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Category: International Bodies and Standards

Financial Action Task Force of Latin America

Also known as: GAFILAT, Grupo de Acción Financiera de Latinoamérica, Latin America Anti-Money Laundering Group
Simply put

GAFILAT is a regional organization that brings together 18 countries from South, Central, and Latin America to work together against money laundering and related financial crimes. It operates as a regional counterpart to the global Financial Action Task Force (FATF), helping member countries strengthen their defenses against illicit finance.

Formal definition

GAFILAT is an intergovernmental organization and a FATF-Style Regional Body (FSRB) comprising 18 member countries across South, Central, and Latin America. It was created to prevent and combat money laundering, the financing of terrorism, and the financing of the proliferation of weapons of mass destruction. As an FSRB, GAFILAT typically works to promote implementation of the FATF Recommendations within its region, including through mechanisms such as mutual evaluations of member countries. Note that the FATF Recommendations are international standards rather than directly binding law; the manner and extent of their implementation is a matter for each member jurisdiction's domestic legal framework, and specific obligations should be confirmed against applicable national legislation.

Why it matters

GAFILAT matters because the effectiveness of the global AML/CFT framework depends heavily on consistent implementation at the regional and national level, and the FATF cannot directly assess or engage every jurisdiction on its own. As a FATF-Style Regional Body (FSRB) covering 18 countries across South, Central, and Latin America, GAFILAT extends the reach of the FATF's work into a region with diverse legal systems, economies, and financial crime risk profiles. For compliance professionals, GAFILAT's mutual evaluations and regional guidance can shape how member states translate the FATF Recommendations into domestic law and supervisory expectations.

Because the FATF Recommendations are international standards rather than directly binding law, GAFILAT's role is largely one of promoting implementation, conducting peer review, and encouraging convergence rather than imposing obligations itself. This distinction is important: an obligation that a compliance officer must actually meet arises from the national legislation of the relevant member jurisdiction, not from GAFILAT membership as such. Understanding which body sets the standard, which body assesses adherence, and which instrument creates the legal duty helps professionals avoid conflating aspiration with enforceable requirement.

For institutions operating across Latin American markets, GAFILAT membership and the outcomes of its mutual evaluation process can serve as one input into country-level risk assessment, though such evaluations describe the state of a national framework at a point in time and are not, on their own, a measure of any individual customer's or transaction's risk. Exact obligations, thresholds, and enforcement mechanisms should always be confirmed against the applicable national legislation of the jurisdiction in question.

Who it's relevant to

Compliance officers at institutions operating in Latin America
Professionals responsible for AML/CFT programs in or across GAFILAT member countries can use mutual evaluation outcomes and regional context as one input into country risk assessment. They should, however, derive their actual obligations from the relevant national legislation rather than from GAFILAT standards directly, as implementation varies by jurisdiction.
Financial intelligence and risk analysts
Analysts assessing jurisdictional risk across South, Central, and Latin America may reference the state of a member country's AML/CFT framework as reflected in GAFILAT's evaluation process. Such assessments describe a framework at a point in time and are not, on their own, indicators of wrongdoing in any specific case or transaction.
Policy, regulatory, and government affairs teams
Those tracking how international standards translate into regional and national requirements benefit from understanding GAFILAT's role as an FSRB that promotes implementation of the FATF Recommendations. This helps distinguish standard-setting and peer-review functions from the domestic legislative processes that create binding obligations.
Legal and cross-border advisory professionals
Lawyers and advisers supporting clients with operations in the region should be attentive to the divergence between GAFILAT's regional promotion of standards and the specific, enforceable duties set out in each member jurisdiction's domestic law, confirming applicable requirements against national legislation.

Inside GAFILAT

FATF-Style Regional Body (FSRB)
GAFILAT (Grupo de Acción Financiera de Latinoamérica, or Financial Action Task Force of Latin America) is one of the FATF-Style Regional Bodies. As an FSRB, it promotes the implementation of the FATF Recommendations among its members rather than issuing its own binding legal standards. The FATF Recommendations remain international standards, not directly enforceable law, and take legal effect only when transposed into each member's national framework.
Regional Membership Scope
GAFILAT's membership is drawn primarily from Latin American jurisdictions. Its work applies to member and observer countries within that regional grouping; jurisdictions outside its membership fall under other FSRBs or under FATF directly. Exact current membership should be confirmed against GAFILAT's official records, as it may change over time.
Mutual Evaluation Function
GAFILAT conducts mutual evaluations (peer reviews) of its members' anti-money laundering and counter-terrorist financing regimes, assessing both technical compliance with the FATF Recommendations and the effectiveness of the measures in practice. These assessments identify deficiencies and inform follow-up processes but are typologically distinct from national supervisory examinations of individual obliged entities.
Typologies and Technical Assistance
GAFILAT generally supports regional typologies work and technical cooperation to help members strengthen AML/CFT frameworks. Such typologies illustrate observed methods of money laundering and terrorist financing within the region as a conceptual and analytical aid; they are not exhaustive lists and do not constitute legal tests or proof of criminality.
Coordination with FATF and the Global Network
GAFILAT operates within the broader FATF Global Network, coordinating with FATF and other FSRBs. It contributes regional perspective to the standard-setting dialogue but does not, on its own, set the international standards, which are the province of FATF.

Common questions

Answers to the questions practitioners most commonly ask about GAFILAT.

Is GAFILAT the same as the FATF, or a regional branch that issues its own binding laws?
No. GAFILAT (the Financial Action Task Force of Latin America, or Grupo de Acción Financiera de Latinoamérica) is a FATF-style regional body (FSRB), not a branch of the FATF and not a lawmaking authority. It promotes the implementation of the FATF Recommendations among its member jurisdictions, but the FATF Recommendations are international standards rather than binding law. GAFILAT itself does not enact legislation; obligations that apply to obliged entities arise from the domestic AML/CFT laws and regulations of each member country. Exact legal requirements should always be confirmed against the applicable national framework.
Does being a GAFILAT member mean a country has been assessed as fully compliant with AML/CFT standards?
No. Membership indicates a jurisdiction's commitment to implementing the FATF Recommendations and to participating in the mutual evaluation process; it is not a statement that the country is fully compliant. GAFILAT conducts mutual evaluations that assess both technical compliance and effectiveness, and outcomes typically vary across member jurisdictions and across individual Recommendations. A country's membership status should not be read as a rating of its overall AML/CFT performance, which should be assessed by reviewing its mutual evaluation reports and follow-up findings.
How can a compliance team use GAFILAT mutual evaluation reports in country risk assessments?
Mutual evaluation reports and their follow-up reports can serve as one input into geographic or country-risk assessments, offering insight into a jurisdiction's technical compliance and effectiveness across the FATF Recommendations. They are generally used alongside other sources rather than in isolation, and teams typically consider the report date, since findings can become dated as jurisdictions address deficiencies. These reports describe the state of a national framework and should not be treated as a definitive risk score for any particular customer or transaction.
Where do GAFILAT outputs actually create obligations for obliged entities?
GAFILAT itself does not impose direct obligations on obliged entities. Any obligations affecting your institution generally flow from the domestic AML/CFT legislation and regulatory guidance of the jurisdiction in which you operate, which may reflect that jurisdiction's efforts to implement the FATF Recommendations that GAFILAT promotes. When determining specific duties, compliance teams should look to the applicable national laws, supervisory authorities, and regulator guidance rather than to GAFILAT publications directly.
Should a firm monitor GAFILAT typologies work as part of its risk assessment process?
GAFILAT typologies and regional studies can be a useful reference for understanding money laundering and terrorist financing methods observed within the region, and firms may incorporate them into risk assessments, training, and the design of detection scenarios. Typologies are illustrative and should be treated as a conceptual aid, not an exhaustive list of methods or red flags; the presence of a described pattern does not by itself establish wrongdoing. They are best used in combination with a firm's own transaction data and broader intelligence sources.
How does GAFILAT's work relate to a group operating across multiple Latin American jurisdictions?
For groups operating across several member jurisdictions, GAFILAT's mutual evaluations and regional guidance can help contextualize differences between the AML/CFT frameworks of the countries in which the group operates. However, because each jurisdiction implements standards through its own laws and supervisory expectations, requirements may diverge across the group's footprint. Compliance functions generally still need to map obligations country by country and confirm specific requirements, thresholds, and reporting duties against each applicable national regime.

Common misconceptions

GAFILAT issues binding AML laws that member countries must directly follow.
GAFILAT is a FATF-Style Regional Body that promotes implementation of the FATF Recommendations, which are international standards rather than binding law. Legal obligations for obliged entities arise from each member state's national legislation and regulations, not from GAFILAT itself.
A GAFILAT mutual evaluation is the same as a supervisor examining an individual bank or firm.
A mutual evaluation is a peer assessment of a country's overall AML/CFT regime, covering technical compliance and effectiveness at the national level. It is distinct from the supervisory examinations that domestic authorities conduct on individual obliged entities, and it does not itself impose penalties on private firms.
GAFILAT and FATF are interchangeable, and GAFILAT sets its own separate global standards.
GAFILAT is a regional body operating within the FATF Global Network to support adoption of the FATF Recommendations across Latin American members. It does not set the international standards; that role belongs to FATF, and GAFILAT's remit is regional rather than global.

Best practices

Treat GAFILAT outputs as regional support for FATF standards, and always trace any specific obligation back to the applicable national legislation, as it is the domestic transposition that creates enforceable requirements for obliged entities.
Consult GAFILAT mutual evaluation reports and follow-up documents for the relevant jurisdiction to understand identified deficiencies and the effectiveness ratings, and factor these into country and jurisdiction risk assessments.
Confirm current GAFILAT membership and observer status against official GAFILAT sources before relying on it, since the composition of the regional body may change over time.
Use GAFILAT regional typologies as analytical inputs to inform risk indicators and scenario design, while recognizing that they are illustrative and non-exhaustive and do not establish criminality on their own.
Distinguish clearly in internal documentation between FATF standards, GAFILAT's regional promotion and evaluation role, and the specific national laws that impose duties, to avoid implying that a single global rule applies uniformly.
Where a mutual evaluation flags weaknesses in a member jurisdiction, apply commensurate risk-based measures for exposure to that jurisdiction, understanding that such measures mitigate rather than eliminate financial crime risk.