Decree 15-2026 in Guatemala: What the New Obligated Persons Must Do
Professionals, notaries and virtual asset providers entered the anti-money laundering regime on 17 September 2026. What the law asks of each one, and how to register with the IVE.
Decree 15-2026 is Guatemala's law against money laundering and terrorist financing, in force since 17 September 2026. It repealed Decrees 67-2001 and 58-2005 and added three kinds of obligated persons: virtual asset service providers, university-trained professionals and notaries. Professionals and notaries follow a special regime; every obligated person registers with the Special Verification Intendancy (IVE).
Eight Things the Law Says
In force since 17 September 2026
Published in the Diario de Centro América on 17 June 2026, it took effect three months later. It repeals Decrees 67-2001 and 58-2005.
Three new kinds of obligated persons
Virtual asset service providers, university-trained professionals with no employment relationship with the client, and notaries. The rest of the list was already in the previous framework.
A special regime for professionals and notaries
Registration with the IVE, a record per client and a notice to the IVE on an inconsistency or an unusual transaction. They keep their records like any other obligated person.
Professional secrecy is kept
A legal professional does not report what they obtain when verifying the client's legal position or in the exercise of the right of defence.
Beneficial owner from 15%
Whoever ultimately holds a stake of fifteen per cent or more, or exercises effective control by any other means, including through a chain of ownership.
PEP status lasts one year after office
The Superintendency of Banks had to issue the list of prominent public positions within thirty days of the law taking effect, and publishes it every January.
The regulation, by 17 March 2027
The Superintendency of Banks, through the IVE, has six months to prepare it. It will set the due diligence thresholds, the RTS deadlines and the sanctioning procedure.
Fines in dollars
A written warning or a fine from US$500 to US$300,000. If the breach was concealed from the IVE, double the fine or twenty per cent of the related transactions, whichever is higher.
Are You One of the New Obligated Persons?
| Who | When the law reaches them | Regime |
|---|---|---|
| University-trained professionals in legal, economic, accounting and audit services | With no employment relationship with the client, when they prepare or carry out for the client operations on real estate; the management of money, securities or assets; the opening or management of accounts; accounting and audit; contributions to create or run legal persons or structures; their creation or management; the custody of their books; or the purchase and sale of shares | Special: registration, record per client and notice to the IVE |
| Notaries public | When they authorise deeds on those same operations | Special: registration, record per client and notice to the IVE |
| Virtual asset service providers | When, as a regular business, they exchange virtual assets for legal tender or for one another, transfer them for third parties, hold them in custody or manage them, create or offer instruments based on them, or provide critical infrastructure or fiduciary management to operate with them for third parties | General: every duty of an obligated person |
The Superintendency of Banks may add activities to the list, with an IVE report and the approval of the national coordination council (CONCLAFT).
What the Special Regime Asks of Professionals and Notaries
- Register with the IVE as an obligated person.
- Keep a record per client. For an individual: name, place and date of birth, nationality, gender, marital status, profession, identity document, address and immigration status. For a legal person: type, company name, trade name, registration, tax identification, incorporation, tax address and legal representative. For both, the date and the service provided.
- Send the IVE a notice within the first fifteen business days of the following month when they detect an inconsistency between the client's information and the service provided, or an unusual transaction.
- Keep the records for five years, like every obligated person.
The IVE does not require a compliance officer from university-trained professionals. And the law keeps professional secrecy: a legal professional does not report what they obtain when verifying the client's legal position or when exercising the right of defence in judicial, administrative, arbitration or mediation matters.
What Every Other Obligated Person Must Do
A virtual asset provider, and every obligated person outside the special regime, carries the full set of duties:
- A compliance officer and a deputy, appointed by the senior governing body; the officer is the only link with the Superintendency of Banks through the IVE. An individual may take on the role
- A prevention manual approved by the senior governing body, and a risk methodology of its own
- Due diligence on the client and the beneficial owner at the start of the relationship, completed later only in justified cases and within three months; high-risk clients reviewed at least once a year
- Permanent screening against the United Nations Security Council lists: on a match, preventively restrict the funds and notify the Public Prosecutor's Office in writing within twenty-four hours
- The Suspicious Transaction Report (RTS) to the IVE, through the compliance officer
- A daily record of every cash transaction, single or structured, of US$10,000 or more, reported periodically to the IVE
- Records kept for five years after the transaction or the relationship ends
- A yearly evaluation of the programme, by internal audit or specialised auditors
How to Register with the IVE
Registration is online, in the IVE's Obligated Persons Registration System (portalpo.sib2.gob.gt). Whoever was already registered under the previous law does not register again, but updates their details; whoever had an application in progress had sixty days from 17 September 2026 to complete it.
- Create an account with your email address as the user, accept the terms of use and validate the email.
- Open a new file, individual or legal person: general data, the activities you carry out and the documents for your type of obligated person.
- Send the file. The owner or the legal representative confirms the application from the registered email; without that confirmation it is not processed.
- The IVE checks it. If it finds errors it raises an objection, and you have thirty calendar days to answer it or the application is closed and has to start again.
- Once admitted, the IVE emails the registration notice and the credentials for the Obligated Persons Portal.
Professionals and notaries
Current identity document (DPI) and a certificate of active membership of their professional association. No compliance officer is required.
Individuals
DPI, tax registration (RTU) updated this year, the business licence for the activity and a utility bill that confirms the address. They may act as their own compliance officer.
Companies
Deed of incorporation, business licences, RTU, legal representative's appointment and DPI, shareholder register and the identification of shareholders and directors. For every corporate shareholder with 15% or more, a chart of the ownership structure and the natural persons who control it. A principal compliance officer and a deputy, with their appointment minutes.
Savings and credit cooperatives
Registration with INACOP, the legal representative's and the board's appointments, DPI, RTU and a utility bill. A principal compliance officer and a deputy.
Deadlines to Keep in Mind
- A change of compliance officer is reported to the IVE within five days of the governing body learning of or approving it; the new officer takes office within sixty days, and the appointment is reported within ten days.
- Existing commercial companies register every member of their board with the Commercial Registry within six months of the law taking effect.
- Companies with shares notify the Commercial Registry of every share registration and transfer within ten business days.
- Policies, procedures and systems are adapted within the term the regulation sets.
Where the law or the IVE does not say whether a term is counted in business or calendar days, confirm it with the IVE before treating a date as certain.
The Record per Client, in COX
One file per client with the data the law lists, list and PEP screening with a certificate, a risk matrix and an immutable trail of every decision, so every notice to the IVE rests on evidence. The decision to notify stays with you.
COX for GuatemalaFrequently Asked Questions
This guide is for informational purposes only and does not constitute legal advice. It summarises Decree 15-2026 and the IVE's instructions of September 2026 without replacing them: confirm deadlines and requirements in the official text, with the IVE or with a Guatemalan adviser.
The Law Is Already in Force
The regulation will come later, but the duties began on 17 September 2026. Start with the record per client.
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