Guatemala approved Decree 15-2026 on 2 June 2026, replacing its older anti-money laundering and terrorist financing framework with a single modern regime. The law was approved by Congress with 147 votes and enters into force three months after publication in the Official Gazette.
A unified AML and counter-terrorist financing law
Decree 15-2026 replaces two older statutes:
- The anti-money laundering law of 2001
- The terrorist financing law of 2005
The new framework covers:
- Money laundering
- Terrorist financing
- Financing of the proliferation of weapons of mass destruction
The law is drafted around the Financial Action Task Force’s 40 Recommendations and is intended to remove duplicated processes, inconsistent obligations, and unnecessary compliance costs created by the previous two-law structure.
The reform also amends other legislation, including the Commercial Code, organised crime legislation, and the Notarial Code. Companies will be required to keep current records of shareholders and ultimate beneficial owners.
Who is brought into the AML perimeter
The law expands the categories of regulated persons and businesses.
Virtual asset service providers
Crypto exchanges, custodians, and related businesses operating in or from Guatemala are brought into the AML framework for the first time.
This aligns with FATF Recommendation 15 and means virtual asset service providers will need formal compliance functions.
Notaries
Notaries are also brought inside the regime. In Guatemala’s civil law system, notaries are involved in many significant transactions, including:
- Property transfers
- Company formations
- Powers of attorney
Notarial transactions are likely to involve more identity checks, source-of-funds explanations, and supporting documentation.
High-value trades and gatekeepers
The reporting obligation also extends to dealers in high-value assets, including:
- Real estate
- Vehicles
- Jewellery
- Works of art
- Similar goods
Other designated non-financial businesses and professions are also included.
New compliance duties
Entities covered by the law must follow a modern compliance framework, including:
- A risk-based approach
- Customer due diligence duties
- Suspicious transaction reporting
- Information retention requirements
- Compliance with requests from competent authorities
The law also requires immediate compliance with United Nations targeted financial sanctions. Designations must be translated into freezes without delay.
Fines can reach up to USD 300,000. Sanctions screening becomes a legal obligation, with response times measured in hours rather than ordinary review cycles.
Why Guatemala changed the law
The reform comes ahead of Guatemala’s evaluation by GAFILAT, the FATF-style regional body for Latin America.
A country operating under a 2001 AML statute while being assessed against current FATF standards risked an adverse report, possible grey-listing pressure, and damage to correspondent banking relationships.
The law is therefore both a financial crime reform and an attempt to preserve Guatemala’s access to international banking and dollar clearing.
Practical implications for private clients and businesses
Anyone with Guatemalan property, companies, banking relationships, or digital asset exposure should expect more documentation and screening once the law takes effect.
Transactions may slow during the early implementation period as newly regulated notaries and dealers over-comply. Source-of-funds documentation should be prepared before it is requested.
Guatemalan companies should update and verify shareholder and beneficial ownership records. Structures involving undocumented nominees, outdated registers, or records that do not match reality should be regularised during the three-month runway.
Digital asset arrangements also need review. Users of Guatemalan virtual asset service providers should expect onboarding refreshes, travel-rule information demands, and possible exits by providers unwilling to carry the new compliance cost.
Sanctions screening will become stricter. Clients with complex ownership chains should check for possible false positives, because under the new regime a freeze may happen before questions are resolved.
Guatemala’s reform reflects a broader international trend: the AML perimeter is expanding to cover crypto, notaries, property, art, and other stores of value that previously sat outside or near the edge of formal financial regulation. Clean, documented, and well-structured wealth should be easier to explain; undocumented or improvised arrangements are more likely to face problems under the new regime.
Source article: knightsbridge.ae
