🇬🇹 Guatemala · IVE · Decree 15-2026
AML in Guatemala: Decree 15-2026 changes who is covered
Guatemala has replaced the anti-money-laundering framework that governed for twenty-five years. Decree 15-2026, in force since 17 September 2026, repeals the 2001 and 2005 laws, merges them into a single statute and adds as obligated persons virtual asset service providers, university-trained professionals who provide legal, economic, accounting or audit services, and notaries. COX gives you the structure to comply from your first client: due diligence files, restrictive list screening, a risk matrix, and the audit trail you need when the Special Verification Intendancy asks.
Regulatory framework of reference
- Decree 15-2026: in force since 17 September 2026; repeals Decrees 67-2001 and 58-2005 and merges the framework into a single statute
- Special Verification Intendancy (IVE): holds the register of obligated persons and receives the Suspicious Transaction Report (RTS)
- CONCLAFT: National Coordination Council against money laundering, terrorist financing and proliferation financing, chaired by the Vice President of the Republic, with the IVE as its technical secretariat
- Superintendency of Banks: supervises the obligated persons and may add activities to the regime, with an IVE report and CONCLAFT approval
- Implementing regulation: to be prepared by the Superintendency of Banks, through the IVE, by 17 March 2027; it will set thresholds and the RTS deadlines
- GAFILAT: fourth-round mutual evaluation of Guatemala dated November 2016; the fifth round is in preparation
What Decree 15-2026 changes
One statute
The new law brings the prevention and punishment of money laundering and of terrorist financing into a single text, replacing two separate decrees, each with its own regulation.
New obligated persons
Virtual asset service providers, university-trained professionals with no employment relationship with the client, and notaries come in. They are the only new ones: the rest of the list in Article 3 was already in the previous framework.
A special regime for professionals and notaries
University-trained professionals and notaries have a regime of their own: they register with the IVE, keep a record per client and notify the IVE, 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.
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.
Beneficial owner from 15%
The law sets the threshold: the beneficial owner is 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 for one year after office
A politically exposed person is one from taking office until one year after leaving it. The enhanced measures reach their first-degree blood relatives, their spouse or partner and their close associates.
Risk-based approach
Each obligated person identifies, assesses and mitigates its risk with its own methodology, approved by its senior governing body, covering at least its clients, geographic location, distribution channels and products or services.
CONCLAFT
A National Coordination Council against money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction is created. It is chaired by the Vice President of the Republic, and the IVE is its technical secretariat.
Companies: directors and shareholders
Existing commercial companies register every member of their board with the Commercial Registry within six months of the law taking effect, and companies with shares notify the Commercial Registry of every share registration and transfer within ten business days.
Is your activity covered?
Article 3 of the law reaches, among others:
- University-trained professionals in legal, economic, accounting and audit services who prepare or carry out transactions for a client
- Notaries, when they authorise deeds on those transactions
- Real estate development, brokerage and sales
- Trade in land, sea or air vehicles
- Cash trade in art, antiques, jewellery, precious stones or metals
- Company services: formation, acting as shareholder, director, attorney or trustee for others, or providing an address
- Lotteries, raffles, bingo and similar games
- Virtual asset service providers
- Armouring and trade in armoured goods
- Pawnshops, currency exchange, lending, factoring, financial leasing and savings and credit cooperatives
- Independent brokerage of life insurance that accumulates value for the insured and of surety insurance
If your firm incorporates companies, handles client funds or takes part in property transfers, you are very likely in scope. The Superintendency of Banks may also add activities, with an IVE report and CONCLAFT approval.
Your duties as an obligated person
Registration with the IVE
Register online in the IVE's Obligated Persons Registration System, with the documents for your type of person, and keep your details current. If the IVE raises an objection, you have thirty calendar days to answer it or the application is closed.
Compliance officer
Companies and cooperatives appoint, through their senior governing body, a principal compliance officer and a deputy, who is their only link with the Superintendency of Banks through the IVE. Individuals may perform the role themselves, on the terms the regulation sets, and university-trained professionals are not required to have one.
Prevention manual
Set out in a manual approved by the senior governing body the due diligence policies, the monitoring and detection of unusual and suspicious transactions, staff screening standards and an ongoing training plan.
Know your client and beneficial owner
Identify and verify the client and its beneficial owner when the relationship begins. Only in justified cases foreseen in the manual may verification be completed later, within three months at most. High-risk clients are reviewed at least once a year.
Restrictive list screening
Screen clients and prospects on a permanent basis against the United Nations Security Council lists. On a match, preventively restrict the use of the funds or assets and notify the Public Prosecutor's Office in writing within twenty-four hours at most.
Reporting to the IVE
Report suspicious transactions to the IVE through the compliance officer, in the Suspicious Transaction Report (RTS), whose procedures and deadlines the regulation will set. Record every cash transaction, single or structured, of ten thousand dollars or more, or its equivalent, on a daily basis and report it periodically to the IVE.
Record keeping
Keep records and due diligence documentation for five years after the transaction or the relationship ends, so that any operation can be reconstructed. Financial entities also keep them for ten more years in digital form.
Effectiveness review
Assess every year the compliance and effectiveness of the programme, through internal audit or specialised auditors, to show that it works, not merely that it exists on paper.
How COX solves it
Digital due diligence file
Every client has a living file with identification, documents, assigned risk and a record of who did what, and when.
Restrictive list screening
Screening against sanctions, PEP and adverse media at onboarding and on a recurring basis afterwards, with evidence of every check.
Politically exposed person detection
Identification of PEPs, their family members and close associates, with the enhanced due diligence workflow that follows.
Risk matrix
Automatic classification by client, activity, geography and channel, with the methodology documented so you can defend it to a supervisor.
Digital onboarding
Clients complete their form and upload documents from their phone. You receive a finished file, not an email with loose attachments.
Alerts and monitoring
Signals when a transaction falls outside a client's profile, or when a counterparty appears on a list after being accepted.
Audit trail for the IVE
An immutable record of every decision, with date, owner and supporting evidence. That is what turns a review into a routine matter instead of a crisis.
Training records
Track who was trained, when, and on what, with a downloadable record.
Why COX
Live in days
No installation, no months-long project. The law has been in force since 17 September 2026; your system can be ready in days.
Built for small firms and practices
Not a banking platform in disguise. Built for the volume and budget of a professional practice or a real estate agency.
Pay as you go
No forced monthly fee. You pay for the clients you screen.
data encryption · immutable audit log · role-based access · cloud hosting
Start before you have to explain it
The law has been in force since 17 September 2026. The Superintendency of Banks has until 17 March 2027 to prepare the implementing regulation, which will set thresholds and RTS deadlines, but the duties begin with the law.
Frequently asked questions
Guides on this topic:
Due diligence and KYC What a compliance officer does Decree 15-2026 of Guatemala explainedCOX also covers these countries:
Panama Mexico: PLD software Mexico: LFPIORPI Colombia Ecuador Dominican Republic Venezuela