On February 24, 2026, Law No. 21,800 (the “Law”) was published in the Official Gazette, establishing a new regulatory framework for aggregate extraction, including traceability requirements, oversight mechanisms, and closure plans.

In addition to its operational and sectoral impact, the Law introduces significant amendments in the areas of Compliance and corporate criminal liability by incorporating new criminal offenses into Law No. 21,595 on Economic Crimes. These offenses are now included in the catalog of unlawful conduct that may give rise to criminal liability for legal entities under Law No. 20,393.

New offenses incorporated

The Law establishes two new criminal offenses relevant to companies operating within or connected to the aggregate extraction industry:

1. Forgery of traceability documentation
   Criminalizes the falsification or alteration of authorizations, technical approvals, or certificates of origin, as well as the malicious use of forged, incomplete, or inaccurate documentation.
2. Illegal extraction of aggregates
   Establishes as a criminal offense the extraction of aggregates without municipal authorization or without a favorable technical approval issued by the Department of Hydraulic Works.

Implications for Crime Prevention Models (CPM)

The inclusion of these offenses within the Economic Crimes framework requires companies directly or indirectly involved in the extraction, transport, processing, or use of aggregates - including those in the construction, infrastructure, and mining sectors - to reassess and update their Crime Prevention Models.

Recommended actions include:

• Updating risk matrices and process maps related to regulatory authorizations.
• Strengthening controls over documentation and traceability mechanisms.
• Enhancing due diligence procedures for contractors, subcontractors, and transport operators.
• Revising contractual clauses and documentary supervision protocols.

Because liability may arise from both internal conduct and certain third-party actions within the value chain, risk management efforts must extend beyond the company’s immediate operations.

Entry into force

The Law will enter into force one year after its publication and will apply to new extraction requests submitted from that date onward.

This legislative development further evidences the continued expansion of the economic crimes regime and the importance of maintaining dynamically updated compliance frameworks.