the purpose of the relationship and whether actual activity remains consistent with the declared profile.4 items+

Reporting entities must collect the Circular 62 identification set for customers, including identity, nationality, occupation, residence, contact information and relationship purpose.
Implementation action
Capture the required fields, obtain identity or passport evidence, authenticate it and record the purpose and expected activity before or during relationship establishment.
Evidence to retain
Customer sheet, document image, verification output, contact validation, purpose, expected activity, timestamp and reviewer.
Primary citation
UAF Circular 62/2025 paras. f.1-f.5
CDD applies before or during a permanent relationship, for linked occasional transactions of USD 3,000 or more, and whenever there is suspicion; Annex 2 contains sector-specific thresholds.
Implementation action
Configure the entity's exact Annex 2 rule, link apparently connected transactions and override all exemptions and thresholds when suspicion exists.
Evidence to retain
Sector classification, Annex 2 mapping, aggregation logic, test cases, customer file and suspicion override.
Primary citation
UAF Circular 62/2025 para. f.4 and Annex 2
Customer information must be updated at least annually or when relevant changes occur, and activity must be continuously compared with purpose, business and risk profile.
Implementation action
Schedule annual refresh, trigger event-driven review and investigate activity inconsistent with the declared profile as potentially unusual.
Evidence to retain
Refresh calendar, change alerts, updated sheet, monitoring cases, discrepancy resolution and approvals.
Primary citation
UAF Circular 62/2025 paras. f.2 and f.7
Refusal to provide required information or provision of false information is an alert requiring evaluation for a ROS.
Implementation action
Do not silently waive missing evidence; record the refusal or falsehood, escalate, consider whether the relationship can lawfully continue and document the ROS decision without tipping off.
Evidence to retain
Request and response, discrepancy evidence, restriction or exit decision, ROS analysis, filing receipt if applicable and communication log.
Primary citation
UAF Circular 62/2025 para. f.6

04KYB, registries and beneficial ownershipA company file must establish legal existence and authority and separately identify the natural people who ultimately own or control the customer.5 items+

For a legal person, Circular 62 requires the RUT or foreign equivalent, proof of constitution, validity and legal form, business activity, address, representatives and beneficial owners.
Implementation action
Obtain current Registry of Commerce or Registry of Companies and Societies evidence, constitutive documents and powers; reconcile RUT, legal status, officers and authority.
Evidence to retain
RUT, constitution, current-statute and validity certificates, registry history, powers, officer KYC, reconciliation and approval.
Primary citation
UAF Circular 62/2025 para. f.3; Commercial Code arts. 20-22 and 425-431; Law 20,659
A beneficial owner is a natural person with at least 10% direct or indirect capital or voting rights or one who exercises effective control even below 10%.
Implementation action
Trace every ownership layer, calculate indirect holdings and evaluate decision, appointment and asset-use control; identify every natural person meeting either limb.
Evidence to retain
Ownership chart, cap tables and shareholder registers, percentage calculations, voting agreements, control analysis and reviewer sign-off.
Primary citation
UAF Circular 62/2025 para. g.2
All reporting entities must obtain the UAF-form beneficial-owner declaration at the CDD trigger, take reasonable verification measures and keep the information in the customer record.
Implementation action
Collect the declaration electronically or in person, corroborate it with lawful independent sources, resolve inconsistencies and refresh it with customer changes.
Evidence to retain
UAF-form declaration, independent-source results, ownership evidence, discrepancy log, verification and updated customer sheet.
Primary citation
UAF Circular 62/2025 paras. g.3.1-g.3.5
Unjustified delay of 40 business days or refusal to provide beneficial-owner information is an alert; the entity may consider refusing or ending the relationship where its governing law permits.
Implementation action
Start the request clock, escalate before expiry, document the alert and ROS assessment and obtain legal approval for refusal, restriction or exit.
Evidence to retain
Request chronology, 40-day control, escalation, ROS decision, legal approval and relationship outcome.
Primary citation
UAF Circular 62/2025 para. g.3.8
As at 1 August 2026, Chile's proposed general National Register of Beneficial Owners was not a substitute for the customer-level UAF declaration and verification process.
Implementation action
Use available company and shareholder records and the UAF declaration; monitor the official bill and implement any enacted registry duty only from its lawful commencement.
Evidence to retain
Current-law check, registry queries, declaration, verification, legislative watch and change assessment.
Primary citation
Ministry of Finance official bill page; UAF Circular 62/2025 ch. G

05PEPs, enhanced diligence and remote onboardingCircular 62 applies reinforced measures to PEPs and other high-risk cases. Electronic implementation is permitted but must still produce verifiable evidence.4 items+

Reporting entities must determine whether a prospective customer, customer or beneficial owner is a PEP under the Circular 62 categories.
Implementation action
Screen public functions and relevant relationships at onboarding and during the relationship, resolve matches and propagate a beneficial-owner PEP result to the customer risk assessment.
Evidence to retain
PEP screening, public-source evidence, role and relationship analysis, customer linkage, review date and alerts.
Primary citation
UAF Circular 62/2025 ch. H and para. g.3.6
PEP relationships require reinforced CDD including senior-management approval, reasonable source-of-wealth and source-of-funds measures and intensified ongoing diligence.
Implementation action
Obtain approval before starting or continuing, corroborate wealth and funds, document the operation purpose and increase monitoring and refresh frequency.
Evidence to retain
Senior approval, wealth and funds evidence, purpose, risk assessment, monitoring plan and periodic review.
Primary citation
UAF Circular 62/2025 para. h.4
Reinforced CDD applies to high-risk geographies, products, services, transactions and channels and whenever customer suspicion exists.
Implementation action
Collect additional purpose, funds and wealth information, require senior approval, intensify monitoring and update customer and beneficial-owner evidence more frequently.
Evidence to retain
High-risk trigger, additional evidence, approval, monitoring configuration, refresh record and disposition.
Primary citation
UAF Circular 62/2025 paras. f.9-f.10
Circular 62 permits electronic means for its obligations, but information still must be reasonably verified and retained.
Implementation action
Authenticate remote identity, bind the person to the evidence, test liveness or equivalent fraud controls where used, record consent and route exceptions to manual review.
Evidence to retain
Remote-flow design, identity source, authenticity and liveness tests, device data, consent, reviewer and retained record.
Primary citation
UAF Circular 62/2025 para. f.5 and operative clause SECOND

06Monitoring, suspicious reporting and confidentialityA ROS is suspicion-based and has no minimum amount or fixed periodic cycle. It is distinct from the periodic cash report.4 items+

All suspicious operations known in the reporting entity's activity must be reported through a ROS to UAF in the shortest possible time, with supporting documentation; there is no amount or periodicity threshold.
Implementation action
Escalate promptly, analyse related activity and participants, make a reasoned decision and file through the UAF channel without waiting for an ROE cycle.
Evidence to retain
Alert, linked activity, analysis, knowledge time, decision time, ROS, supporting documents and acknowledgement.
Primary citation
Law 19,913 art. 3; UAF Circular 62/2025 paras. c.1-c.4
Potential suspicious cases must be analysed in a structured way, documenting phases, steps and sources; analysed cases must be retained for five years.
Implementation action
Use a controlled case workflow that records opening and closing dates, reason, activity, analysis, sources, conclusion and the basis for filing or dismissal.
Evidence to retain
Case file, chronology, source log, investigator notes, decision, quality review and five-year retention tag.
Primary citation
UAF Circular 62/2025 paras. c.7-c.8
The reporting entity must protect the security, confidentiality and timeliness of ROS information.
Implementation action
Restrict report access, separate ROS content from ordinary customer service records, protect exports and prevent customer communications from revealing the review or report.
Evidence to retain
Access roles and logs, encryption, report repository, communication review, confidentiality training and incident record.
Primary citation
Law 19,913 arts. 6 and 13; UAF Circular 62/2025 para. c.5
A good-faith report under Law 19,913 benefits from the statutory protection, but the entity must still provide truthful and complete information.
Implementation action
Document the factual basis, separate fact from inference, preserve source material and correct material errors through the UAF process.
Evidence to retain
Approved narrative, source documents, legal review, submission, correction request and acknowledgement.
Primary citation
Law 19,913 art. 3

07Cash, transfers, payments and fintechCash reporting, transfer information and financial-service authorization are separate controls with different thresholds and authorities.4 items+

Reporting entities must file an ROE for cash operations exceeding USD 10,000 equivalent using the observed exchange rate on the operation date, and file a negative report when no such operation occurred.
Implementation action
Identify actual notes and coins, include cash deposits into the entity's account, convert using the correct date and submit either the positive or negative report.
Evidence to retain
Cash ledger, exchange-rate source, threshold calculation, ROE file, validation and UAF acceptance.
Primary citation
Law 19,913 art. 5; UAF Circular 62/2025 paras. d.1-d.5
ROE frequency is monthly, quarterly or semiannual according to the reporting entity category in Circular 62 Annex 1 and the official calendar.
Implementation action
Map the entity to Annex 1, maintain the current UAF calendar and verify system acceptance; correct rejected files and follow the replacement procedure.
Evidence to retain
Sector mapping, official calendar, submission, acceptance, error correction and reconciliation.
Primary citation
UAF Circular 62/2025 paras. d.4-d.7 and Annex 1; UAF 2026 ROE calendar
Providers of domestic or cross-border electronic transfers of funds or assets must include and verify originator and beneficiary information for transfers of USD 1,000 or more and retain it for at least five years, subject to stated exceptions.
Implementation action
Configure the required party, account, identity, address, amount, asset and date fields; detect incomplete messages and document card and institution-to-institution exceptions.
Evidence to retain
Transfer schema, field validation, verification, sample messages, exception rationale, repair queue and five-year retention.
Primary citation
UAF Circular 62/2025 ch. I
Law 21,521 regulated services may involve virtual financial assets or cryptoassets and require the correct CMF status; covered providers also fall within the UAF perimeter.
Implementation action
Analyse each virtual-asset activity as potential instrument custody, intermediation, order routing, advice or alternative trading; confirm CMF and UAF registration and authorization before launch.
Evidence to retain
Asset and service legal analysis, CMF status, UAF registration, authorization, customer disclosures, controls and launch approval.
Primary citation
Law 21,521 arts. 1-7 and 39; CMF NCG 502

08Targeted financial sanctionsChile requires systematic UN-list review and immediate UAF reporting. Asset restraint is ordered through the statutory UAF and Santiago Court process.4 items+

Reporting entities must periodically and systematically screen all customers and prospective customers against the UN Security Council lists identified by Circular 62 and retain search evidence for at least three years.
Implementation action
Screen at onboarding, throughout the relationship and on list changes; include aliases and ownership or control analysis and preserve every search result.
Evidence to retain
List inventory, update time, population, screening output, match analysis, ownership review and three-year retention tag.
Primary citation
UAF Circular 62/2025 paras. c.9-c.10; Law 19,913 art. 38
A positive identification on an applicable list must be reported immediately to UAF by ROS without first requiring transaction-behaviour analysis.
Implementation action
Escalate the identity match immediately, prevent avoidable asset movement within lawful authority, file the ROS and remain ready to implement the court-ordered measure communicated through UAF.
Evidence to retain
Match time, identity resolution, escalation, ROS, acknowledgement, asset status and authority communications.
Primary citation
UAF Circular 62/2025 para. c.11
UAF must seek the statutory measure from a Santiago Court of Appeals minister within 24 hours after receiving evidence that a listed person seeks to transact; UAF communicates an accepted measure to the reporting entity within 24 hours.
Implementation action
Maintain an always-on response route, freeze or restrict exactly as ordered, record scope and duration and follow extension, variation or release communications.
Evidence to retain
UAF communication, receipt time, implemented controls, asset ledger, legal review, status reports and release record.
Primary citation
Law 19,913 art. 38
Chile implements UN financial-sanctions obligations through Law 19,913, published decrees and the coordination framework in Decree 214/2020.
Implementation action
Maintain a legal inventory linking the UN list, Chilean decree and UAF procedure; monitor terrorism and proliferation designations and do not rely on a commercial list alone.
Evidence to retain
Legal inventory, official decree sources, vendor mapping, update tests, gaps and remediation.
Primary citation
Law 19,913 art. 38; Decree 214/2020

09Records and authority accessCircular 62 defines permanent registers and a five-year minimum, while sanctions-search evidence has its own three-year minimum.4 items+

Reporting entities must maintain permanent registers for cash operations, suspicious cases, CDD, PEP operations and, where applicable, electronic transfers of funds and assets.
Implementation action
Assign a system of record to each register, define mandatory content, prevent unauthorised alteration and reconcile filings to source records.
Evidence to retain
Register catalogue, schemas, access controls, reconciliations, exception log and owner approvals.
Primary citation
UAF Circular 62/2025 para. e.1
Circular 62 register information must be kept for at least five years from the end of the relationship or the last occasional operation and remain available to UAF and competent authorities.
Implementation action
Calculate the correct trigger, archive all supporting evidence, apply legal holds and test timely retrieval and authority production.
Evidence to retain
Retention schedule, customer and operation timeline, archive manifest, retrieval test, legal holds and production receipt.
Primary citation
UAF Circular 62/2025 para. e.2
If the entity keeps Circular 62 records for more than five years, it remains obliged to provide retained information when requested.
Implementation action
Align actual deletion with the approved schedule; do not claim that older retained records are outside UAF access merely because the minimum expired.
Evidence to retain
Actual retention configuration, approved deletion, request protocol, search log and response.
Primary citation
UAF Circular 62/2025 para. e.2
Records must support secure, complete and timely delivery during UAF supervision.
Implementation action
Maintain request intake, legal review, search reproducibility, a complete production index and chain of custody.
Evidence to retain
Request register, query, quality check, production index, secure transfer and receipt.
Primary citation
Law 19,913 arts. 2 and 5; UAF Circular 62/2025 operative clause THIRD

10Privacy, biometrics and international transfersAs at the review date, Law 19,628 remains operative. The Law 21,719 reform, new authority and cross-border regime commence on 1 December 2026 and require an explicit transition plan.4 items+

Through 30 November 2026, personal-data processing remains governed by the current version of Law 19,628, including purpose, consent or another lawful authorization, data quality, confidentiality, security responsibility and individual rights.
Implementation action
Map each KYC field to its purpose and current legal basis, provide clear notices, restrict reuse, secure data and operate correction, deletion or blocking workflows where applicable.
Evidence to retain
Data inventory, current-law basis matrix, privacy notice, consent where used, rights procedure, access controls and case log.
Primary citation
Law 19,628, version in force through 30 November 2026, arts. 4-12 and 23
The Law 21,719 reform takes effect on 1 December 2026 and introduces broader controller and processor duties, special-category controls, incident duties, international-transfer rules and the Personal Data Protection Agency.
Implementation action
Run a dated readiness programme, map future legal bases and notices, update contracts and transfer mechanisms, establish incident and DPIA governance and assign Agency engagement ownership without presenting future duties as already operative.
Evidence to retain
Transition plan, legal gap assessment, future-state records, contracts, DPIA method, incident workflow, training and go-live checklist.
Primary citation
Law 21,719 and deferred Law 19,628 text, effective 1 December 2026
Biometric and identity data require necessity, proportionality, accuracy and security under current law and will face express special-category and automated-decision controls under the future regime.
Implementation action
Use the least intrusive effective method, separate biometric templates, encrypt and restrict them, test bias and presentation attacks, provide accessible alternatives and define deletion.
Evidence to retain
Necessity assessment, current and future legal basis, vendor review, accuracy and bias testing, security, fallback and deletion test.
Primary citation
Law 19,628 arts. 2, 4, 9-11; Law 21,719 deferred amendments
Cross-border handling must satisfy the current Chilean legal basis and contract framework and be remediated for the adequacy, safeguard and accountability rules effective 1 December 2026.
Implementation action
Map destinations and onward transfers, document current authorization and processor terms, assess security and implement the appropriate future safeguard before the new regime starts.
Evidence to retain
Transfer map, current-law analysis, contracts, importer and subprocessor assessment, future safeguard and transition approval.
Primary citation
Law 19,628 arts. 4-5; Law 21,719 deferred Law 19,628 arts. 27-29

11Practical evidence packsEvidence should reconstruct the source, rule, decision, reviewer and timing without depending on staff memory.4 items+

Every onboarding decision should be reproducible from current official and customer evidence.
Implementation action
Bundle identity, company status, representatives, ownership and control, screening, purpose, risk, approvals and exceptions under one stable identifier.
Evidence to retain
Timestamped onboarding pack, source URLs and extracts, hashes, reviewer, decision and refresh date.
Primary citation
Implementation control supporting Law 19,913 and UAF Circular 62/2025 chs. F-H
Every ROS decision should show the full structured analysis required by Circular 62.
Implementation action
Preserve opening and closing dates, reason, related activity and people, sources, analysis, conclusion, filing or dismissal, and quality review.
Evidence to retain
Case file, chronology, source log, narrative, decision, ROS and UAF receipt where filed.
Primary citation
UAF Circular 62/2025 paras. c.7-c.8
Every regulatory parameter must remain linked to the current official source and the entity's exact sector category.
Implementation action
Maintain a parameter register for Annex 1 frequency, Annex 2 thresholds, USD conversion, beneficial-owner clock, transfer threshold, retention and sanctions response; test every change.
Evidence to retain
Parameter register, official source and review date, change ticket, test cases, deployment and post-change review.
Primary citation
UAF Circular 62/2025 and official UAF reporting calendar
Launch approval must address UAF, CMF, BCCh, privacy and operational evidence together.
Implementation action
Use a cross-functional release gate and block launch for unresolved perimeter, authorization, data, sanctions, reporting or record defects.
Evidence to retain
Signed launch checklist, legal analyses, register and authorization extracts, control tests, risk acceptance and rollback plan.
Primary citation
Implementation control; applicable Law 19,913, Law 21,521, Law 20,950 and Law 19,628 requirements

Primary-source register

22 sources used for this checklist

Use these links to verify the underlying legislation, regulator guidance, reporting procedures and international status statements.

Direct answers

Chile KYC, KYB and AML questions

Who receives suspicious operation reports in Chile?+

Reporting entities file Reports of Suspicious Operations (ROS) with the Unidad de Analisis Financiero (UAF) through the UAF reporting channel.

What is the ROS deadline?+

Circular 62 requires all known suspicious operations to be reported in the shortest possible time. A ROS has no fixed periodicity and no monetary threshold. The entity should preserve the knowledge, analysis, decision and filing timestamps.

What cash operations must be reported?+

Reporting entities report actual cash operations exceeding USD 10,000 equivalent at the observed exchange rate on the operation date. Frequency is monthly, quarterly or semiannual by sector under Annex 1, and a negative report is required when there is no reportable cash operation.

When is customer due diligence required?+

Generally before or during a permanent relationship, for one or more linked occasional transactions of USD 3,000 or more, and whenever there is suspicion. Circular 62 Annex 2 sets specific thresholds for listed sectors and must be checked.

Who is a beneficial owner?+

A natural person with at least 10% direct or indirect capital or voting rights, or a natural person who exercises effective control even with a lower percentage. Reporting entities must obtain the UAF declaration, take reasonable verification measures and record the result.

Does Chile have a universal national beneficial-owner register?+

As at 1 August 2026, the general National Register of Beneficial Owners remained an official legislative proposal. Operators still need the customer-level declaration and verification required by Circular 62 and must use available corporate and shareholder records.

How long must AML records be retained?+

Circular 62 permanent-register information is kept for at least five years from the end of the relationship or the last occasional operation. Evidence of periodic UN-list searches has a specific minimum of three years. Other sector or legal holds may require longer retention.

What happens on a UN sanctions-list match?+

The reporting entity immediately files a ROS without first requiring transaction-behaviour analysis. UAF uses the article 38 process to seek a measure from a Santiago Court of Appeals minister and communicates the accepted measure for immediate implementation.

Do fintech and virtual-asset services need CMF authorization?+

Services within Law 21,521 require CMF registration and, where article 7 applies, authorization under consolidated NCG 502. Because virtual financial assets can be instruments under the law, custody, intermediation, advice or trading features need a service-specific analysis. Covered providers also have UAF duties.

Which privacy regime applies in 2026?+

The existing version of Law 19,628 applies through 30 November 2026. The Law 21,719 reform, new Personal Data Protection Agency and new transfer and accountability rules take effect on 1 December 2026. Operators should run a transition programme while labelling future duties accurately.

Is Chile on the FATF grey list?+

No, based on the FATF public lists reviewed 1 August 2026. Chile is a GAFILAT member and remains subject to normal mutual-evaluation follow-up, which is separate from FATF public increased monitoring.

Research and review method

VOVE ID Compliance Research maps the regulatory perimeter, translates obligations into operational controls, links each material claim to a source and records the date and version of every review.

General regulatory information, not legal advice, an authorization decision or a substitute for the operative Spanish text, Circular 62 annexes, UAF portal instructions or sector rules. Reviewed 1 August 2026. Apply the exact Annex 1 ROE frequency and Annex 2 CDD threshold for the reporting entity. The new Law 21,719 privacy regime takes effect on 1 December 2026; implementation work should distinguish current duties from future-state controls. Confirm perimeter, reporting calendar, licensing, sanctions procedure, privacy transition and later developments with qualified Chilean counsel and the competent authority before launch.

Chile KYC & AML compliance checklist

What does the Chile compliance checklist cover?

Key regulatory facts

Chile compliance requirements and actions

Persons and entities carrying on an activity listed in article 3 of Law 19,913 must register as reporting entities, appoint the UAF contact and comply with the law and current UAF instructions.

A change to the compliance officer or legal representative registered with UAF must be requested through the UAF site within 10 business days.

Professional provision of services listed in article 2 of Law 21,521 requires entry in the CMF Financial Service Providers Register and, where article 7 applies, CMF authorization before service begins.

Non-bank issuance or operation of payment means with provision of funds is governed by Law 20,950, BCCh rules and CMF supervision.

Each reporting entity must maintain a Prevention and Detection Manual covering governance, CDD, beneficial owners, PEPs, risk policy, suspicious reporting, sanctions-list review and higher-risk jurisdictions.

The AML/CFT/CPF risk policy must use UAF national risk assessments and sector approaches where issued and classify exposure as high, medium or low.

The compliance officer controls UAF reporting and must have secure and timely access to the information needed for the role.

All staff must receive AML/CFT/CPF training at least annually, with the manual and UAF alert guide as minimum content.

Reporting entities must collect the Circular 62 identification set for customers, including identity, nationality, occupation, residence, contact information and relationship purpose.

CDD applies before or during a permanent relationship, for linked occasional transactions of USD 3,000 or more, and whenever there is suspicion; Annex 2 contains sector-specific thresholds.

Customer information must be updated at least annually or when relevant changes occur, and activity must be continuously compared with purpose, business and risk profile.

Refusal to provide required information or provision of false information is an alert requiring evaluation for a ROS.

For a legal person, Circular 62 requires the RUT or foreign equivalent, proof of constitution, validity and legal form, business activity, address, representatives and beneficial owners.

A beneficial owner is a natural person with at least 10% direct or indirect capital or voting rights or one who exercises effective control even below 10%.

All reporting entities must obtain the UAF-form beneficial-owner declaration at the CDD trigger, take reasonable verification measures and keep the information in the customer record.

Unjustified delay of 40 business days or refusal to provide beneficial-owner information is an alert; the entity may consider refusing or ending the relationship where its governing law permits.

As at 1 August 2026, Chile's proposed general National Register of Beneficial Owners was not a substitute for the customer-level UAF declaration and verification process.

Reporting entities must determine whether a prospective customer, customer or beneficial owner is a PEP under the Circular 62 categories.

PEP relationships require reinforced CDD including senior-management approval, reasonable source-of-wealth and source-of-funds measures and intensified ongoing diligence.

Reinforced CDD applies to high-risk geographies, products, services, transactions and channels and whenever customer suspicion exists.

Circular 62 permits electronic means for its obligations, but information still must be reasonably verified and retained.

All suspicious operations known in the reporting entity's activity must be reported through a ROS to UAF in the shortest possible time, with supporting documentation; there is no amount or periodicity threshold.

Potential suspicious cases must be analysed in a structured way, documenting phases, steps and sources; analysed cases must be retained for five years.

The reporting entity must protect the security, confidentiality and timeliness of ROS information.

A good-faith report under Law 19,913 benefits from the statutory protection, but the entity must still provide truthful and complete information.

Reporting entities must file an ROE for cash operations exceeding USD 10,000 equivalent using the observed exchange rate on the operation date, and file a negative report when no such operation occurred.

ROE frequency is monthly, quarterly or semiannual according to the reporting entity category in Circular 62 Annex 1 and the official calendar.

Providers of domestic or cross-border electronic transfers of funds or assets must include and verify originator and beneficiary information for transfers of USD 1,000 or more and retain it for at least five years, subject to stated exceptions.

Law 21,521 regulated services may involve virtual financial assets or cryptoassets and require the correct CMF status; covered providers also fall within the UAF perimeter.

Reporting entities must periodically and systematically screen all customers and prospective customers against the UN Security Council lists identified by Circular 62 and retain search evidence for at least three years.

A positive identification on an applicable list must be reported immediately to UAF by ROS without first requiring transaction-behaviour analysis.

UAF must seek the statutory measure from a Santiago Court of Appeals minister within 24 hours after receiving evidence that a listed person seeks to transact; UAF communicates an accepted measure to the reporting entity within 24 hours.

Chile implements UN financial-sanctions obligations through Law 19,913, published decrees and the coordination framework in Decree 214/2020.

Reporting entities must maintain permanent registers for cash operations, suspicious cases, CDD, PEP operations and, where applicable, electronic transfers of funds and assets.

Circular 62 register information must be kept for at least five years from the end of the relationship or the last occasional operation and remain available to UAF and competent authorities.

If the entity keeps Circular 62 records for more than five years, it remains obliged to provide retained information when requested.

Records must support secure, complete and timely delivery during UAF supervision.

Through 30 November 2026, personal-data processing remains governed by the current version of Law 19,628, including purpose, consent or another lawful authorization, data quality, confidentiality, security responsibility and individual rights.

The Law 21,719 reform takes effect on 1 December 2026 and introduces broader controller and processor duties, special-category controls, incident duties, international-transfer rules and the Personal Data Protection Agency.

Biometric and identity data require necessity, proportionality, accuracy and security under current law and will face express special-category and automated-decision controls under the future regime.

Cross-border handling must satisfy the current Chilean legal basis and contract framework and be remediated for the adequacy, safeguard and accountability rules effective 1 December 2026.

Every onboarding decision should be reproducible from current official and customer evidence.

Every ROS decision should show the full structured analysis required by Circular 62.

Every regulatory parameter must remain linked to the current official source and the entity's exact sector category.

Launch approval must address UAF, CMF, BCCh, privacy and operational evidence together.

22 sources used for this checklist

Chile KYC, KYB and AML questions

Research and review method

Verify once. Everywhere.

Chile KYC & AML compliance checklist

What does the Chile compliance checklist cover?

Key regulatory facts

Chile compliance requirements and actions

Persons and entities carrying on an activity listed in article 3 of Law 19,913 must register as reporting entities, appoint the UAF contact and comply with the law and current UAF instructions.

A change to the compliance officer or legal representative registered with UAF must be requested through the UAF site within 10 business days.

Professional provision of services listed in article 2 of Law 21,521 requires entry in the CMF Financial Service Providers Register and, where article 7 applies, CMF authorization before service begins.

Non-bank issuance or operation of payment means with provision of funds is governed by Law 20,950, BCCh rules and CMF supervision.

Each reporting entity must maintain a Prevention and Detection Manual covering governance, CDD, beneficial owners, PEPs, risk policy, suspicious reporting, sanctions-list review and higher-risk jurisdictions.

The AML/CFT/CPF risk policy must use UAF national risk assessments and sector approaches where issued and classify exposure as high, medium or low.

The compliance officer controls UAF reporting and must have secure and timely access to the information needed for the role.

All staff must receive AML/CFT/CPF training at least annually, with the manual and UAF alert guide as minimum content.

Reporting entities must collect the Circular 62 identification set for customers, including identity, nationality, occupation, residence, contact information and relationship purpose.

CDD applies before or during a permanent relationship, for linked occasional transactions of USD 3,000 or more, and whenever there is suspicion; Annex 2 contains sector-specific thresholds.

Customer information must be updated at least annually or when relevant changes occur, and activity must be continuously compared with purpose, business and risk profile.

Refusal to provide required information or provision of false information is an alert requiring evaluation for a ROS.

For a legal person, Circular 62 requires the RUT or foreign equivalent, proof of constitution, validity and legal form, business activity, address, representatives and beneficial owners.

A beneficial owner is a natural person with at least 10% direct or indirect capital or voting rights or one who exercises effective control even below 10%.

All reporting entities must obtain the UAF-form beneficial-owner declaration at the CDD trigger, take reasonable verification measures and keep the information in the customer record.

Unjustified delay of 40 business days or refusal to provide beneficial-owner information is an alert; the entity may consider refusing or ending the relationship where its governing law permits.

As at 1 August 2026, Chile's proposed general National Register of Beneficial Owners was not a substitute for the customer-level UAF declaration and verification process.

Reporting entities must determine whether a prospective customer, customer or beneficial owner is a PEP under the Circular 62 categories.

PEP relationships require reinforced CDD including senior-management approval, reasonable source-of-wealth and source-of-funds measures and intensified ongoing diligence.

Reinforced CDD applies to high-risk geographies, products, services, transactions and channels and whenever customer suspicion exists.

Circular 62 permits electronic means for its obligations, but information still must be reasonably verified and retained.

All suspicious operations known in the reporting entity's activity must be reported through a ROS to UAF in the shortest possible time, with supporting documentation; there is no amount or periodicity threshold.

Potential suspicious cases must be analysed in a structured way, documenting phases, steps and sources; analysed cases must be retained for five years.