Venezuela KYC, KYB & AML compliance checklist
A practical, source-linked checklist for implementing KYC, KYB and AML requirements in Venezuela.
- Last reviewed
- Last reviewed:
- Version
- Version 1.0
Direct answer
What does the Venezuela compliance checklist cover?
The Venezuela checklist translates primary KYC, KYB and AML rules into 11 control areas and 31 implementation checks. It identifies the relevant authorities, customer and beneficial-owner controls, reporting duties, recordkeeping expectations and evidence teams should retain.
Key regulatory facts
- FIU
- Unidad Nacional de Inteligencia Financiera (UNIF)
- Primary framework
- LOCDOFT and activity-specific supervisor rules
- Suspicion reporting
- Attempted or completed suspicious activity, regardless of amount, to UNIF; timing is sector-specific
- Beneficial ownership
- Identify and verify under the applicable sector rule; no single public central BO register confirmed
- Retention
- At least five years; banking and insurance sector rules may require ten years
- FATF status
- Increased monitoring as at 19 June 2026
Implementation detail
Venezuela 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 licensingResolve the entity, activity and supervisor before selecting controls.3 items+
Determine whether each activity is a reporting entity under LOCDOFT or a sector rule.
- Implementation action
- Map the legal entity, products, customers and channels to LOCDOFT articles 7-9 and the current supervisor perimeter; obtain local advice for gaps.
- Evidence to retain
- Applicability memo, product map and authority or counsel confirmation.
- Primary citation
- LOCDOFT arts. 7-9; applicable sector rule
Treat UNIF as the national FIU and reporting recipient.
- Implementation action
- Complete applicable RUSO and supervisor onboarding, nominate authorised users and test the prescribed UNIF channel.
- Evidence to retain
- Registrations, user approvals, access test and reporting procedure.
- Primary citation
- LOCDOFT arts. 13 and 25
Obtain authorisation before regulated banking, insurance, securities, payments, exchange or virtual-asset activity.
- Implementation action
- Classify the model with the competent supervisor and obtain every licence or registration before launch.
- Evidence to retain
- Perimeter analysis, authority correspondence and licence register.
- Primary citation
- Applicable sector legislation and supervisor rules
02Governance and risk assessmentControls must reflect the sector and Venezuela-specific risk.2 items+
Maintain documented AML/CFT/CPF risk governance.
- Implementation action
- Approve customer, product, channel, geography, sanctions and technology assessments and proportionate controls.
- Evidence to retain
- Board approvals, risk assessment, manual, testing and remediation log.
- Primary citation
- LOCDOFT arts. 8 and 10-19; applicable sector rule
Appoint the required compliance function.
- Implementation action
- Confirm eligibility, independence, resources, reporting line and registration or approval requirements with the relevant supervisor.
- Evidence to retain
- Appointment, role profile, authority filing and board minutes.
- Primary citation
- Applicable SUDEBAN, SUDEASEG, SUNAVAL, SAREN or other sector rule
03Natural-person identificationCDD uses reliable documents, data and risk-sensitive verification.3 items+
Identify and verify the customer before or while establishing the relationship.
- Implementation action
- Collect identity, address, occupation or activity, purpose and expected activity and authenticate evidence under the applicable rule.
- Evidence to retain
- Identity file, verification output, customer profile and approval.
- Primary citation
- LOCDOFT arts. 11-12 and 16
Identify representatives and verify authority.
- Implementation action
- Verify the representative and customer and authenticate the power or mandate before acting.
- Evidence to retain
- Identity results, power, authority check and approval.
- Primary citation
- LOCDOFT art. 16; applicable sector rule
Escalate incomplete or unreliable CDD without assuming an unrestricted exit right.
- Implementation action
- Do not establish an unidentified relationship; for an existing relationship, document legal review because LOCDOFT article 15 may require judicial authority to suspend, close or cancel service, and assess a confidential SAR.
- Evidence to retain
- Exception, legal review, service decision and SAR analysis.
- Primary citation
- LOCDOFT arts. 11, 13 and 15; sector rule
04KYB, registries, and beneficial ownershipRegistry evidence does not replace ownership and control analysis.3 items+
Verify legal existence, purpose, address, governance and authority.
- Implementation action
- Obtain current Commercial Registry, constitutive, RIF, director, signatory and power evidence and reconcile changes.
- Evidence to retain
- Registry extract, constitutive documents, RIF and powers.
- Primary citation
- Commercial Code arts. 201-336; Registries and Notaries Law; sector rule
Identify and verify natural-person beneficial owners under the applicable sector rule.
- Implementation action
- Trace ownership and control layers, document the sector definition used and do not invent a universal ownership threshold or fallback test.
- Evidence to retain
- Ownership chart, source records, control analysis and verified identities.
- Primary citation
- LOCDOFT art. 16; SUDEBAN Resolution 083.18 art. 49; applicable sector rule
Treat SAREN as a basic-information source, not a confirmed comprehensive public BO register.
- Implementation action
- Obtain authorised registry evidence and supplement it with customer and independent records; investigate discrepancies.
- Evidence to retain
- Registry record, access basis, supporting records and discrepancy decision.
- Primary citation
- Registries and Notaries Law; CFATF Venezuela MER, R.24
05PEPs, EDD, and remote onboardingHigh-risk cases require sector-specific enhanced measures.3 items+
Detect domestic and foreign PEPs, relatives and close associates.
- Implementation action
- Screen customers and connected persons and extend screening to beneficial owners as an internal risk control where the sector text is incomplete.
- Evidence to retain
- Screening, match decision and relationship map.
- Primary citation
- LOCDOFT arts. 4.19 and 18; applicable sector rule
Apply PEP approval, provenance and monitoring measures required by the sector.
- Implementation action
- Obtain senior approval, source-of-funds and source-of-wealth evidence and enhanced monitoring to the extent required and risk-appropriate.
- Evidence to retain
- Approval, provenance evidence and monitoring plan.
- Primary citation
- SUDEBAN Circular SIB-DSB-OPCLC-00161; sector PEP rule
Control non-face-to-face and technology risk.
- Implementation action
- Validate identity, liveness, device, fraud, security and exception controls before relying on remote onboarding.
- Evidence to retain
- Remote-onboarding assessment, tests and exceptions.
- Primary citation
- Applicable sector technology and CDD rules
06Monitoring and suspicious reportingUNIF reporting is confidential; scope and timing require careful sector mapping.3 items+
Monitor activity against the customer's profile.
- Implementation action
- Detect and investigate unusual, complex, linked and attempted activity and preserve a reasoned conclusion.
- Evidence to retain
- Alerts, investigation, disposition and rule governance.
- Primary citation
- LOCDOFT arts. 12-13; applicable sector rule
Report attempted or completed suspicious activity to UNIF regardless of amount.
- Implementation action
- Apply the current sector trigger and deadline; do not substitute the general 30-day UNIF circular where a different binding sector period applies.
- Evidence to retain
- SAR decision, chronology, submission and acknowledgement.
- Primary citation
- LOCDOFT arts. 4.2 and 13; applicable supervisor rule
Prevent tipping off and protect SAR confidentiality.
- Implementation action
- Restrict access and prevent disclosure that a SAR was filed or that related activity is under review.
- Evidence to retain
- Access logs, procedure and training.
- Primary citation
- LOCDOFT art. 14
07Payments, wires, thresholds, and agentsObjective reporting and payment requirements vary by activity.3 items+
Configure only applicable cash and objective reports.
- Implementation action
- Confirm report type, threshold, currency conversion, aggregation, period and deadline with the current sector rule and UNIF channel before configuration.
- Evidence to retain
- Rule copy, mapping, tests and receipts.
- Primary citation
- LOCDOFT art. 17; applicable sector rule
Preserve originator and beneficiary data for wire transfers.
- Implementation action
- For bank transfers, apply the current SUDEBAN wire rule regardless of value and control missing information.
- Evidence to retain
- Payment message, validation and exception decision.
- Primary citation
- SUDEBAN Circular SIB-DSB-UNIF-19610
Retain accountability for agents and outsourcing.
- Implementation action
- Perform diligence, contract for security and record access, monitor performance and test retrieval.
- Evidence to retain
- Due diligence, contract, monitoring and retrieval test.
- Primary citation
- Applicable sector governance and outsourcing rules
08Targeted financial sanctionsThe framework has material technical gaps; legal escalation is essential.3 items+
Screen applicable UN designations and national notices.
- Implementation action
- Screen customers, beneficial owners, counterparties and transactions at onboarding, list updates and before execution.
- Evidence to retain
- List source, update log, match logic and dispositions.
- Primary citation
- UN Security Council consolidated list; national Resolution 122 and Resolution 158 framework
Escalate potential matches immediately under the live sector and national process.
- Implementation action
- Prevent unauthorised movement where legally supported, notify compliance and obtain the competent authority route before freeze, report, reject or release action.
- Evidence to retain
- Match file, timestamps, legal basis and authority communications.
- Primary citation
- Resolutions 122 and 158; applicable sector rule
Do not overstate proliferation-financing freeze powers.
- Implementation action
- Record the legal basis for each PF action; CFATF rated Recommendation 7 non-compliant in the 2025 follow-up.
- Evidence to retain
- Legal analysis, authority instruction and controlled disposition.
- Primary citation
- CFATF Venezuela 2025 follow-up, R.7
09Records and regulator accessRetention varies between the statutory floor and sector overlays.3 items+
Retain transaction records for at least five years after completion.
- Implementation action
- Apply any longer sector period; banking and insurance rules identified by CFATF extend relevant retention to ten years.
- Evidence to retain
- Schedule, legal mapping, archive sample and deletion control.
- Primary citation
- LOCDOFT art. 10; SUDEBAN Resolution 083.18 art. 69; SUDEASEG Resolution SAA-8-004-2021 arts. 8 and 84
Retain CDD and correspondence for at least five years after relationship end or the occasional transaction.
- Implementation action
- Link identity, ownership, monitoring and reporting support under stable identifiers and apply longer sector rules.
- Evidence to retain
- CDD archive, case files and retrieval test.
- Primary citation
- LOCDOFT art. 10; applicable sector rule
Respond to lawful UNIF and supervisor requests.
- Implementation action
- Authenticate the request, preserve confidentiality, collect reproducibly and log production and receipt.
- Evidence to retain
- Request, legal review, production index and acknowledgement.
- Primary citation
- LOCDOFT arts. 8.6 and 25.2
10Privacy, biometrics, and transfersNo comprehensive general personal-data statute was confirmed; constitutional and sector duties remain relevant.3 items+
Document the lawful and proportionate basis for identity and AML processing.
- Implementation action
- Map purpose, necessity, notice, security, retention, access and disclosure against constitutional habeas-data and sector duties.
- Evidence to retain
- Data inventory, legal-basis memo, notices and rights procedure.
- Primary citation
- Constitution arts. 28 and 60; applicable sector confidentiality rules
Apply enhanced safeguards to biometric and sensitive data.
- Implementation action
- Minimise collection, restrict access, test security, document necessity and assess cross-border vendor and transfer risk.
- Evidence to retain
- Impact assessment, security tests, access controls and transfer analysis.
- Primary citation
- Constitution arts. 28 and 60; applicable special law and contract
Recheck legislative change before launch.
- Implementation action
- Confirm whether a comprehensive data-protection law or implementing authority has become applicable after this review date.
- Evidence to retain
- Dated legal update and counsel or authority confirmation.
- Primary citation
- CFATF Venezuela MER, R.2; current official gazette
11Practical evidence packsKeep concise packs that reproduce each decision.2 items+
Maintain a reconstructable onboarding pack.
- Implementation action
- Bundle identity, KYB, ownership, screening, risk, approvals and exceptions.
- Evidence to retain
- Complete sampled onboarding pack.
- Primary citation
- Operational control supporting LOCDOFT arts. 10-18
Maintain a reconstructable monitoring and reporting pack.
- Implementation action
- Link transactions, alerts, analysis, approvals, submissions and post-filing controls while protecting confidentiality.
- Evidence to retain
- Complete sampled case pack and access log.
- Primary citation
- Operational control supporting LOCDOFT arts. 10 and 13-14
Primary-source register
8 sources used for this checklist
Use these links to verify the underlying legislation, regulator guidance, reporting procedures and international status statements.
- Organic Law against Organized Crime and Terrorist Financing - legal analysis and operative provisionsCFATF / FATF · Authoritative mutual evaluation with statute citations
- Venezuela mutual evaluation and 2025 technical ratingsFATF · Authoritative country assessment
- Venezuela country page and current monitoring historyFATF · Authoritative country status
- Jurisdictions under increased monitoring - 19 June 2026FATF · Authoritative current status
- Venezuela third enhanced follow-up report announcementCFATF · Authoritative follow-up
- National securities supervisorSUNAVAL · Official financial supervisor
- Constitution of the Bolivarian Republic of VenezuelaSupreme Court of Justice · Primary constitutional text
- United Nations Security Council consolidated sanctions listUnited Nations · Authoritative sanctions list
Direct answers
Venezuela KYC, KYB and AML questions
Who receives suspicious activity reports in Venezuela?+
The Unidad Nacional de Inteligencia Financiera (UNIF).
When is a SAR filed?+
LOCDOFT covers attempted or completed suspicious activity regardless of amount. Filing periods vary by sector, so apply the current supervisor rule rather than inventing one universal deadline.
Is there one universal cash-report threshold?+
No universal amount should be assumed. Confirm the report, threshold, aggregation and deadline applicable to the entity and activity.
How long are AML records retained?+
LOCDOFT sets a five-year minimum. Banking and insurance rules identified by CFATF can require ten years for specified records.
Is beneficial ownership only a registry check?+
No. Apply the relevant sector definition and verify natural-person ownership and control; SAREN basic information does not replace customer due diligence.
What happens on a sanctions match?+
Escalate immediately, preserve the status quo where legally supported, and follow the competent authority and sector process. Venezuela's TF and PF targeted-sanctions framework has documented technical gaps.
Does Venezuela have a comprehensive general data-protection law?+
None was confirmed as applicable at the 14 August 2026 review. Constitutional habeas-data, privacy, secrecy and special-sector duties still require documented safeguards.
Is Venezuela on a FATF public list?+
Yes. It remained under increased monitoring on 19 June 2026. FATF does not call for automatic enhanced due diligence solely because of listing; use a documented risk-based approach.
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 or a licence determination. Reviewed and legally scoped as applicable on 14 August 2026. Confirm reporting-entity status, current sector rules, RUSO and UNIF filing specifications, cash-report parameters, beneficial-owner tests, sanctions mechanics, privacy basis, product licensing and official-portal availability with the competent supervisor and qualified Venezuelan counsel before launch.