AAIP No Llame Enforcement for Outbound Teams

DNC LATAM · Compliance guides

Argentina's Do Not Call enforcement runs on consumer complaints, not a calendar audit of your whole program. Someone reports a call. The AAIP looks at whether that number was on the Registro Nacional No Llame at the time, and whether you can show a current consult or dated consent. Each call that fails can be its own infringement under Law 26.951.

This page is the high-level enforcement view for outbound ops. Narrative of a single complaint: how complaints become sanctions. Registry: Registro Nacional No Llame. Not legal advice.

Where a complaint starts

A consumer who registered with No Llame, or who never consented to marketing contact, can file with the enforcement authority. From the caller's side the first signal is rarely a warning about "your program." It is one number, one date, sometimes a short pattern of retries. US teams that wait for something that looks like an FTC sweep miss the window to have the file ready.

Mexico's PROFECO process is also complaint-shaped. Do not import a US "we will hear from the agency first" assumption into either market. PROFECO REPEP fines.

The two questions AAIP actually asks

  1. Was the number registered at the time of the call? Last quarter's download does not answer this. Continuous consumer registration means only a current check is responsive.
  2. If it was registered, do you have documented prior consent that overrides? A customer relationship slide is not the same as a dated, number-specific consent record.

A company that can produce a dated screening record plus the Scrub Result for that campaign, or a dated consent record, has an answer. A company that can only say "we scrub lists" does not. The screening record holds counts and metadata. It never lists phones. Keep it with the result you retained.

Why one call is one infringement

Law 26.951 treats each call to a registered number as a separate breach. A dialer that retries an unanswered line three times in a week is not automatically one problem. Repeat-offender escalation makes a pattern of complaints worse than a first file. The fine calculator uses a conservative editable default of USD $300 per violating call as a single-infringement baseline, not a stack across retries or recidivism. We do not publish official peso amounts.

Published enforcement decisions have involved banks, insurers, and call centers. That is a sector signal, not a closed list of who can be sanctioned.

What foreign teams get wrong

  • Treating AAIP registration as a one-time onboarding task, then dialing for months on the first file.
  • Assuming a CUIT they do not have is "someone else's problem" while still placing +54 marketing calls.
  • Mixing Argentina into a US DNC vendor output. The FTC file cannot see the number.
  • Keeping the only proof in one ops inbox that gets cleaned every quarter.

Access barrier: company-user registration. Vendor gap: DNC scrubbing vs US TCPA.

Be ready before the complaint exists

Two controls, every campaign:

  1. Current No Llame check on the actual call date window.
  2. A dated record tied to that batch, retrievable on request.

DNC LATAM maintains AAIP access and attaches the screening record to every operational check. Send country: "ar" or upload CSV. From $500/month at 10,000 checks. Independent SKU. Annual billing charges ten months for twelve. Privacy posture: zero-retention DNC scrubbing.

Questions, answered

How does AAIP enforce No Llame? +

Enforcement is complaint-driven. A consumer reports an unwanted call. AAIP checks whether the number was registered and whether the caller can produce a record of a current registry consult or dated consent. Each failing call can be its own infringement under Law 26.951.

Is there a routine audit cycle? +

Not in the way US teams picture a scheduled inspection of the whole program. The trigger is a specific person reporting a specific call. You need to be ready before the complaint exists.

Why do dated checks matter? +

The relevant registry state is whatever was current on the call date. A file from last quarter does not answer that question. The screening record names the check context and counts. Keep the Scrub Result separately.

What fine figure should we use? +

We do not publish an official peso table. Sanctions escalate for repeat offenders. The fine calculator uses an editable conservative default of USD $300 per violating call. Actual amounts depend on the file. Not legal advice.

When should we buy DNC LATAM for Argentina? +

When you need a current AAIP check and a dated screening record on every campaign, and you cannot hold a CUIT company-user account. From $500/month at 10,000 checks.