Business AML consulting · Guatemala
Decree 15-2026 takes effect on September 17, 2026. Before buying generic manuals or adopting standard controls, a company should determine whether its actual activities make it an Obligated Person and how the new Law may affect its business relationships.
— The first question
Decree 15-2026 reorganizes Guatemala's framework for preventing money laundering and terrorist financing, strengthens the risk-based approach and brings additional activities into the preventive system.
Coverage does not depend only on a trade name, professional title or legal form. The analysis must consider the activity actually performed, how it is delivered, which transactions are carried out and whether the person acts on their own behalf or for third parties.
An incorrect conclusion can lead to either of two costly outcomes: failing to meet applicable obligations or imposing a structure that the Law does not require.
The correct starting point is an applicability and gap assessment based on the company's actual operations.
— Indirect impact
Selling to an Obligated Person does not automatically turn a supplier into an Obligated Person. The relationship may nevertheless create practical requirements affecting contracts, payments, financing and commercial continuity.
Banks and other Obligated Persons must identify their customer, verify who acts on its behalf, identify beneficial owners, understand the relationship and assign a risk level. If they cannot complete the review, they may have to decline or terminate the relationship.
An Obligated Person may require corporate information, beneficial-ownership details, declarations, compliance clauses and evidence concerning particular transactions as a commercial condition. These requests do not by themselves change the supplier's legal category, but they may determine whether it keeps the customer or closes the transaction.
Is your company prepared to provide the information that its banks, customers, investors and counterparties may begin to require?
— Executive review
Does the company's actual activity fall within a category of Obligated Person?
Does it adequately identify its customers, counterparties and beneficial owners?
Does it have documented criteria for classifying risk and detecting warning signs?
Do its policies, files and assigned responsibilities reflect how the business really operates?
Can it explain to an authority, bank, auditor or business partner why it accepted a relationship or transaction?
— Readiness path
A professional assessment helps define a scope proportionate to the risk and the activity. The engagement may include:
Determining whether the company is an Obligated Person and assessing its existing controls.
Risk matrices, customer and third-party due diligence, beneficial ownership and Politically Exposed Persons.
Designing or updating manuals, forms, responsibilities, controls and escalation mechanisms.
Training, work plans, decision records and periodic review.
— Business-minded consulting
Ronaldo Estrada Rivera is an economist, MBA and FIBA-certified AMLCA professional. His work combines economic analysis, business experience, due diligence and risk management to help organizations understand what applies to them and translate it into a viable implementation path.
— Next step
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Information updated on September 12, 2026. This content is informational and does not determine whether a specific person or company qualifies as an Obligated Person. The advertised consulting concerns corporate AML compliance and risk management. Any legal or notarial service that may become necessary must be defined and engaged under a separate scope.