Guatemala's adherence to international AML/CFT standards: Guatemala is a member of the Financial Action Task Force of Latin America (GAFILAT), a FATF-style regional body, and is therefore expected to implement FATF recommendations. FATF Recommendation 15 explicitly applies AML/CFT obligations, including sanctions compliance, to VASPs.

Global financial interconnectedness: Transactions involving cryptocurrencies often touch upon jurisdictions or financial institutions that are directly subject to OFAC, EU, or UN sanctions. Non-compliance can lead to loss of correspondent banking relationships, secondary sanctions, and reputational damage.

Nature of the regulated entities: If a VASP is part of a larger financial group or relies on traditional financial institutions for fiat on/off-ramps, those institutions' compliance obligations will extend to the VASP.

U.S. persons (citizens, residents, entities incorporated in the U.S. or its territories).

Any transaction routed through the U.S. financial system, even if the parties are non-U.S.

Entities dealing in U.S. dollars.

Non-U.S. entities that facilitate significant transactions for or on behalf of sanctioned persons, or engage in activities that could trigger secondary sanctions.

Sanctioned Entity Screening: VASPs must screen all customers (KYC/CDD) and counterparties against OFAC's Specially Designated Nationals (SDN) and Blocked Persons List, the Consolidated Sanctions List (CSL), and other relevant lists (e.g., Non-SDN Palestinian Legislative Council List, Sectoral Sanctions Identifications List, etc.).

Prohibition on Transactions: VASPs are prohibited from engaging in any transactions involving property or interests in property of individuals or entities on OFAC's lists, or those associated with comprehensively sanctioned jurisdictions (e.g., Cuba, Iran, North Korea, Syria).

Geographic Restrictions: Strict prohibitions apply to transactions involving comprehensively sanctioned countries or regions.

Reporting Obligations: U.S. persons, and in some cases non-U.S. persons, have reporting obligations for blocked property.

OFAC Sanctions Programs and Information: https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-information

OFAC FAQs on Virtual Currency: https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/1601

EU nationals and entities incorporated or constituted under the law of an EU Member State.

Operations within the territory of the EU.

Aircraft and vessels under the jurisdiction of an EU Member State.

Asset Freeze and Travel Ban: Prohibition on making funds or economic resources available, directly or indirectly, to designated persons/entities.

Specific Sectoral Sanctions: Adherence to prohibitions related to specific sectors (e.g., arms embargoes, financial restrictions on certain entities).

Geographic Restrictions: Compliance with sanctions against specific countries or regimes.

Consolidated Financial Sanctions List (EU): https://data.europa.eu/data/datasets/consolidated-list-of-persons-groups-and-entities-subject-to-eu-financial-sanctions?locale=en

Sanctioned Entity Screening: Screening against the UN Security Council Consolidated List, which includes individuals and entities subject to asset freezes, travel bans, and arms embargoes.

Immediate Implementation: Member States are expected to implement UN sanctions without delay.

UN Security Council Sanctions Committees: https://www.un.org/securitycouncil/sanctions/information

UN Security Council Consolidated List: https://www.un.org/securitycouncil/content/un-sc-consolidated-list

The Bank of Guatemala (Banco de Guatemala) is the central bank and primary financial regulator, but it has not issued any regulation, circular, or guidance specific to virtual assets, cryptocurrencies, or digital asset service providers as of the last available official publications. Bank of Guatemala (URL is official homepage; no crypto-specific page exists in the provided sources — this is an inference from the absence of any such citation in sources provided; see Key Gaps)

The Superintendency of Banks of Guatemala (Superintendencia de Bancos) oversees banking and financial institutions, but no text in the supplied sources indicates it has issued any virtual asset rules. Superintendencia de Bancos (URL is official homepage; no crypto-specific page exists in the provided sources — see Key Gaps)

The U.S. Congress introduced H.R. 7314, the "Guatemala Rule of Law Accountability Act," on December 13, 2018, requiring the U.S. President to impose asset-blocking sanctions and visa denials on individuals who undermined the rule of law in Guatemala; the bill was introduced but its passage status is not stated in the sources. Torres Introduces Guatemala Sanctions Legislation to Combat Corruption and Money Laundering | U.S. Congresswoman Norma Torres of California's 35th District

The U.S. Congress.gov record for H.R. 7314 (115th Congress, 2017-2018) shows the bill's full legislative history including cosponsors and text, but the sources do not indicate final passage into law. All Info - H.R.7314 - 115th Congress (2017-2018): Guatemala Rule of Law Accountability Act | Congress.gov | Library of Congress

The European Union, via the Council of the EU, has imposed restrictive measures (asset freezes and travel bans) on Guatemalan individuals and entities for undermining democracy and rule of law, acting under a sanctions regime distinct from any crypto-specific framework. Guatemala: Council sanctions five individuals for undermining democracy and the rule of law - Consilium

The Malta-based Sanctions Monitoring Board (SMB) lists a "Guatemala Regime" under EU and UN sanctions, confirming the existence of an active international sanctions framework targeting Guatemala. Guatemala Regime - SMB - Sanctions Monitoring Board

No licensing regime for virtual asset service providers (exchanges, custodians, brokers, or payment processors) exists in Guatemala under any law or regulation cited in the provided sources; therefore, no applications can be submitted and no license can be granted.

No entity has been licensed to operate a crypto exchange, custody service, or digital asset business in Guatemala, based on the sources provided — the count of licensed entities is effectively zero.

The only "licensing-adjacent" framework present in the sources is the U.S. H.R. 7314 sanctions bill, which would impose asset blocking and visa bans on individuals undermining rule of law, not a business licensing mechanism. Torres Introduces Guatemala Sanctions Legislation to Combat Corruption and Money Laundering | U.S. Congresswoman Norma Torres of California's 35th District

The EU sanctions regime targets individuals and entities for political corruption, not crypto businesses; there is no licensing pathway under that regime. Guatemala: Council sanctions three individuals and one entity for undermining democracy and the rule of law - Consilium

No AML/KYC obligations specific to virtual assets have been established in Guatemala by any regulator or law cited in the provided sources; no CDD, EDD, STR, record retention, beneficial ownership, or PEP screening rules for crypto businesses are documented in these sources.

The U.S. sanctions bill H.R. 7314 describes asset-blocking and visa-denial sanctions as a response to corruption and money laundering concerns in Guatemala, but it does not create any AML/KYC obligations for crypto firms. Torres Introduces Guatemala Sanctions Legislation to Combat Corruption and Money Laundering | U.S. Congresswoman Norma Torres of California's 35th District

The EU Council sanctions press releases reference "undermining democracy and the rule of law" as the basis for asset freezes and travel bans, but they do not impose any AML/KYC duties on financial institutions or crypto service providers in Guatemala. Guatemala: Council sanctions five individuals for undermining democracy and the rule of law - Consilium

The EU Council imposed restrictive measures (asset freeze and travel ban) on five individuals on February 2, 2024, for undermining democracy and the rule of law in Guatemala — these are sanctions-designation actions, not enforcement actions against crypto firms. Guatemala: Council sanctions five individuals for undermining democracy and the rule of law - Consilium

The EU Council imposed restrictive measures on three additional individuals and one entity on June 12, 2025, under the same Guatemala sanctions regime — again, no crypto-related entity or individual was sanctioned in the provided text. Guatemala: Council sanctions three individuals and one entity for undermining democracy and the rule of law - Consilium

No enforcement action — fine, penalty, arrest, or cease-and-desist — against any crypto or virtual asset business in Guatemala appears in any of the provided sources.

The U.S. H.R. 7314 bill, if enacted, would require sanctions against individuals who "trampled the rule of law" in Guatemala, but it was only introduced in December 2018; no evidence of its enactment or subsequent enforcement appears in the sources. All Info - H.R.7314 - 115th Congress (2017-2018): Guatemala Rule of Law Accountability Act | Congress.gov | Library of Congress

A crypto business operating in Guatemala faces a high level of legal uncertainty: there is no license to obtain, no AML compliance standard to meet, and no tax treatment to follow, but this "freedom" carries the risk of regulatory action once — and if — legislation is eventually passed.

The EU sanctions regime is active and expanding (February 2024, June 2025, and January 2026 prolongation), meaning any Guatemalan-connected entity — including crypto firms — that is seen as undermining rule of law could be designated and subject to EU asset freezes. Guatemala: Council prolongs restrictive measures by a year - Consilium

The Malta Sanctions Monitoring Board listing confirms that Guatemala is under an active EU/UN sanctions regime, obligating EU-based crypto firms and financial institutions to screen against designated Guatemalan persons and entities. Guatemala Regime - SMB - Sanctions Monitoring Board

The U.S. Congress.gov record for H.R. 7314, if the bill was not passed, indicates a persistent but unfulfilled U.S. legislative effort to impose Guatemala-specific sanctions, creating potential future policy risk for Guatemalan entities and their international correspondent relationships. All Info - H.R.7314 - 115th Congress (2017-2018): Guatemala Rule of Law Accountability Act | Congress.gov | Library of Congress

Torres Introduces Guatemala Sanctions Legislation to Combat Corruption and Money Laundering | U.S. Congresswoman Norma Torres of California's 35th District

Guatemala Regime - SMB - Sanctions Monitoring Board

All Info - H.R.7314 - 115th Congress (2017-2018): Guatemala Rule of Law Accountability Act | Congress.gov | Library of Congress

Guatemala: Council sanctions three individuals and one entity for undermining democracy and the rule of law - Consilium

Guatemala: Council prolongs restrictive measures by a year - Consilium

Guatemala: Council sanctions five individuals for undermining democracy and the rule of law - Consilium