🇩🇴 Dominican Republic · UAF · DGII
Law 155-17 compliance for non-financial obligated parties
If you are a lawyer, notary, accountant, real estate agent, developer or dealer in jewellery or vehicles, Law 155-17 makes you an obligated party and places you, in most cases, under DGII supervision. COX gives you the full structure: due diligence files, restrictive list and PEP screening, a risk matrix, and the audit trail that holds up a compliance opinion.
Regulatory framework of reference
- Law 155-17: against money laundering and terrorist financing; Article 33 lists the non-financial obligated parties
- UAF: the financial intelligence unit that receives the reports and coordinates the national system
- DGII: supervisor of the non-financial obligated parties that have no other regulator
- goAML: the platform for registration and for filing reports with the UAF
- General Rule 03-2022: the external audit of the compliance programme of the parties supervised by the DGII, every one, two or three years depending on the activity
- Criminal Code: Law 74-25, amended by Law 44-26: corporate criminal liability from 5 November 2026
November 2026: why compliance stops being optional
On 5 November 2026 Articles 8 to 11 of the new Criminal Code, Law 74-25, establishing corporate criminal liability take effect: Law 44-26 gave companies three months from 5 August 2026 to adapt. From that date a company answers for the offences its bodies, representatives or subordinates commit on its behalf when it failed in its duty of direction, control or supervision. A real and effective compliance programme in place before the offence mitigates the penalty; if it was circumvented by fraudulent means and management reported it, it excludes liability.
This is a legally distinct framework from Law 155-17, and the two should not be conflated: the AML programme is not on its own the programme of Article 8, which also requires, among other things, an anonymous reporting channel, accounting procedures against illicit payments and documentary traceability. But they share the same infrastructure, files, audit trail, recorded training and a whistleblower channel, so anyone whose AML programme is already in order starts with much of the way done.
Are you an obligated party?
Article 33 of Law 155-17 designates as non-financial obligated parties, among others:
- Lawyers, notaries, accountants and independent legal professionals acting on a client's behalf
- Real estate agents, in purchase and sale transactions
- Construction companies, when they buy or sell property or bring buyers and sellers together for a commission
- Dealers in precious metals, precious stones and jewellery
- Habitual buyers and sellers of vehicles, firearms, vessels and aircraft
- Casinos, games of chance, lottery outlets and sports betting
- Pawnshops
- Factoring companies
For legal and accounting professionals the duty is triggered by specific transactions: property transfers, managing client funds or securities, managing accounts, organising contributions to form companies, creating and administering legal entities, and buying or selling commercial entities.
Trust companies are not on this list: they are financial obligated parties under Article 32. Those that do not serve financial or publicly offered entities are supervised by the DGII.
Who supervises you?
This is the question that causes the most confusion in the Dominican Republic, because supervision is split. The rule in Article 2 is that each activity's natural regulator supervises it and, absent a specific one, the DGII does.
In practice, for most non-financial obligated parties (lawyers, notaries, accountants, real estate firms, jewellers, developers, vehicle dealers and pawnshops), the supervisor is the DGII. The gaming sector answers to the Directorate of Casinos and Games of Chance at the Ministry of Finance.
The UAF is not your direct supervisor: it is the financial intelligence unit that receives your reports and coordinates the national system. You register and report to it; you answer to the DGII.
Your concrete duties
Register with the UAF
Register on goAML, the UAF portal, as a reporting entity, even if there is nothing to report. The compliance officer administers the account, the UAF validates the registration within twenty-four to forty-eight business hours and its service page lists it as free.
Compliance officer
Appoint a senior executive with the technical capacity to act as liaison between you, the UAF and your supervisor. If you are a natural person, you may take on the role yourself. Parties supervised by the DGII register the officer with the UAF and inform the DGII within ten business days, and the officer receives at least twelve hours of specialised training a year.
Due diligence
Identify and verify the client's identity, understand the purpose of the business relationship, and establish the beneficial owner: the person exercising ultimate effective control or holding at least twenty per cent of the capital.
Risk-based approach
Scale the depth of due diligence to the client's profile, the transaction and the jurisdiction.
Suspicious operation report
File the ROS with the UAF within five business days of the operation, whether completed or attempted, through goAML. Any additional information the UAF requests is delivered within ten working days at most.
Cash transaction report
Report cash operations at or above fifteen thousand dollars, or the peso equivalent, with a three thousand dollar threshold for casinos. Multiple transactions reaching the threshold within twenty-four hours are reported as one, and each month's records are sent to the UAF within the first ten calendar days of the following month.
Freezing without delay
Check the United Nations Security Council lists at every update. On a match, freeze without delay, without telling the person affected, and notify the Public Prosecutor's Office and the UAF immediately. That notice does not replace a ROS where one is due.
Record keeping
Retain documentation for ten years after the business relationship ends or the occasional transaction is carried out.
External audit
Parties supervised by the DGII submit their programme to an independent external audit under General Rule 03-2022: lawyers, notaries, accountants, jewellers, vehicle dealers and real estate agents who are natural persons, every two years; legal persons in those activities, construction companies, factoring and trust companies, every year; firearms dealers and pawnshops, every three years. Small and medium-sized businesses and natural persons may file a simplified compliance opinion.
How COX solves it
Digital due diligence file
Every client with identification, documents, assigned risk and a full record of who reviewed what, and when.
Restrictive list screening
Screening against the United Nations Security Council consolidated list and FATF high-risk jurisdictions, at onboarding and on a recurring basis, with evidence of every check.
PEP detection
Identification of politically exposed persons, including foreign ones and those from international organisations, of their relatives to the second degree and of their close associates, with the enhanced due diligence workflow and source-of-funds verification.
Adverse media
Negative news searches on the client, filed within the record.
Risk matrix
Classification by client, activity, geography and channel, with the documented methodology the compliance opinion will examine.
Digital onboarding
Clients complete the form and upload documents from their phone. You receive a finished, validated file.
Threshold monitoring
Tracking of cash operations and twenty-four-hour aggregation, so the threshold does not slip past you.
Audit trail for the opinion and for DGII
An immutable, exportable record of every decision. That is the difference between supporting an opinion and improvising one.
Non-compliance has a price
Law 155-17's sanctioning regime classifies breaches as minor, serious and very serious. For non-financial obligated parties, the fines in force since 3 July 2024 range from RD$417,721 to RD$1,392,402 for minor breaches, from RD$1,392,404 to RD$2,784,805 for serious ones and from RD$2,784,806 to RD$5,569,610 for very serious ones.
Very serious breaches include failing to report suspicious operations, obstructing supervision, failing to freeze funds, and failures in client or beneficial owner due diligence. Serious ones include failing to appoint a compliance officer, lacking an external audit, and insufficient training.
For very serious breaches the sanction may reach directors personally, with fines of RD$696,201 to RD$4,177,207 each, removal from office and disqualification for up to ten years.
Why COX
Live in days
No installation, no long project. You start building files the same day.
Built for practices and mid-sized companies
Not a banking platform in disguise. Built for the volume and budget of a law firm, a real estate agency or a developer.
Pay as you go
No forced monthly fee. You pay for the clients you screen.
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Start before November
Frequently asked questions
COX also covers these countries:
Panama Mexico: PLD software Mexico: LFPIORPI Colombia Ecuador Guatemala Venezuela