Key facts
- The Citizenship by Investment Programmes Agency leads the evaluation.
- SIDE, UIF, the Ministry of Security and the Ministry of the Interior take part (official release).
- Decreto 524/2025 also consults RENAPER and the Registro Nacional de Reincidencia (criminal records).
- Standard: aligned with OECD and FATF. All funds must pass through the formal financial system.
Due diligence is where citizenship by investment programmes earn or lose their credibility. A 2023 joint report by the OECD and the FATF found that weak vetting in some programmes had let criminals launder money, hide assets and evade law enforcement. Argentina’s announcement on 2 October 2026 put due diligence close to the top, and named the OECD and FATF as its benchmarks.
This article explains who is involved, what each body is likely to examine, and what that means for a well-prepared applicant.
The six areas of review
The official release lists six areas:
- Identity verification. You are who you say you are, with a consistent history of names, dates and nationalities.
- Traceability and legality of funds. The money for the investment can be followed from its origin to the Treasury, and it was earned lawfully.
- Financial and asset analysis. Your overall wealth makes sense given your career, business and inheritance.
- Jurisdictional risk. Where you live, hold assets and do business, and whether those places carry sanctions or high money-laundering risk.
- Criminal and reputational background. Convictions, investigations, adverse media and connections.
- Migration history. Past visas, refusals, overstays and deportations.
Who does what
The release names the agencies. It does not describe how each one divides the work. The descriptions below rest on each body’s published role. How they apply it to this programme is our informed reading, not official procedure.
| Body | Public role | What it is likely to check |
|---|---|---|
| Agencia de Programas de Ciudadanía por Inversión | Evaluates applications; created under the Ministry of Economy | Collects the file, coordinates checks, writes the report |
| SIDE (Secretaría de Inteligencia de Estado) | State intelligence | National security, terrorism and serious organised-crime links |
| UIF (Unidad de Información Financiera) | Financial intelligence | Money-laundering, terrorist-financing and proliferation risk; suspicious-transaction history |
| Ministry of National Security | Federal law enforcement | Criminal records, warrants and police intelligence |
| Ministry of the Interior | Interior administration | Coordination with migration and civil registration |
| RENAPER | National registry of persons | Identity records and, if approved, Argentine identity documents |
| Registro Nacional de Reincidencia | National criminal-records registry | Argentine criminal records |
| Dirección Nacional de Migraciones | Migration authority | Migration history; final decision within 30 business days of the Agency’s report |
| ARCA | Tax and customs agency (replaced AFIP in 2024) | Not a vetting body under the decree; issues a tax ID (CUIT) to new citizens |
SIDE
SIDE is Argentina’s state intelligence secretariat. Its involvement suggests that applicants will be screened against intelligence holdings, not only public records. Applicants with links to sanctioned states, armed groups or serious organised crime should expect refusal.
UIF
The UIF describes itself as the body that analyses and disseminates financial intelligence to prevent money laundering, terrorist financing and the financing of weapons proliferation. It is the natural home for source-of-funds questions. Expect it to test whether your wealth story is consistent with the money trail. Our source of funds guide explains what evidence usually satisfies this kind of review.
Ministry of Security and Ministry of the Interior
The Ministry of Security oversees federal law enforcement, so criminal and police checks will likely run through it. The Ministry of the Interior’s role in the programme was not detailed in the release.
RENAPER and the criminal-records registry
Article 3 of Decreto 524/2025 lists the bodies the Agency consults: the Ministry of National Security, the UIF, the Registro Nacional de Reincidencia, RENAPER and SIDE, plus any other body it considers relevant. RENAPER, the national registry of persons, handles identity records and, at the end, Argentine identity documents. The Registro Nacional de Reincidencia holds Argentine criminal records.
ARCA, the tax and customs agency that replaced AFIP under Decreto 953/2024, has a different role. Under Article 5 of the decree it issues a tax identification number (CUIT) to new citizens. It is not listed among the vetting bodies.
What “aligned with OECD and FATF” means
The FATF sets the global standards against money laundering. Its standards ask for a risk-based approach, enhanced checks on politically exposed persons (PEPs), and attention to the source of wealth and source of funds.
Argentina itself was assessed by the FATF and its regional body GAFILAT in 2024. The report was adopted in October 2024. Argentina was not placed on the FATF “grey list”. The assessors noted progress since 2010, and asked Argentina to improve effectiveness, especially in prosecuting laundering linked to corruption. A clean, well-run programme matters for Argentina’s own standing with the FATF.
The 2023 OECD–FATF report on the misuse of citizenship and residency by investment recommends multi-layer due diligence. In practice, that usually means independent checks on identity, wealth and reputation, rather than trusting the applicant’s own file.
What this means for applicants
- Consistency wins. The agencies will compare your forms, your documents and public records. Small differences in names, dates or figures cause delays.
- Disclose, then explain. A past visa refusal, a minor conviction or a PEP connection is not always fatal. Concealing it usually is. DNU 366/2025 is reported to add concealment of facts as a ground to annul naturalisation, although this is not yet confirmed in an official consolidated text.
- Use the formal financial system. All funds must move through regulated banks. Cash, informal transfers and unexplained intermediaries will not pass.
- Expect questions. A request for more information is normal. Answer it fully and consistently.
Our list of application mistakes to avoid covers the most common problems. For the full document list, see requirements. For the steps in order, see how to apply.
Unknowns
As of 2 October 2026, the government had not published the due diligence fee, whether private screening firms will be used, the appeal process after a refusal, or a processing time before the Agency’s report.
The programme also faces a legal challenge. The Cámara Nacional Electoral declared DNU 366/2025 unconstitutional on 30 June 2026, and the government has appealed to the Supreme Court. See legal status.
Sources
- Government of Argentina, official release (2 October 2026): https://www.argentina.gob.ar/noticias/luis-caputo-anuncio-la-puesta-en-marcha-del-programa-de-ciudadania-por-inversion-de
- Boletín Oficial, Decreto 524/2025 (31 July 2025): https://www.boletinoficial.gob.ar/detalleAviso/primera/329061/20250731
- Palabras del Derecho, on Decreto 524/2025: https://www.palabrasdelderecho.com.ar/articulo/6125/El-Gobierno-reglamento-el-acceso-a-la-ciudadania-de-extranjeros-que-realicen-grandes-inversiones
- Unidad de Información Financiera (UIF), official page: https://www.argentina.gob.ar/uif
- FATF, Mutual Evaluation of Argentina (2024): https://fatf-gafi.org/en/publications/Mutualevaluations/MER-Argentina-2024.html
- Marval O’Farrell Mairal, “Argentina passed the FATF Mutual Evaluation”: https://www.marval.com/Publicacion/argentina-supero-la-evaluacion-mutua-del-gafi-16958?lang=en
- Marval O’Farrell Mairal, on the creation of ARCA: https://www.marval.com/publicacion/el-poder-ejecutivo-nacional-disuelve-afip-y-crea-arca-16988?lang=en
- OECD and FATF, “Misuse of Citizenship and Residency by Investment Programmes” (November 2023): https://www.oecd.org/en/publications/2023/11/misuse-of-citizenship-and-residency-by-investment-programmes_a3e76bac.html
- Perfil, on the Cámara Nacional Electoral ruling: https://www.perfil.com/noticias/judiciales/la-camara-nacional-electoral-anulo-el-dnu-de-milei-sobre-ciudadania-y-migraciones-el-fallo-considero-la-medida-inconstitucional.phtml
