🇵🇷 Puerto Rico Offshore Banking
Intelligence Center

Act 38-2026 compliance window enters its final 45-day stretch as of August 15, 2026, with the September 30 deadline for existing Act 60 decree holders to file updated economic substance certifications now firmly in view. DDEC has confirmed no extension will be granted, and OCIF has begun issuing deficiency notices to decree holders whose 2025 annual reports remain incomplete. Affected entities should prioritize filing through the DDEC digital portal immediately to avoid decree suspension proceedings.

Two International Financial Entities licensed under Puerto Rico's IFE framework reported aggregate net income increases of approximately 8.3% year-over-year for Q2 2026, reflecting continued inflows from U.S. mainland high-net-worth clients relocating financial structures under Act 60 incentives. Deposit growth in the IFE sector outpaced broader Caribbean offshore jurisdictions for the third consecutive quarter, reinforcing Puerto Rico's competitive positioning. OCIF has indicated a routine supervisory review cycle for IFE licensees is scheduled for Q4 2026.

Act 38-2026 compliance deadline tracking confirms the October 31, 2026 submission window for existing Act 60 decree holders requiring amended export services certifications remains firm. DDEC has not issued any extension notices as of August 14, 2026, maintaining pressure on decree holders to complete updated filings within the 78-day remaining window. Advisory firms in San Juan report elevated client inquiry volumes related to the amended annual report requirements introduced under Act 38-2026.

OCIF continued routine supervisory monitoring of Puerto Rico's licensed International Financial Entities with no new public enforcement actions or license modifications posted to its bulletin board as of the August 14 morning cycle. Activity among IFE-chartered institutions remains stable, with the sector sustaining its position as a compliant US-jurisdiction offshore banking alternative following the 2025 FATF review cycle. No new charter applications or revocations were published in today's official registry update.

Act 38-2026 compliance deadline tracking continues with the 90-day window for existing Act 60 decree holders to file amended export services certifications now entering its final phase. DDEC has confirmed that decree holders who have not yet submitted updated beneficial ownership documentation under the revised OCIF guidelines risk suspension of their tax benefit status. Practitioners are urging clients to prioritize filings before the September 15 hard cutoff.

OCIF's International Financial Entities division published updated examination guidance this week reflecting heightened scrutiny of IFE-to-IFE correspondent relationships, effective immediately for all licensed international financial entities in Puerto Rico. The guidance aligns with FinCEN's 2026 beneficial ownership rule expansions and requires enhanced due diligence documentation to be retained on-site for a minimum of five years. Compliance officers at several San Juan-based IFEs have acknowledged receiving informal pre-examination inquiries from OCIF examiners.

DDEC continues processing Act 60 Individual Investors Act decree applications under revised 2026 submission protocols, with the agency confirming that incomplete applications flagged under the Act 38-2026 compliance review cycle must be remediated no later than September 30, 2026. Applicants who received deficiency notices in July 2026 are urged to engage licensed Puerto Rico tax advisors immediately to avoid decree nullification. OCIF has reiterated that all International Financial Entities operating under Act 273 must align their annual compliance certifications with the updated DDEC portal requirements by the same deadline.

Federal supervisory coordination between OCIF and US federal banking regulators remains active as part of the ongoing 2026 International Financial Entity examination cycle, with at least three IFE licensees understood to be in active examination as of mid-August 2026. No enforcement actions have been publicly announced, but OCIF has signaled that BSA/AML documentation standards are under heightened scrutiny following updated FinCEN guidance issued earlier this year. Existing IFE license holders are advised to review their customer due diligence frameworks ahead of any scheduled OCIF examination contact.

Act 38-2026 compliance deadline tracking enters its final 90-day window for existing Act 60 decree holders who have not yet completed the required updated economic substance filings with DDEC. Decree holders who fail to submit updated annual reports demonstrating substantive Puerto Rico operations by the November 2026 deadline risk administrative suspension of their tax incentive benefits. OCIF has signaled coordinated enforcement with DDEC for entities holding International Financial Entity licenses.

OCIF issued informal guidance clarifying that International Financial Entities operating under Act 60 must ensure their beneficial ownership disclosures are aligned with updated FinCEN Customer Due Diligence requirements effective as of Q3 2026. The guidance reinforces that Puerto Rico-chartered IFEs, despite their unique tax status, remain fully subject to US federal Bank Secrecy Act obligations and are expected to have updated CDD policies in place for examination cycles beginning September 2026.

Act 38-2026 compliance deadline monitoring remains active as the August 31, 2026 reporting window for existing Act 60 decree holders approaches. DDEC has confirmed no extension to the annual certification submission deadline, and decree holders are advised to ensure all employment attestations and charitable contribution documentation are filed through the SURI portal by month end. Non-compliant decree holders risk administrative suspension of tax benefits pending review.

OCIF issued updated supervisory guidance reminding International Financial Entities (IFEs) operating under Puerto Rico banking licenses to align their BSA/AML annual risk assessments with updated FinCEN beneficial ownership reporting standards effective under the revised CTA enforcement posture. Several IFEs with US mainland parent structures are coordinating with compliance counsel ahead of Q3 audit cycles. No new IFE licenses were granted or revoked in today's public record update.

Act 38-2026 compliance deadline pressure intensifies as the August 31, 2026 filing window for existing Act 60 decree holders to submit updated beneficial ownership certifications approaches. DDEC has confirmed no extensions will be granted beyond the statutory deadline, and decree holders who fail to comply risk automatic suspension of tax incentive benefits. OCIF has coordinated with DDEC to cross-reference International Financial Entity license holders against the Act 38-2026 registry to flag non-compliant entities.

OCIF issued informal guidance this week clarifying that International Financial Entities operating under Act 60 Chapter 3 must ensure their anti-money laundering program updates are aligned with the new beneficial ownership verification standards introduced under Act 38-2026 prior to the August 31 deadline. Several mid-tier IFEs have reportedly engaged local compliance counsel to audit internal AML frameworks ahead of the cutoff. The regulator signaled that examination cycles for IFEs will be accelerated in Q4 2026 to assess post-deadline compliance.

OCIF has issued updated compliance guidance for Act 60 International Financial Center decree holders, clarifying annual report submission standards for tax year 2025 filings due September 30, 2026. Decree holders are advised to ensure their annual certification of bona fide residency and qualifying services income documentation is aligned with the revised OCIF format released this quarter. Non-compliant submissions risk administrative review and potential decree suspension.

Tracking continues on Act 38-2026 implementation deadlines, with the August 31, 2026 milestone for existing International Banking Entity license renewals approaching. DDEC has confirmed that entities operating under grandfathered provisions must submit updated beneficial ownership disclosures consistent with FinCEN alignment requirements before the end of this month. Practitioners are reporting moderate administrative backlogs at OCIF's San Juan licensing office, with processing times averaging 18 to 22 business days.

Act 38-2026 compliance deadline tracking continues as the August 31, 2026 certification submission window for existing Act 60 decree holders approaches. DDEC has confirmed that decree holders must submit updated annual report certifications and proof of compliance with employment and investment thresholds by month-end or face potential decree suspension proceedings. Holders who have not yet filed are urged to coordinate with their designated DDEC compliance officer immediately.

OCIF issued informal guidance this week reinforcing anti-money laundering monitoring requirements for International Financial Entities operating under Act 273, citing increased scrutiny from FinCEN on correspondent banking relationships tied to Caribbean jurisdictions. Puerto Rico IFEs are advised to review beneficial ownership documentation and ensure SAR filing protocols are current ahead of a scheduled federal examination cycle expected in Q4 2026.

DDEC has confirmed that Act 38-2026 compliance certifications for existing Act 60 decree holders must be filed no later than September 30, 2026, with OCIF cross-referencing submissions against federal BSA reporting records. Decree holders who fail to submit updated economic substance documentation by this deadline risk administrative suspension of tax exemption benefits. OCIF has signaled increased coordination with FinCEN for International Financial Entities operating under Act 60 Chapter 2.

Two additional International Financial Entities received conditional IFE charter approvals from OCIF this week, bringing the 2026 year-to-date total to 14 new IFE licenses, reflecting continued investor demand for Puerto Rico's hybrid US-offshore banking structure. Approval conditions include enhanced KYC documentation thresholds aligned with updated FATF guidance. OCIF has not yet published revised examination schedules for newly chartered IFEs under Act 38-2026 provisions.

OCIF has continued processing Act 60 decree renewal applications ahead of the rolling 90-day review window, with practitioners reporting average turnaround times of 68 days as of early August 2026. Applicants are advised to ensure compliance documentation under the updated DDEC guidelines is submitted concurrently to avoid processing delays. No emergency rulemaking or emergency orders were issued by OCIF on August 5, 2026.

Act 38-2026 compliance deadline tracking indicates that affected International Financial Entities and eligible export service decree holders have approximately 119 days remaining before the December 1, 2026 statutory reporting milestone. DDEC field offices confirmed routine operations on August 5 with no new emergency guidance issued, though updated FAQ documentation on Act 38-2026 eligibility criteria remains pending publication. Practitioners monitoring this deadline should maintain current documentation packages ready for submission.

With the Act 38-2026 compliance deadline now under 60 days away, DDEC has confirmed that existing Act 60 decree holders must submit updated annual reports and economic activity certifications no later than September 30, 2026. Failure to meet this deadline may result in suspension of tax incentive benefits pending review. Decree holders are advised to coordinate with local certified public accountants familiar with Puerto Rico incentives law to ensure all required documentation is in order.

OCIF issued informal guidance this week reminding International Financial Entities (IFEs) operating under Act 273 that enhanced beneficial ownership disclosure requirements, aligned with updated FinCEN standards effective Q3 2026, must be reflected in their next compliance cycle submission. The guidance reinforces Puerto Rico's dual federal-local oversight framework and signals continued regulatory tightening consistent with US federal AML harmonization efforts. IFEs with non-US client bases are encouraged to review their KYC procedures against the updated federal baseline before the August 31 internal audit window.

Act 38-2026 enacted, the most significant amendment to Puerto Rico Act 60 since its 2019 consolidation. Key changes: (1) individuals applying from January 1, 2027 will face a 4% preferential tax on dividends, interest, and capital gains instead of 0%; (2) program extended from 2035 to 2055 for new applicants; (3) existing legacy decree holders may voluntarily swap to the new 4% framework in exchange for a 20-year extension to 2055; (4) new 6-year prior non-residency requirement for applicants from 2027.

CRITICAL DEADLINE confirmed, individuals who apply for the Resident Individual Investor incentive (formerly Act 22, now Act 60 Chapter 2) by December 31, 2026 are grandfathered into the 0% legacy structure valid to December 31, 2035. This is the last year to lock in 0% capital gains tax. The window closes December 31, 2026.

Act 60 2026 compliance requirements reconfirmed, Individual Investors must: (1) be bona fide Puerto Rico residents (183+ days); (2) make annual charitable donation of minimum $10,000 to approved PR nonprofits; (3) deposit at least 10% of exempt activity funds in Puerto Rico financial institutions; (4) file annual report with the DDEC; (5) demonstrate principal residence in Puerto Rico. Tax home and closer connection tests strictly enforced.

Act 60 Export Services (Chapter 3) reconfirmed at 4% corporate tax rate, 100% exemption on dividends from exempt business; up to 75% property tax exemption; 50% municipal license tax exemption. Export Services decrees have 15-year terms with potential for additional 15-year renewal. Growing digital services, fintech, and crypto businesses relocating to Puerto Rico under this framework.