🇻🇪 Venezuela · UNIF · LOCDOFT · LC/FT/FPADM
COX Compliance in Venezuela: the UNIF and non-financial obligated entities
If your business buys and sells real estate, builds, trades precious metals and stones or vehicles, or you are a lawyer, accountant, economist or administrator carrying out certain transactions for clients, the LOCDOFT makes you an obligated entity and the UNIF tells you how to report. COX gives you the day-to-day structure: due diligence files, restrictive list and PEP screening, beneficial owners, a risk matrix and the audit trail of every decision.
Regulatory framework of reference
- LOCDOFT: Official Gazette No. 39,912 of 30 April 2012; Article 9 designates the obligated entities
- UNIF: receives the RAS, sets its form sector by sector and issues circulars for every obligated entity
- RAS forms of 2024: one form and one set of instructions per sector, mandatory from 1 October 2024
- Circular UNIF-DDG-DSU-06915: freezing without delay on a match with the UN Security Council lists (11 November 2025)
- Circular UNIF-DDG-DSU-05448: identification, verification and register of beneficial owners (29 August 2025)
What the UNIF expects from a non-financial obligated entity
The Organic Law against Organised Crime and Terrorist Financing (LOCDOFT), published in Official Gazette No. 39,912 of 30 April 2012, is the law that designates the obligated entities. The National Financial Intelligence Unit (UNIF) receives the Suspicious Activity Report (RAS), sets its form and issues circulars for every obligated entity, financial and non-financial.
Over the last two years the UNIF changed three things a non-financial obligated entity has to keep up to date: the RAS form of its sector, how to act on a match with the UN Security Council lists, and what it must know and keep about its clients' beneficial owners.
Are you an obligated entity?
Besides the banking, insurance and securities sectors, Article 9 of the LOCDOFT designates as obligated entities, among others:
- Those who buy and sell real estate or construct buildings
- Those who trade precious metals and stones, or art or archaeological objects
- Those who buy and sell ships, aircraft and motor vehicles, or spare parts and used vehicles
- Those who buy, sell and service new and used mobile phones
- Those who rent and keep safe deposit boxes, transport valuables or transfer and send funds
- Those who advise on investments, placements and other financial business
- The merchant navy
- Public registry offices and public notaries
- Casinos, bingo halls and hotels or tourist centres authorised to exchange currency
- Foundations, civil associations and other non-profit organisations
Lawyers, administrators, economists and accountants in private practice are obligated entities when they carry out transactions for a client involving the purchase and sale of property, managing the client's money, securities, assets or accounts, organising contributions to create or run companies, or creating, operating or managing legal persons or arrangements and buying and selling commercial entities. Pawnshops, savings and credit cooperatives and remittance companies are not named as such in Article 9.
Your concrete duties
Customer due diligence
Do not deal with anyone who is not fully identified, identify the third parties involved and apply due diligence to politically exposed persons, as Articles 11, 16 and 18 of the LOCDOFT require.
Beneficial owner
Identify the beneficial owner in every case, whatever the client's risk, and trace the ownership chain to the human being who exercises control. Circular UNIF-DDG-DSU-05448 sets no percentage: you identify whoever has effective control.
Occasional transactions
Without a permanent relationship, the beneficial owner information is requested from three thousand dollars or the equivalent in bolivars at the BCV rate, in one transaction or in several that appear linked. If there is suspicion, it is requested whatever the amount.
Register of beneficial owners
Keep an up-to-date, complete digital register of beneficial owners, with the documents that support the chain: articles of association, share registers, contracts and share transfers. An unjustified delay or a refusal to provide them is a red flag.
Freezing on UN lists
On a match with a person or entity designated by the Security Council, freeze their funds and assets without delay, within twenty-four hours at most, without telling the client, and inform the UNIF within the following twenty-four hours. That notice is not the RAS and does not replace it.
Suspicious Activity Report
Detect unusual or suspicious transactions and file the RAS with the UNIF on your sector's form. Since 1 October 2024 the UNIF only accepts the forms it published on 30 August 2024, and it forbids altering them.
Confidentiality
Do not disclose to the client or to third parties that a RAS was filed or that a transaction is being examined, as Article 14 of the LOCDOFT orders.
Last month's cash
Report to the UNIF the cash transactions of the previous month, under Article 17 of the LOCDOFT.
Record keeping
Keep records for at least five years, under Article 10 of the LOCDOFT.
One RAS form per sector
On 30 August 2024 the UNIF published a RAS form and instructions for each sector, mandatory from 1 October 2024. The earlier formats, such as PE-UNIF-005, ceased to apply, and a RAS on a repealed format is not accepted. For non-financial obligated entities they are:
- DGOE-004/2024, registries and notaries
- DGOE-006/2024, tourism sector
- DGOE-007/2024, casinos, bingo halls and slot machines
- DGOE-008/2024, other designated non-financial businesses and professions
They are downloaded from the Circulars section of unif.gob.ve. The banking sector instructions set a deadline of no more than twenty-four hours from the moment the transaction was deemed suspicious; your sector's deadline is in the instructions that apply to you.
How COX solves it in Venezuela
Digital due diligence file
Every client, natural person or company, with identification, documents, assigned risk and a full record of who reviewed what, and when.
Beneficial owners with their chain
The shareholders and beneficial owners of each legal person stay in its file, and a shareholder that is itself a company is linked to its own file until the chain reaches the human being.
Restrictive list screening
Screening against the United Nations Security Council consolidated list, read from the official copy COX downloads, the OFAC lists and other international sources, with the edition searched and the evidence of every check.
Ongoing monitoring
When the issuer publishes a new edition of a list, COX checks your files against it and alerts you to every new match, which is what the UNIF asks for when the lists are updated.
PEP detection
A record of the politically exposed status of the client and of the people linked to them, with the enhanced due diligence workflow.
The RAS inside the system
The suspicious case is documented in COX with its analysis and supporting documents, prepared by the analyst and reviewed and approved by the manager, with a trail of every step.
Risk matrix
Classification by client, activity, geography and channel, with the documented methodology and the validity period of every assessment.
Digital onboarding
Clients complete the form and upload documents from their phone. You receive a finished, validated file.
Audit trail for your supervisory body
An immutable record of every decision. That is the difference between standing behind a file and rebuilding it when someone asks for it.
What COX does not do for you
COX does not fill in the UNIF's DGOE form or file the RAS on your behalf: the RAS is filed with the UNIF on your sector's format. Nor does it send the UNIF the freezing notice for the UN lists, or screen against Venezuelan national designation lists.
Circular UNIF-DDG-DSU-06915 treats as a match the same identity document, the same date of birth, or the same spelling of the name or its phonetics. COX compares names by spelling, not by sound: a phonetic match is assessed by your compliance officer.
What COX gives you is the file, the list screening, the beneficial owners, the risk matrix and the evidence behind each of those reports.
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.
data encryption · immutable audit log · role-based access · cloud hosting
Keep your programme in line with the UNIF rules
Frequently asked questions
COX also covers these countries:
Panama Mexico: PLD software Mexico: LFPIORPI Colombia Ecuador Guatemala Dominican Republic