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Combating Money Laundering: Towards a New Culture of Compliance

With the globalization of business, technological innovations that facilitate the movement of capital, and the increasing sophistication of criminal methods used to conceal illicit proceeds, the fight against money laundering has become increasingly complex. In Guatemala’s case, a culture focused on formal compliance and a legal framework that is more than 24 years old —and has been criticized for its weaknesses— seem insufficient to address such a challenging landscape.

In early 2027, representatives of the Financial Action Task Force (FATF) [1] are expected to visit Guatemala to assess the country's progress in combating money laundering and terrorist financing. This review will determine whether the country will be included on a "gray list" of nations that have deficiencies in their measures to combat these threats.

The International Monetary Fund (IMF), in its recent Article IV assessment report [2], recommended, among other things, prioritizing the revision of the Law on Banks and Financial Groups and completing the transition to International Financial Reporting Standards. It also emphasized the critical need to adopt new laws, including a renewal of the Law against Money Laundering and Terrorist Financing.

On August 28, 2025, the Executive Branch presented Initiative 6593 the Comprehensive Law against Money Laundering and Other Assets and the Financing of Terrorism in Guatemala, which is awaiting the respective rulings of the Finance and Economy Committees in Congress to continue its legislative process.

Although 2027 seems far away, the new legislation against Money Laundering and Other Assets and the Financing of Terrorism should be approved before the end of 2025. Thus, during 2026, its effective application can be demonstrated.  

Paradigm Shift

Until now, most of the efforts to prevent money laundering in Guatemala have focused on formal compliance: filling out forms, submitting periodic reports, and complying with the instructions of the financial intelligence unit of the Special Verification Intendance (IVE).

However, international experience and FATF recommendations have shown that the true value of these standards happens when there is a culture of prevention within organizations. 

One of the highlights of the initiative is that compliance would no longer be purely technical and reserved for banks and financial institutions that are commonly required to comply. On the one hand, the number of entities required to comply would be expanded, meaning that important players that are not currently regulated would be required to implement internal protocols for identifying, monitoring, and reporting suspicious transactions.

On the other hand, the initiative proposes a paradigm shift that seeks to align the country with the most demanding international standards and strengthen the reputation of its financial and business system. This would result in a cultural change where companies, professionals, and organizations would no longer view compliance as an administrative burden, but rather as a strategic tool for reputational and legal protection. 

In short, compliance should not be an end in itself, but a means to ensure business integrity and transparency in the economic system. In a world where financial and commercial transactions are increasingly global, the reputation of a company or country can be a decisive positive or negative factor. 

The Importance of a Solid Economic System

Updating criminal offenses, including new regulated entities, and implementing legal reforms are essential to align with the 40 recommendations of the FATF. This will help avoid sanctions, restrictions in the international banking system, or the inclusion of Guatemala on lists of non-cooperative countries. 

But beyond that, adopting legislation of this magnitude should be seen as a responsibility and commitment, as well as an opportunity to improve the confidence of investors and business partners. Embracing a new culture of compliance based on prevention, transparency, and business ethics will help any organization greatly avoid criminal investigations, administrative sanctions, and irreparable damage to credibility.

[1] https://www.imf.org/en/News/Articles/2025/09/05/pr-25289-guatemala-imf-executive-board-concludes-2025-article-iv-consultation

https://biblioteca.gafilat.org/wp-content/uploads/2024/10/Tercer-informe-de-seguimiento-intensificado-de-Guatemala.pdf

[2] https://www.imf.org/en/News/Articles/2025/09/05/pr-25289-guatemala-imf-executive-board-concludes-2025-article-iv-consultation 

Published on October 10, 2025

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