SUSEP Electronic Circular No. 3/2022: Guidelines for submission of “Negative Communications” (CNO) in SISCOAF

The Superintendence of Private Insurance (“SUSEP”) published Electronic , in  regard to what is established by SUSEP Circular No. 612/2020, which regulates the systems for the Prevention of Money Laundering, Terrorism Financing, and Proliferation of Weapons of Mass Destruction (PLD/FTP).

SUSEP Circular No. 612/2020 determined the amendment of the so-called “negative communications” or  (“CNO”) – procedure for cases,  in which the agent must annually communicate to the Regulator t of proposals, transactions, atypical operations, or those suspected of money laundering and financing of terrorism.

Circular No. 3/2022 was published together with a guide which aims to  elucidate the step-by-step procedures for reporting the CNO under the new system:


The CNO referring to the entire previous calendar year must be filed by the last business day of March of the following year. In 2022, in light of the entry into force of SUSEP Circular No. 612/2020 in May 2021, the agents must send the Negative Communication  referring only to the period of May to December 2021, through the Control System of Financial Activities (“SISCOAF”) platform, whose access link can be found on the SUSEP website (accessible here).



The next step is to fill in the required fields in the system, during which the Superintendence of Private Insurance must be selected as the agency to which the information will be submitted.

  • Once SUSEP is selected, the CNO options will appear. For the year 2022, only information related to the year 2021 must appear in the system, with a deadline of March 31, 2022.
  • In the case that there are no proposals, transactions, or operations that can be communicated, the year in question must be selected, followed by pressing the “Confirm” button.
  • Finally, to confirm registration of the CNO, it is necessary to select the option “Register Communication of Non-Occurrence”, which is followed by the issuance of a certificate confirming the the negative communication submission.
  • SISCOAF enables supervised entities to reprint annual CNO certificates submitted after SUSEP Circular No. 612/2020 came into force.

For any queries  regarding the matter, agents can, initially, access the information available on the Prevention of Money Laundering webpage. Should such queries remain unresolved, they can be directed to

Demarest’s Insurance and Reinsurance team remains available to provide any further clarifications on this and other related topics.