How Guatemala is preparing for the Gafilat Mutual Evaluation with the new anti-money laundering law

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How Guatemala is preparing for the Gafilat Mutual Evaluation with the new anti-money laundering law

With the approval by the Congress of the Republic of initiative 6593, Comprehensive Law against Money Laundering or Other Assets and the Financing of Terrorism, which is now law, Guatemala modernized the legal framework to prevent and combat money laundering and the financing of terrorism (MLFT).

Guatemala is part of the International Financial Action Task Force (Gafi) and the Latin American Financial Action Task Force (Gafilat), and will be subjected to the fifth round of Mutual Evaluation starting in February 2027. The process will be developed in different phases until the presentation of the results, scheduled for August 2028, by a specialized group.

The Mutual Evaluation consists of a review of the country’s system to prevent and combat money laundering and the financing of terrorism (MLFT). The country receives a rating that determines whether its anti-money laundering and countering the financing of terrorism (AML/CFT) system is effective. Additionally, the process provides recommendations to correct identified deficiencies and strengthen the system.

The approval of the law by the Congress of the Republic coincides with the visit of a mission from the International Monetary Fund (IMF) to review Article IV, an annual review that evaluates the country’s economic situation.

Guatemala prepares anti-money laundering evaluation

In general terms, the law unifies in a single text the framework to prevent and combat money laundering and the financing of terrorism (MLFT), with international compliance standards, identification mechanisms and linkage with the global network.

In February 2027 – an election year in Guatemala – the Latin American Financial Action Group (Gafilat) will carry out the Mutual Evaluation, which includes the review of technical compliance and the evaluation of the effectiveness of the system.

Technical compliance, which is part of the legal and institutional framework, includes the requirements of the recommendations of the Financial Action Task Force (FATF), as well as the powers and procedures of the institutions involved.

Another component is that the country receives a rating that allows determining whether the anti-money laundering and counter-financing of terrorism (AML/CFT) system is effective.

In addition, it provides recommendations to correct the deficiencies detected and strengthen the system.

The effectiveness assessment identifies the extent to which a country achieves the key outcomes for a robust AML/CFT system.

Structural elements include political stability; high-level commitment to address AML/CFT-related issues, and the existence of stable institutions, with accountability, integrity and transparency.

Five experts will evaluate the country

Various actors participate in the Mutual Evaluation process. Guatemala will be evaluated both at the level of public and private institutions.

The evaluation team is made up of five certified experts, designated by the member countries of the Latin American Financial Action Group (Gafilat). In addition, an observer responsible for monitoring the process participates.

The specialists are distributed in the following areas:

  • legal expert
  • financial expert
  • Supervision expert
  • Research expert
  • AML/CFT risk expert

The quality and consistency reviewers of the Mutual Evaluation are also appointed by the Gafilat member countries.

The process also includes a preparatory phase prior to the start of the evaluation.

Anti-money laundering exam will conclude in 2028

Currently, Guatemala is in the preparatory phase of the Mutual Evaluation, which covers from June 2025 to December 2026, a period of 18 months.

The pre-evaluation visit will begin in February 2027, when a high-level mission from the Latin American Financial Action Task Force (Gafilat) is expected to arrive.

During the following months, the technical compliance questionnaire and the effectiveness questionnaire of the anti-money laundering and countering the financing of terrorism (AML/CFT) system will be completed.

An on-site visit by the evaluation team will take place in November 2027.

During the Gafilat plenary session of July 2028 and the Mutual Evaluation Report (IEM), which will be held in Argentina, the reports will be reviewed and the results will be presented to the plenary session of the organization.

In August 2028, the Financial Action Task Force (FATF) will carry out the final review and the endorsed qualifications will be known.

That same month, Gafi and Gafilat will publish the results corresponding to Guatemala.

Results will activate continuous monitoring

Following the results of the Mutual Evaluation Report (IEM), a monitoring process and a roadmap are established to strengthen compliance with international standards.

Regular monitoring: Applies to countries with high levels of compliance with the recommendations of the Financial Action Task Force (FATF). In these cases, the country presents a report on its progress three years after the adoption of the MER.

Intensified monitoring: Applies to countries with significant deficiencies in compliance with FATF standards and requiring significant improvements. In this case, the country must present a mandatory report on the progress of the roadmap to the Latin American Financial Action Group (Gafilat) three years after the adoption of the IEM.

FATF Gray List: Includes countries with strategic deficiencies in compliance with FATF standards. These must present mandatory reports every four months on the progress of the action plan designed to correct the deficiencies detected.

New law reinforces anti-money laundering system

With the modernization of laws to prevent and combat money laundering and the financing of terrorism (MLFT), Guatemala registers significant progress that will be considered in the next Mutual Evaluation:

  • Addresses the deficiencies noted in the 2016 Mutual Evaluation Report.
  • Incorporates new requirements of the standards of the Financial Action Task Force (FATF).
  • Updates the legal framework in accordance with international standards and treaties.
  • It demonstrates the country’s high-level commitment and strengthens the confidence of international partners.

With information from the Special Verification Intendancy (IVE) and the Superintendence of Banks (SIB).

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