--- title: "Chile (CL) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/chile-cl/ source_html: /jurisdictions/chile/index.html description: "Financial integrity intelligence for Chile (CL): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T22:34:26Z content_sha256: fd611f689647303043f3375b819b9634276022177757f1079674ddaea2e5574d generator: "fe-fleet/md-twin@1.0" --- # Chile (CL) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Chile CL Domains covered 8 of 8 Sources 164 Role actions 8 Horizon <90d 1 Jurisdiction profile FATF status: Compliant Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed Chile's AML/CFT architecture rests on Ley 19.913 (2003, creates the Unidad de Análisis Financiero/UAF) and Ley 20.393 (2009, autonomous corporate criminal liability for money laundering, terrorist financing and bribery). More Chile is a GAFILAT member, last underwent its 4th-round FATF/GAFILAT mutual evaluation (on-site Jan 2020, report 2021), and is not currently on the FATF grey or black list. A 2025 UNCAC Cycle II review found continued gaps in international cooperation and integrity legislation. Key deficiencies - Bank secrecy rules described as among the strictest globally, which reportedly allowed a bank-insider laundering network to move funds undetected for years - Absence of a fully centralized, publicly accessible beneficial-ownership register comparable to EU/US standards - No dedicated international judicial-cooperation statute; cooperation relies on the Penal Code, Criminal Procedure Code and treaties/reciprocity - Foreign transnational criminal organizations (Tren de Aragua) demonstrated ability to penetrate formal banking sector via insider recruitment Recent developments (18m) - June 2026: arrest of a Banco Santander Chile employee among 18 suspects in an $85 million Tren de Aragua-linked money-laundering probe spanning nearly every major Chilean bank - June 2026: national debate reignited over reform of Chile's strict bank-secrecy rules following the Santander case - April 2026: disarticulation of a criminal network shipping an estimated $917 million in stolen copper to Peru and China, exposing trade-based laundering and environmental-crime nexus - December 2025: OFAC designated a Tren de Aragua-linked money-laundering network, including an individual based in Chile, under counter-terrorism/TCO authorities - May 2025: UNODC published Chile's UNCAC Cycle II country review report addressing corporate transparency, asset recovery and international cooperation gaps Brief ## Lead signal #### Lead Signal Chile's financial-integrity picture this cycle is defined by two parallel regulatory build-outs rather than a single headline event. The Comisión para el Mercado Financiero has clarified, via Official Letter 101082, that crypto-assets are treated as financial instruments for the purposes of Ley Fintec (Ley 21.521), and that a self-custody wallet where the provider does not control private keys does not constitute custody for regulatory purposes. This is a structural clarification of perimeter rather than an enforcement action: it tells crypto-asset service providers where the line between custodial and non-custodial activity sits, with direct consequences for which entities fall under the obliged-entity regime going forward. The finding is probable rather than confirmed, as it rests on secondary legal commentary describing the CMF letter rather than the letter's own text. Read full brief #### Lead Signal Chile's financial-integrity picture this cycle is defined by two parallel regulatory build-outs rather than a single headline event. The Comisión para el Mercado Financiero has clarified, via Official Letter 101082, that crypto-assets are treated as financial instruments for the purposes of Ley Fintec (Ley 21.521), and that a self-custody wallet where the provider does not control private keys does not constitute custody for regulatory purposes. This is a structural clarification of perimeter rather than an enforcement action: it tells crypto-asset service providers where the line between custodial and non-custodial activity sits, with direct consequences for which entities fall under the obliged-entity regime going forward. The finding is probable rather than confirmed, as it rests on secondary legal commentary describing the CMF letter rather than the letter's own text. Alongside this, the Unidad de Análisis Financiero has consolidated its AML/CFT/CPF instructions under Circular N°62, which sets five-year record-retention and annual staff-training duties and introduces a tiered administrative sanction ladder: minor infractions up to 800 UF, less-serious up to 3,000 UF, and serious up to 5,000 UF, each triplable on repetition. The circular also flags the automotive sector as a disproportionate laundering vector, citing a 73.9 percent share of 2019-2023 convictions. Taken together, the crypto-perimeter clarification and the AML consolidation point toward a regulator pairing that is actively defining scope and tightening consequence at the same time, rather than waiting for enforcement volume to force the question. #### Other Developments Judicial confirmation of an AML sanction came from the Corte de Apelaciones de Santiago, which upheld a UAF written-warning-plus-40-UF-fine sanction against a remittance firm for anti-money-laundering programme failures. The finding is uncertain in its particulars, since it rests on specialist legal-news reporting with an approximate ruling date rather than the court's own text, but the direction is clear: Chilean courts are not disturbing UAF sanctions on review, which is itself a signal about the durability of the regulator's enforcement architecture even where individual penalties are modest in absolute terms. The crypto-asset classification sits inside a wider pattern of CMF guidance progressively fleshing out the regulatory perimeter established by Ley Fintec, rather than a one-off event. No other sanctions, beneficial-ownership, enabler-jurisdiction, conflict-finance, compliance-technology or commercial-activity development specific to Chile met the bar for inclusion this cycle. #### Cross-Monitor Connections The crypto-asset classification finding connects directly to payments-side monitoring of Chile's stablecoin and open-finance agenda: the same Ley Fintec architecture that the CMF is now interpreting for custody purposes is the framework under which the Banco Central de Chile is separately developing stablecoin-issuance and open-finance rules, meaning any payments-side infrastructure development in Chile will increasingly have to be read against this CMF custody determination. The automotive-sector laundering flag in Circular N°62 is a commercial-activity-adjacent signal: a sector not typically treated as a financial-crime frontline being identified as carrying nearly three-quarters of recent laundering convictions is the kind of structural, architecture-level finding that merits attention beyond the AML pillar alone, including wherever automotive-sector financing or remittance flows intersect with trade or conflict-finance monitoring elsewhere. #### Outlook The near-term trajectory in Chile is incremental rather than disruptive. The CMF's crypto-asset classification is likely to be followed by further implementing guidance as providers adjust their custody arrangements to the self-custody carve-out, and the UAF's Circular N°62 sanction ladder will likely generate a visible enforcement record over coming cycles given the automotive-sector flag now sits on the regulator's own risk map. Judicial deference to UAF sanctions on review, as shown in the Santiago Court of Appeals decision, suggests that enforcement outcomes already in train are unlikely to be overturned, which in turn gives the UAF's tiered sanction architecture more practical weight than its modest individual fine amounts might suggest standing alone. As scheduled, Open Finance obligations under Ley Fintec remain in a pending in-force stage, with technical standards finalised and testing environments open but a prior postponement of general go-live still unresolved; this remains a structural item to watch rather than a settled fact. Earlier periodic briefs (5) 8 Nov 2026 · fim-2026-11-08 #### Lead Signal Chile's financial-integrity picture is defined by two parallel regulatory build-outs rather than a single headline event. The Comisión para el Mercado Financiero has clarified, via Official Letter 101082, that crypto-assets are treated as financial instruments for the purposes of Ley Fintec (Ley 21.521), and that a self-custody wallet where the provider does not control private keys does not constitute custody for regulatory purposes. This is a structural clarification of perimeter rather than an enforcement action: it tells crypto-asset service providers where the line between custodial and non-custodial activity sits, with direct consequences for which entities fall under the obliged-entity regime going forward. The finding is probable rather than confirmed, as it rests on secondary legal commentary describing the CMF letter rather than the letter's own text. Alongside this, the Unidad de Análisis Financiero has consolidated its AML/CFT/CPF instructions under Circular N°62, which sets five-year record-retention and annual staff-training duties and introduces a tiered administrative sanction ladder: minor infractions up to 800 UF, less-serious up to 3,000 UF, and serious up to 5,000 UF, each triplable on repetition. The circular also flags the automotive sector as a disproportionate laundering vector, citing a 73.9 percent share of 2019-2023 convictions. Taken together, the crypto-perimeter clarification and the AML consolidation point toward a regulator pairing that is actively defining scope and tightening consequence at the same time, rather than waiting for enforcement volume to force the question. #### Other Developments Judicial confirmation of an AML sanction came from the Corte de Apelaciones de Santiago, which upheld a UAF written-warning-plus-40-UF-fine sanction against a remittance firm for anti-money-laundering programme failures. The finding is uncertain in its particulars, since it rests on specialist legal-news reporting with an approximate ruling date rather than the court's own text, but the direction is clear: Chilean courts are not disturbing UAF sanctions on review, which is itself a signal about the durability of the regulator's enforcement architecture even where individual penalties are modest in absolute terms. The crypto-asset classification sits inside a wider pattern of CMF guidance progressively fleshing out the regulatory perimeter established by Ley Fintec, rather than a one-off event. No other sanctions, beneficial-ownership, enabler-jurisdiction, conflict-finance, compliance-technology or commercial-activity development specific to Chile met the bar for inclusion. #### Cross-Monitor Connections The crypto-asset classification finding connects directly to payments-side monitoring of Chile's stablecoin and open-finance agenda: the same Ley Fintec architecture that the CMF is now interpreting for custody purposes is the framework under which the Banco Central de Chile is separately developing stablecoin-issuance and open-finance rules, meaning any payments-side infrastructure development in Chile will increasingly have to be read against this CMF custody determination. The automotive-sector laundering flag in Circular N°62 is a commercial-activity-adjacent signal: a sector not typically treated as a financial-crime frontline being identified as carrying nearly three-quarters of recent laundering convictions is the kind of structural, architecture-level finding that merits attention beyond the AML pillar alone, including wherever automotive-sector financing or remittance flows intersect with trade or conflict-finance monitoring elsewhere. #### Outlook The near-term trajectory in Chile is incremental rather than disruptive. The CMF's crypto-asset classification is likely to be followed by further implementing guidance as providers adjust their custody arrangements to the self-custody carve-out, and the UAF's Circular N°62 sanction ladder will likely generate a visible enforcement record over coming cycles given the automotive-sector flag now sits on the regulator's own risk map. Judicial deference to UAF sanctions on review, as shown in the Santiago Court of Appeals decision, suggests that enforcement outcomes already in train are unlikely to be overturned, which in turn gives the UAF's tiered sanction architecture more practical weight than its modest individual fine amounts might suggest standing alone. As scheduled, Open Finance obligations under Ley Fintec remain in a pending in-force stage, with technical standards finalised and testing environments open but a prior postponement of general go-live still unresolved; this remains a structural item to watch rather than a settled fact. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Chile's financial-integrity picture is defined by an AML/CFT architecture upgrade that entered force on schedule. UAF/SCJ Joint Circular N63 came into effect on 1 October 2026, introducing a risk-based AML/CFT/counter-proliferation-financing approach for the country's 25 licensed casinos, replacing the 2014 joint circular. The new regime requires a mandatory Comite de Prevencion, a reinforced Compliance Officer function, customer due diligence differentiated by risk level, and updated suspicious-transaction analysis and reporting. This is a structural tightening of the gambling-sector AML perimeter, consistent with current FATF Recommendations, and it is confirmed by both the Unidad de Analisis Financiero's own circular register and corroborating trade-press reporting. #### Other Developments Crypto registration perimeter operating but incomplete. Chile's Ley Fintec framework has brought virtual-asset service providers within the CMF's registration and authorisation perimeter, imposing AML/KYC duties equivalent to those borne by other supervised financial entities. As of 6 October 2026, however, the country's two most prominent domestic exchanges, Buda.com and CryptoMKT, remained in the registration process, described as "en tramite," rather than fully authorised proveedores de servicios sobre activos virtuales. This is a supervisory-completion lag rather than a perimeter gap: the legal obligation to register and the AML/KYC duties attach regardless of completion status, but de facto supervisory oversight of the largest local platforms has not yet caught up with the de jure requirement. Mutual evaluation preparation continues without a confirmed date. The UAF participated in GAFILAT Fifth Round preparatory and strategic-commission sessions held in Honduras in late September 2026. An older UAF national strategy document points to a preliminary evaluation slot in 2031, but that figure was not reconfirmed and the Fifth Round methodology itself remains unpublished. Chile is not currently FATF grey-listed, and this activity reflects ordinary preparatory engagement rather than a status change. Adjacent commercial signal. Blanco Financiero, a Chilean digital factoring business, closed a US$5.2 million seed round led by Credicorp's Krealo venture arm. This sits outside the AML-analytical core of the findings but is noted as a commercial-activity data point touching the broader fintech-adjacent compliance-technology landscape. #### Cross-Monitor Connections The casino AML tightening under Circular N63 connects directly to gambling-sector findings tracked elsewhere: a regime that reinforces customer due diligence and suspicious-transaction reporting at licensed casinos reduces a historically significant money-laundering channel through cash-intensive gaming establishments, a structural improvement independent of any single enforcement action. The crypto registration lag at Buda.com and CryptoMKT is a direct point of overlap with digital-asset market-structure monitoring: a VASP that is legally obliged to register but has not completed authorisation sits in a supervisory grey zone that correspondent banks and payment processors assessing counterparty risk should treat as materially different from either a fully authorised or wholly unregistered platform. #### Outlook The near-term question for Chile's AML/CFT posture is less about the casino circular, which is now in force and operating, than about how quickly CMF supervisory completion catches up with the Ley Fintec registration perimeter for its largest domestic crypto exchanges. A second item to watch is whether the GAFILAT Fifth Round methodology is published and whether Chile's evaluation date is confirmed, since the 2031 figure currently in circulation traces to an unconfirmed planning document rather than a scheduled commitment. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Chile's financial-integrity picture this cycle is defined by an AML/CFT architecture upgrade that entered force on schedule. UAF/SCJ Joint Circular N63 came into effect on 1 October 2026, introducing a risk-based AML/CFT/counter-proliferation-financing approach for the country's 25 licensed casinos, replacing the 2014 joint circular. The new regime requires a mandatory Comite de Prevencion, a reinforced Compliance Officer function, customer due diligence differentiated by risk level, and updated suspicious-transaction analysis and reporting. This is a structural tightening of the gambling-sector AML perimeter, consistent with current FATF Recommendations, and it is confirmed by both the Unidad de Analisis Financiero's own circular register and corroborating trade-press reporting. #### Other Developments Crypto registration perimeter operating but incomplete. Chile's Ley Fintec framework has brought virtual-asset service providers within the CMF's registration and authorisation perimeter, imposing AML/KYC duties equivalent to those borne by other supervised financial entities. As of 6 October 2026, however, the country's two most prominent domestic exchanges, Buda.com and CryptoMKT, remained in the registration process, described as "en tramite," rather than fully authorised proveedores de servicios sobre activos virtuales. This is a supervisory-completion lag rather than a perimeter gap: the legal obligation to register and the AML/KYC duties attach regardless of completion status, but de facto supervisory oversight of the largest local platforms has not yet caught up with the de jure requirement. Mutual evaluation preparation continues without a confirmed date. The UAF participated in GAFILAT Fifth Round preparatory and strategic-commission sessions held in Honduras in late September 2026. An older UAF national strategy document points to a preliminary evaluation slot in 2031, but that figure was not reconfirmed this cycle and the Fifth Round methodology itself remains unpublished. Chile is not currently FATF grey-listed, and this activity reflects ordinary preparatory engagement rather than a status change. Adjacent commercial signal. Blanco Financiero, a Chilean digital factoring business, closed a US$5.2 million seed round led by Credicorp's Krealo venture arm. This sits outside the AML-analytical core of this cycle's findings but is noted as a commercial-activity data point touching the broader fintech-adjacent compliance-technology landscape. #### Cross-Monitor Connections The casino AML tightening under Circular N63 connects directly to gambling-sector findings tracked elsewhere: a regime that reinforces customer due diligence and suspicious-transaction reporting at licensed casinos reduces a historically significant money-laundering channel through cash-intensive gaming establishments, a structural improvement independent of any single enforcement action. The crypto registration lag at Buda.com and CryptoMKT is a direct point of overlap with digital-asset market-structure monitoring: a VASP that is legally obliged to register but has not completed authorisation sits in a supervisory grey zone that correspondent banks and payment processors assessing counterparty risk should treat as materially different from either a fully authorised or wholly unregistered platform. #### Outlook The near-term question for Chile's AML/CFT posture is less about the casino circular, which is now in force and operating, than about how quickly CMF supervisory completion catches up with the Ley Fintec registration perimeter for its largest domestic crypto exchanges. A second item to watch is whether the GAFILAT Fifth Round methodology is published and whether Chile's evaluation date is confirmed, since the 2031 figure currently in circulation traces to an unconfirmed planning document rather than a scheduled commitment. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Chiles Comision para el Mercado Financiero (CMF) issued a public alert on 6 September 2026 naming SUXXESS FX LTD and a platform impersonating Bakkt as unregistered and unauthorised to provide regulated financial services in Chile. The alert continues a pattern established in June 2026, when the CMF cancelled roughly twenty fintech registrations and applications, including that of Inversiones Plusservice SpA (Plusspay), a platform prosecutors have linked to a Tren de Aragua laundering network alleged to have moved more than USD 84 million through stablecoins. Read together, the two events describe a structural feature of Chiles Fintech Law (Ley N21.521) rather than an isolated incident: the CMF can cancel a registration once an entity is inside the Registro de Prestadores de Servicios Financieros (RPSF), but it has publicly acknowledged it has no supervisory or sanctioning power over a platform that was never registered or authorised in the first place. Its only tools against such platforms are public warning and referral to prosecutors. This registration-versus-authorisation gap is the single most consequential financial-integrity finding on Chile this cycle. It matters less as a story about any one platform than as a description of where enforcement capacity in Chiles licensing architecture actually stops, and where illicit finance has room to operate beneath that line. #### Other Developments The AML/CFT regime of record is unchanged. Chiles standing framework, Ley N19.913 (creating the Unidad de Analisis Financiero), as amended by Ley 20.818 and Ley 21.732, continues to govern obliged-entity suspicious-transaction-report duties and UN Security Council list-match and asset-freeze obligations under Article 38. The UAFs Circular N62 of 19 March 2026 consolidates AML/CFT/CPF supervisory instructions and remains the current baseline; nothing in this cycles research disturbs that baseline. Chile remains off the FATF increased-monitoring list. Following the 19 June 2026 plenary, which added Bosnia and Herzegovina and Iraq and removed Algeria and Namibia, Chile was not named. This is a standing confirmation rather than a new development, but it is the correct backdrop against which the registration-enforcement gap above should be read: Chile is not a jurisdiction under international grey-list pressure, so the gap persists despite, not because of, external scrutiny. Beneficial ownership transparency remains unresolved. Chile still has no centralised public beneficial-ownership register. GAFILATs 2021 Mutual Evaluation Report rated FATF Recommendation 24 as only Partially Compliant, and a bill introduced to Congress, administered by the Servicio de Impuestos Internos (SII), proposing a 10 percent ownership-disclosure threshold, has not been enacted. A separate, unrelated bill (Boletin 14.838-03), covering online betting platforms and approved in general terms by the Senate on 9 September 2026, would, if enacted, bring online-betting operators into the UAFs obliged-entity perimeter with beneficial-ownership and source-of-funds disclosure duties. Both are forward-looking signals rather than completed changes. #### Cross-Monitor Connections The registration-versus-authorisation gap underlying the Plusspay cancellation and the SUXXESS FX/Bakkt-impersonation alert sits squarely at the intersection of financial-integrity and digital-asset-market-access concerns: the same platforms that evade CMF licensing enforcement are, by construction, platforms operating in the crypto and digital-asset space, where stablecoin-denominated flows were central to the Tren de Aragua laundering allegations. The compliance-technology dimension of this gap, namely whether the CMF or the UAF has any automated or structural means of detecting unregistered platforms before volumes reach the scale alleged in Plusspay, is not addressed by any source reaching this cycles research and is logged as a gap rather than inferred. #### Outlook The near-term question is whether the CMFs pattern of ex-post registration cancellation and public alerting evolves into a mechanism with actual reach over never-registered platforms, a change that would require either new statutory authority or an enforcement-cooperation arrangement with prosecutors that goes beyond referral. As at the close of this cycle no such change has been identified. On beneficial ownership, the SII-administered register bill and the online-betting obliged-entity bill are both still in the legislative process; neither has passed, and their trajectory should be read as a policy intention, not an enacted change, until a later cycle confirms otherwise. 14 Sep 2026 · fim-2026-08-05 #### Lead Signal The most significant development this cycle is the US Treasury's designation of Bolai (Brilliancy Sihanoukville Investment and Development Co Ltd), its founder Luo Hong, and two supporting companies, for coercing trafficking victims into running digital-asset fraud schemes and laundering at least USD73 million in US victim funds through gambling-linked banking and crypto channels (High confidence). The designation lands alongside TRM Labs' 2026 Crypto Crime Report, which recorded approximately USD158 billion in illicit crypto flows in 2025, a 145 percent increase on 2024's USD64.5 billion and the highest level in five years (High confidence) — a metric the Bolai case illustrates directly rather than abstractly. Architecture, not incident, is the right frame here: Cambodia's casino and junket-linked infrastructure continues to function as a shadow-banking layer for scam-compound proceeds, and the pattern of external designation preceding domestic supervisory action recurs. The National Bank of Cambodia ordered liquidation and suspended operations at Prince Bank only after founder Chen Zhi's US fraud indictment tied to the Prince Group scam-center network became public (Assessed confidence, single Tier-4 source pending primary corroboration) — a reactive rather than anticipatory supervisory posture that is itself a structural signal about the enabler-jurisdiction environment. #### Other Developments Chile tightens formal-sector AML/CFT standards while a separate corporate-liability bill responds to allegations. The CMF's Circular No. 2,368 (2 February 2026) imposes materially higher AML/CFT and beneficial-ownership identification standards on banks and other supervised entities, including a designated senior AML/CFT compliance officer (Assessed confidence, secondary characterisation of a Tier-1 circular). Separately, Senators Esteban Velasquez and Alejandra Sepulveda filed a bill to toughen corporate-liability sanctions for firms whose grave negligence or weak controls facilitate money laundering, responding directly to bank-executive laundering allegations (Low confidence, single source, introduction stage only). Chile's Supreme Court separately upheld a UAF administrative sanction, a written admonition plus a 15 UF fine, against an entity for customer-due-diligence, PEP-identification and sanctions-list-monitoring failures, ruling the entity's claimed remediation untimely (Assessed confidence). Sanctions architecture continues to diverge across the three major regimes. The EU Council's 21st Russia sanctions package added 218 designations and, for the first time, targeted vessels that refuel Russia's shadow-fleet tankers at sea, holding the oil price cap at USD44.10 per barrel (Assessed confidence, Tier-4 commercial press only this cycle). The UK's OFSI designated 70 individuals and entities, including 27 vessels and a Nigeria-based facilitator supporting the A7 illicit financial network (Assessed confidence, Tier-4 only). Neither EU nor UK action this cycle was matched by new US OFAC vessel designations against Russia, continuing a stall dating to January 2025. FATF rebalanced its grey list at its final Mexico-chaired Plenary before transferring the Presidency to the UK. Bosnia and Herzegovina and Iraq were added, Algeria and Namibia were removed, holding the list at 22 jurisdictions under increased monitoring, with the blacklist of Iran, North Korea and Myanmar unchanged (High confidence, primary FATF publication). Giles Thompson (UK) succeeded Mexico's Elisa de Anda Madrazo as FATF President effective 1 July 2026, with Vivek Aggarwal (India) as Vice President (High confidence, primary US Treasury corroboration). A separate metric surfaced on trade-based laundering. FinCEN advisory material, characterised secondhand this cycle, attributes more than USD312 billion in trade-based money-laundering activity between 2020 and 2024 to Chinese networks and Mexican cartels (Assessed confidence, Tier-4 secondary characterisation pending primary retrieval). #### Cross-Monitor Connections The Cambodia findings sit squarely at the intersection of FIM's enabler-jurisdiction and crypto typologies and would be directly relevant to any monitor tracking trafficking-adjacent financial flows or state-linked protection of scam-compound infrastructure. The Russia sanctions-divergence pattern is a standing cross-reference for any monitor tracking conflict-adjacent commodity flows, given that shadow-fleet servicing infrastructure is now a first-order EU and UK target rather than a secondary one. Chile's parallel tightening of formal-sector AML/CFT standards is structurally distinct from, and this cycle unconnected to, the country's separate online-gambling tax-enforcement track, a distinction worth preserving rather than conflating across monitors. #### Outlook The FATF UK Presidency's strategic priorities are expected to become clearer over the coming quarter; continuity of monitoring intensity is the current working assumption pending the UK's stated agenda (Assessed confidence). In Chile, the pending Sistema de Inteligencia Economica contra el Delito (Boletin 15975-25) would grant the UAF and CMF administrative bank-secrecy-lift powers currently requiring judicial authorisation, a meaningful expansion of financial-intelligence reach if enacted, alongside updated illegal-gambling definitions coordinated with Chile's separate online-betting bill (Assessed confidence). The most consequential open question remains whether Cambodia's domestic supervisory posture shifts from reactive to anticipatory absent further external designation pressure, and whether US OFAC vessel-designation activity against Russia resumes to narrow the current three-regime enforcement gap. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion On 3 December 2025, OFAC designated multiple individuals and entities tied to a Tren de Aragua money-laundering network under Executive Order 13224, as amended, and its transnational-criminal-organization authorities. One designee, Cheison Royer Guerrero Palma, carries a recorded location of Chile. This is an individual-level action rather than a country-level sanctions program, but it demonstrates how a January 2025 authority, Executive Order 14157, which elevated cartels and transnational criminal organizations including Tren de Aragua to Foreign Terrorist Organization and Specially Designated Global Terrorist designation tier, now projects US secondary-sanctions risk into a jurisdiction that itself carries no OFAC, EU, or UK country-level designation. Continue reading Applying a three-level sanctions-architecture reading to this development produces a clearer picture than treating the designation as an isolated event. At the scheme level, the designation targets financial facilitators of a Tren de Aragua-linked laundering network with infrastructure operating from or through Chile. At the architecture level, open reporting describes front entities and banking access spanning at least Chile, Venezuela, and Colombia, meaning any single national law-enforcement response addresses only one node of a regionally distributed structure rather than the structure itself. At the level of strategic consequence, the elevation of cartel and transnational-criminal-organization designation to a terrorism-authority tier under Executive Order 14157, an authority the EU and the UK have not mirrored, creates a genuine and durable divergence in sanctions architecture across the Atlantic. Financial institutions transacting with Chile-based or Chile-resident counterparties now face a US secondary-sanctions exposure with no equivalent trigger under EU or UK regimes, a mismatch that a compliance program calibrated only to EU or UK list-screening would not detect. This divergence sits atop an otherwise unremarkable sanctions profile for Chile. The country carries no country-level OFAC, EU, or UK sanctions designation, is absent from the FATF grey and black lists as of the 19 June 2026 Plenary, and does not appear on the EU high-risk third-country list following the 4 December 2025 update under Delegated Regulation (EU) 2026/83, a list to which Bolivia and Venezuela were both added within the same review window. In comparative regional terms, Chile is the lower-friction jurisdiction. The analytical significance of this cycle is precisely that gap between comparative standing and Chile-specific exposure: the US cartel-as-terrorist-organization authority operates independently of, and in advance of, any broader multilateral sanctions consensus regarding Chile, meaning secondary-exposure risk can materialize in a jurisdiction that no other major regime currently treats as high-risk. Firms relying solely on the presence or absence of a country-level designation as a proxy for sanctions exposure will misprice this risk. The Chile nexus also illustrates a structural feature of transnational-criminal-organization financial infrastructure more broadly: designation of individual facilitators, however well-evidenced, does not by itself dismantle the underlying network. The front-entity and banking-access architecture described in reporting on this designation persists across jurisdictions until each node is separately identified and addressed, a pattern that recurs across the FIM standing tracker for Tren de Aragua-linked infrastructure and that mirrors the broader Latin American pattern of criminal organizations exploiting jurisdictional fragmentation in sanctions and law-enforcement authority. This cycle also surfaces a secondary FATF-adjacent uncertainty relevant to sanctions-architecture assessment: the exact slot of Chile in the FATF and GAFILAT fifth-round mutual evaluation sequence under the 2022 Methodology remains unconfirmed, with the next full assessment expected only in the 2027 to 2030 window. Because mutual evaluation reports are among the few multilateral mechanisms capable of testing whether the sanctions-screening and beneficial-ownership frameworks of a jurisdiction are adequate to detect facilitators like those named in the December 2025 designation, this scheduling uncertainty extends the period during which the compliant FATF status of Chile and its demonstrated Tren de Aragua exposure can coexist without external re-assessment. #### Outlook The T6 standing tracker, Sanctions Regime Divergence, will continue to monitor whether further Executive Order 14157-linked designations acquire additional Chile-nexus facilitators, and whether the EU or the UK moves to mirror the cartel and transnational-criminal-organization-as-terrorist-organization authority in any form. Absent a change in EU or UK designation practice, the divergence identified this cycle should be read as structural rather than episodic and can be expected to persist through at least the 2026 to 2027 horizon. Financial institutions with correspondent-banking exposure that also touch Chilean counterparties carry the most direct exposure to this asymmetry and should not treat the clean multilateral sanctions status of Chile as a complete picture of transaction risk arising from its jurisdiction. Future cycles should track whether the authorities of Chile take any domestic action, designation, or asset-freeze measure against the front-entity infrastructure described in the December 2025 OFAC action, which would indicate a shift from reactive tolerance toward structural response. Judgment: No Chile-specific sanctions-evasion development found this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency Chile sits outside the direct perimeter of the EU AML Package: the country is a non-EU, non-EEA third country, and the AML Regulation, the transposition of the sixth Anti-Money Laundering Directive by individual member states, and the direct and indirect supervisory perimeter of the new Anti-Money Laundering Authority do not apply to Chilean obliged entities. The developments directly relevant to the beneficial-ownership and corporate-transparency perimeter of Chile this cycle instead concern the durability of its own domestic gaps, most visibly surfaced by the June 2026 arrest of a Banco Santander Chile employee among eighteen suspects in an alleged 85 million dollar Tren de Aragua-linked laundering network that moved funds through accounts at nearly every major bank in the country. Chile has never established a centralized, publicly searchable beneficial-ownership register comparable to post-2020 EU or US standards; the May 2025 UNCAC Cycle II country review instead describes reliance on Ley 20.285, the general transparency-of-public-administration framework, in place of a dedicated beneficial-ownership registry regime. Continue reading The Santander case is best read as the practical expression of that registry gap rather than as an unrelated banking-controls failure. Absent a centralized register that would allow prosecutors, the Financial Analysis Unit, or reporting entities to independently verify beneficial ownership of the accounts and corporate vehicles used to layer funds, detection depended on an after-the-fact criminal investigation rather than a proactive transparency mechanism. The case has reignited a domestic political debate over reforming the bank-secrecy rules that constrained account-level scrutiny during the multi-year operation of the network; potential legislative reform sits in the 2026 fourth quarter to 2027 horizon window but has not yet been tabled, and its enactment is assessed as possible rather than probable. The active scheme inventory tracked this cycle identifies two red-flag indicators tied to this exposure: an insider bank employee facilitating large-scale layering of funds across nearly every major domestic bank, observable chiefly through transaction-monitoring controls, and the use of strict bank-secrecy protections to obscure account-level scrutiny over a multi-year duration, observable chiefly at onboarding. Both indicators are linked to retail and corporate customer typologies, meaning the exposure is not confined to a narrow high-risk segment but extends across the ordinary retail and corporate banking population, a feature that increases the systemic significance of any eventual secrecy reform. The absence of a dedicated beneficial-ownership framework compounds a related structural gap: Chile also lacks a dedicated international judicial-cooperation statute, relying instead on general Penal Code and Criminal Procedure Code provisions, treaties, and reciprocity, according to the same 2025 UNCAC review. For beneficial-ownership investigations with a cross-border dimension, such as the front-entity and banking-access architecture described in connection with Tren de Aragua financial facilitators, this compounds registry opacity with cooperation-mechanism opacity, a combination that a single legislative reform addressing bank secrecy alone would not fully resolve. Globally, the EU AML Package sets the structural direction against which beneficial-ownership regimes worldwide are increasingly measured, even for jurisdictions like Chile that fall outside its direct scope. The package now comprises three distinct instruments rather than a single directive: the AML Regulation, known as the AMLR, under Regulation (EU) 2024/1624, which is directly applicable across EU member states without national transposition; the sixth Anti-Money Laundering Directive, or 6AMLD, which each member state transposes individually into national law; and the AMLA Regulation, Regulation (EU) 2024/1620, which establishes the Anti-Money Laundering Authority itself. Together these instruments shift supervision away from a purely national model toward a hybrid EU-level regime, in which AMLA will directly supervise a defined population of the highest-risk cross-border obliged entities while continuing to coordinate indirect supervision of the remainder through national authorities. For Chile, this architecture is contextual rather than binding: no Chilean obliged entity falls within the AMLA direct or indirect supervisory perimeter, and the practical consequence for Chile is limited to the EU high-risk third-country classification exercise itself, from which Chile remained absent following the 4 December 2025 update under Delegated Regulation (EU) 2026/83, even as regional peers Bolivia and the British Virgin Islands were added. #### Outlook The most consequential near-term development for the beneficial-ownership perimeter of Chile is the domestic bank-secrecy reform debate reignited by the Santander case, which could expand Financial Analysis Unit and prosecutorial account-level access if it advances toward legislation in the 2026 to 2027 window. Absent that reform, or a parallel decision to establish a centralized beneficial-ownership register, the structural gap identified this cycle should be expected to persist, and future insider-assisted laundering schemes exploiting the same secrecy protections cannot be ruled out. Separately, the timing of the next FATF and GAFILAT mutual evaluation of Chile under the 2022 Methodology fifth round remains unconfirmed, with a working expectation of assessment only in the 2027 to 2030 window; that scheduling uncertainty means the beneficial-ownership deficiencies surfaced this cycle may not be formally retested by the multilateral evaluation mechanism for several years, extending the period during which a FATF-compliant status and a documented registry gap can coexist without external re-assessment. Judgment: No Chile-specific beneficial-ownership development found this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators Applying the four-dimension enabler-jurisdiction test, legal framework, enforcement, capacity versus choice, and systemic significance, to Chile this cycle produces a capacity-deficit rather than a political-choice reading. The legal framework itself is not unusually permissive by design: the bank-secrecy protections of Chile are described in reporting as among the strictest in the world, a status generally associated with taxpayer and account-holder privacy protection rather than a deliberate accommodation of illicit finance. The enforcement dimension, however, reveals the practical consequence of that framework: a recruited employee of Banco Santander Chile was able to move funds through accounts at nearly every major bank in the country as part of an alleged 85 million dollar Tren de Aragua-linked laundering network, reportedly for a period of years before eighteen suspects, including the employee, were arrested on 2 June 2026. Continue reading The mechanism at work here is professional or insider access rather than an informal value-transfer channel or a permissive registration regime. This distinguishes the Chile case from enabler-jurisdiction findings elsewhere in the FIM coverage that center on lax company-formation rules or weak beneficial-ownership disclosure; in Chile, a strong secrecy protection, intended to serve a legitimate privacy function, was converted into a laundering enabler once a single insider gained systemic banking access. On the capacity-versus-choice axis, this reads as a capacity deficit: Chile has not chosen permissiveness as a competitive strategy in the way some jurisdictions market themselves as low-friction financial centers, but it has also not built the monitoring capability commensurate with the strength of its secrecy protections, leaving a detectable gap between legal protection and supervisory capacity. A second enabler-relevant finding this cycle concerns international cooperation infrastructure rather than domestic banking secrecy. The May 2025 UNCAC Cycle II country review of Chile notes the absence of a dedicated international judicial-cooperation statute; the country instead relies on general Penal Code and Criminal Procedure Code provisions, treaties, and case-by-case reciprocity to support cross-border investigations. Whether this reflects capacity constraint or deliberate policy choice remains unresolved in the sources reviewed this cycle, but its practical effect is to slow or complicate cross-border tracing of the kind required to fully map the front-entity and banking-access architecture that reporting associates with Tren de Aragua financial facilitators operating from or through Chile. On the systemic-significance dimension, the Santander case indicates that the enabler function operates at scale: funds moved through accounts spanning nearly every major bank in the country, not a narrow or peripheral segment of the financial system. This scale, combined with the multi-year duration before detection, suggests the enabler condition identified here is structural rather than confined to a single institution weakness, and that similar insider-access schemes could in principle recur absent either secrecy reform or enhanced internal-control requirements at the institutional level. This capacity-deficit enabler profile sits in some tension with the otherwise compliant multilateral standing of Chile: the country is absent from the FATF grey and black lists as of the 19 June 2026 Plenary and does not appear on the EU high-risk third-country list following the December 2025 update. The FIM standing assessment treats these two readings as compatible rather than contradictory: multilateral list status measures technical and effectiveness compliance against FATF recommendations, chiefly Recommendations 24 and 25 on beneficial ownership, at the time of the last full evaluation, while the enabler-jurisdiction test applied here measures whether the demonstrated operational reality this cycle, an insider-exploited secrecy regime and an unconfirmed cooperation framework, is consistent with that formal status. The gap between the two readings is itself the analytically significant finding: a jurisdiction can retain compliant list status for years while an exploitable structural condition persists undetected, precisely because mutual evaluation cycles are infrequent and the next full reassessment of Chile under the FATF and GAFILAT 2022 Methodology fifth round is not confirmed to occur before 2027 at the earliest. #### Outlook The domestic bank-secrecy reform debate reignited by the Santander case is the primary near-term marker for whether the enabler condition identified this cycle narrows. If reform advances in the 2026 fourth quarter to 2027 window, it would most directly address the enforcement dimension of the four-dimension test by expanding Financial Analysis Unit and prosecutorial account-level access. It would not, by itself, address the international-cooperation gap identified in the UNCAC review, which would require a separate legislative initiative establishing a dedicated cooperation statute. Absent movement on either front, the enabler profile of Chile should be read as stable rather than improving, with the demonstrated capacity to be exploited by insider-access schemes persisting as a background condition even though Chile itself pursues no permissive policy by design. Judgment: No enabler-jurisdiction dynamic specific to Chile found this cycle. Uncertain #### Conflict Finance and Extractive-Industry Integrity Applying the source-channel-deployment trace prescribed by the conflict-finance filter to the copper-smuggling case disarticulated in Chile in April 2026 clarifies why this is a structural extractive-industry integrity finding rather than an isolated theft prosecution. At the source, organized criminal groups stole and processed copper cathode and concentrate from Chilean mining and transport infrastructure, reportedly at a scale investigators describe as previously unreported, capitalizing on elevated global copper prices to make large-volume theft commercially attractive. At the channel level, the illicit metal was commingled with legitimate export flows and financed through commercial trade financing instruments, allowing an estimated 917 million dollars in stolen copper to be shipped to Peru and China without the commingling itself triggering detection at the point of export. At the deployment level, proceeds were repatriated through the same trade-finance channels used to disguise the illicit origin of the underlying commodity, echoing the environmental-crime money-laundering typology work published by FATF describing how extractive-sector theft is layered through ordinary commercial trade infrastructure rather than through parallel or informal financial systems. Continue reading This structure means that trade-based laundering and extractive-industry theft in Chile are not two separate findings but a single financial-crime architecture: the theft generates the illicit commodity, the trade-finance channel launders it, and the repatriated proceeds close the loop. Two red-flag indicators anchor the active scheme inventory tracked for this exposure: the commingling of stolen and legitimate copper exports within the same trade-finance flows, observable chiefly through trade-documentation review, and commodity export volumes inconsistent with reported mining and transport output, also observable through trade-documentation review. Both indicators are linked to trade-finance and corporate customer typologies, meaning the exposure sits squarely within commercial banking relationships rather than retail banking, a different customer-risk profile than the insider-access banking scheme identified elsewhere in FIM coverage of Chile this cycle. The state response to this exposure is the Politica Nacional contra el Crimen Organizado, a national organized-crime policy explicitly targeting copper- and timber-theft economies and cross-border smuggling, with implementation continuing through the 2026 to 2027 horizon. The durability of the disruption achieved by the April 2026 network disarticulation will depend substantially on whether this policy vehicle can address the underlying commercial incentive structure, elevated global copper prices meeting weak chain-of-custody verification in the mining and export sectors, rather than only prosecuting the specific network already disarticulated. A policy response confined to prosecution of the disarticulated network without parallel reform of export-verification and trade-finance due-diligence practice would leave the commercial incentive structure that enabled this scheme intact for successor networks. This finding also situates Chile within a broader Latin American pattern of extractive-sector financial-crime exposure that the monitor tracks across multiple jurisdictions, in which legitimate commodity export infrastructure functions as the laundering channel of choice precisely because it is subject to less granular anti-money-laundering scrutiny than the formal banking sector. The 917 million dollar scale of the Chile pipeline, disarticulated only after reaching what investigators describe as a previously unreported scale, indicates that detection in this domain currently depends on law-enforcement investigation rather than on transaction-monitoring or trade-finance due-diligence controls operating in real time, a structural detection gap distinct from, but comparable in kind to, the banking-secrecy detection gap identified in the Beneficial Ownership and Corporate Transparency domain this cycle. Whether Chilean commercial banks and trade-finance providers currently apply enhanced due diligence specific to mining-sector export documentation could not be confirmed from primary sourcing this cycle, and this sourcing gap itself should be treated as a priority for future-cycle research given the scale of the exposure now documented. #### Outlook Continued rollout of the Politica Nacional contra el Crimen Organizado through 2026 and 2027 is the primary marker this monitor will track for whether the extractive-industry integrity posture of Chile shifts from reactive prosecution toward structural pre-emption. Given that the scheme disarticulated in April 2026 involved trade-finance channels rather than only physical smuggling routes, effectiveness will depend on whether enhanced due diligence in commodity trade financing and export documentation review becomes part of the implementation, and not solely on continued law-enforcement action against smuggling networks. Absent such enhancement, elevated global copper prices are likely to sustain the commercial incentive for similar theft-to-export schemes, and the trade-based-laundering channel identified this cycle should be treated as a persistent rather than a resolved exposure. Judgment: No conflict-finance development specific to Chile found this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation The defining development for Chile's digital-asset perimeter this cycle is the Comisión para el Mercado Financiero's Official Letter 101082, which settles two linked questions under Ley Fintec (Ley 21.521): first, that crypto-assets are financial instruments for the purposes of the law, and second, that a self-custody wallet where the service provider does not control the private keys does not amount to custody. This is a probable finding, resting on secondary legal commentary describing the letter rather than the CMF's own published text, and the gap in direct retrieval of the letter itself is recorded rather than smoothed over. Even on that basis, the determination matters because it draws the line that decides which crypto-asset service providers fall inside the custodial obliged-entity perimeter and which, by virtue of key-control architecture alone, sit outside it. Continue reading The practical effect is to push crypto-asset businesses operating in Chile toward a binary choice in how they structure custody: providers that retain key control are now on notice that they are treated as financial-instrument custodians, with the compliance obligations that follow, while those that architect genuine non-custodial access can rely on the CMF's own characterisation to stay outside that perimeter. This is the kind of structural, architecture-level clarification that outweighs any single enforcement action in significance, because it will shape how the entire sector in Chile designs its technical and legal custody arrangements going forward, not just how one firm is treated after the fact. It also sits inside a broader pattern: CMF guidance has been incrementally fleshing out the regulatory perimeter established by Ley Fintec over successive cycles, of which this is simply the latest instalment, rather than an isolated one-off ruling. The absence of any sanctions-regime or beneficial-ownership overlap in this finding is notable by omission: the CMF's custody determination is being made on pure financial-instrument and custody-law grounds, with no indication this cycle that AML/CFT exposure assessments for crypto-asset operators have been separately revised in light of it. That gap is itself worth tracking, since a custody classification with this much structural weight would ordinarily be expected to prompt a parallel look at how the AML/CFT obliged-entity list for crypto-asset operators should be updated. #### Outlook Further CMF implementing guidance is likely as crypto-asset providers adjust their custody architecture to the self-custody carve-out confirmed in Official Letter 101082; whether that guidance arrives as additional official letters or as formal regulation remains unresolved as scheduled. The broader Ley Fintec Open Finance data-sharing regime, for which technical standards NCG 514 and NCG 569 are already finalised, remains in a pending in-force stage with testing environments open but general go-live already postponed once; the next observable marker will be whether that go-live proceeds on its revised timeline or slips again. Independent retrieval of the CMF's own Official Letter 101082 text would allow this classification finding to move from probable toward a firmer confidence tier in a future cycle. Judgment: CMF guidance continues to flesh out the crypto-asset regulatory perimeter under Ley Fintec. Probable #### Compliance Technology and Active Defence The material finding for this domain in Chile this cycle is an absence rather than a development: no primary-source material was located on the RegTech or SupTech posture of the Comision para el Mercado Financiero or the Financial Analysis Unit, nor on any perpetual-KYC or continuous-monitoring initiative these bodies may or may not have underway. This sourcing gap is treated as the standing D6 signal for Chile at this baseline, consistent with the monitor practice of surfacing coverage absence as an analytically meaningful condition rather than silently omitting it. A related but distinct uncertainty concerns the scheduling of the next FATF and GAFILAT mutual evaluation of Chile under the 2022 Methodology fifth round, which remains unconfirmed against the published assessment calendar, with a working expectation of assessment only in the 2027 to 2030 window. Because mutual evaluation reports are one of the principal mechanisms through which compliance-technology and supervisory-technology posture becomes externally verifiable, this scheduling uncertainty compounds the direct sourcing gap: even absent a change in primary-source availability, formal external verification of compliance-technology maturity for Chile is unlikely within the near term. Future cycles should specifically target CMF regulatory filings, UAF annual reports, and any published guidance on virtual-asset supervision as the highest-value sources to close this gap. Continue reading #### Outlook Closing the CMF and UAF sourcing gap identified this cycle is the explicit research priority for the next FIM cycle covering Chile. Until direct primary-source material is located, this domain should continue to be treated as a genuine coverage gap rather than as evidence of either strong or weak compliance-technology maturity, and no severity or trajectory judgment beyond watch should be inferred from the absence of findings recorded here. Judgment: No compliance-technology development specific to Chile found this cycle. Uncertain #### AML/CTF Regime Chile's AML/CFT regime moved on two fronts this cycle. The Unidad de Análisis Financiero issued Circular N°62, consolidating existing anti-money-laundering, counter-terrorist-financing and counter-proliferation-financing instructions into a single framework: obliged entities must retain records for five years, provide annual staff training, and are now subject to a tiered administrative sanction ladder running from minor infractions (fines of up to 800 UF) through less-serious (up to 3,000 UF) to serious (up to 5,000 UF), with each tier triplable on repetition. The circular also identifies the automotive sector as a disproportionate laundering vector, citing a 73.9 percent share of total convictions between 2019 and 2023 — a figure striking enough to justify singling the sector out for supervisory attention going forward. This is a probable finding, as the UAF's own Circular N°62 text was not independently retrieved this cycle and the figures rest on secondary trade-press reporting describing an industry training session on the new requirements. Continue reading Separately, the Corte de Apelaciones de Santiago confirmed a UAF administrative sanction — a written warning plus a 40 UF fine — against a remittance firm for anti-money-laundering programme failures. This is an uncertain finding given reliance on specialist legal-news reporting with an approximate ruling date rather than the court's own judgment text, but its significance lies less in the modest fine amount than in the fact of judicial deference: the court upheld the UAF's administrative determination rather than disturbing it on review. For a compliance regime, this kind of outcome is the quieter but more durable signal — it establishes that sanctions issued under the consolidated framework are likely to survive judicial scrutiny, which gives the new Circular N°62 sanction ladder practical teeth beyond its nominal fine ranges. Reading the two developments together, Chile's AML/CFT architecture is being actively consolidated and tested at the same time: the UAF is formalising obligations and consequences through Circular N°62 while the courts are simultaneously validating the UAF's prior exercises of sanction authority. The automotive-sector flag is the most structurally interesting element, since it identifies a sector outside the traditional financial-services AML frontline as carrying the bulk of recent laundering convictions, which should be read as an architecture-level finding about where illicit flows are actually concentrating in Chile's economy rather than as an incidental statistic. #### Outlook Given the automotive-sector flag now sits explicitly within Circular N°62, visible enforcement activity directed at that sector is a reasonable expectation over coming cycles, though this is illustrative orientation rather than a prediction. The judicial pattern of upholding UAF sanctions on review, as shown in the Santiago Court of Appeals decision, suggests that administrative sanctions issued under the new tiered ladder are likely to hold up if challenged, which should reinforce the UAF's willingness to use the full range of the ladder rather than defaulting to its lower tiers. Independent retrieval of the UAF's own Circular N°62 text in a future cycle would allow the sanction-tier figures and training/retention obligations to be confirmed directly rather than through secondary reporting. Judgment: UAF Circular N°62 consolidates standing AML/CFT obligations with a tiered sanction ladder and automotive-sector risk flag; judicial enforcement continues to uphold UAF sanctions on review. Probable Judgment: No integrity-sector commercial event specific to Chile found this cycle. Uncertain Regulatory horizon Consultation 2026-Q4 · ±half_year ### Chile Sistema de Inteligencia Economica contra el Delito (Boletin 15975-25) If passed, would strengthen the UAF and create an Economic Intelligence system with new bank-secrecy-lift authority and updated illegal-gambling definitions coordinated with the pending online-betting bill. [Source](https://www.senado.cl/comunicaciones/noticias/subsistema-de-inteligencia-y-seguridad) In Force Pending 2027-Q3 · ±half_year ### Ley Fintec Sistema de Finanzas Abiertas (Open Finance) entry into force Open Finance data-sharing obligations under Ley 21.521 become operative for in-scope financial entities. [Source](https://www.bcentral.cl/en/areas/financial-policy/informe-de-sistemas-de-pago) Consultation 2031-Q1 · ±multi_year ### GAFILAT Fifth Round Mutual Evaluation of Chile A future effectiveness-focused re-assessment of Chile's AML/CFT/CPF system under a yet-unpublished methodology. [GAFILAT Source](https://www.uaf.cl/media/documentos/NationalStrategic.pdf) 3 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### UAF Circular N62 introduces a tiered sanction ladder and flags the automotive sector as a disproportionate laundering vector. Obliged entities now face a formalised minor/less-serious/serious sanction structure with amounts triplable on repetition, and record-retention and training duties are consolidated into one instruction. The automotive-sector flag signals where SAR-adjacent attention may concentrate going forward. 2 evidence refs Compliance ### CMF clarifies the crypto-asset custody perimeter while UAF consolidates AML/CFT obligations under Circular N62. The custody determination affects which crypto-asset service providers are treated as obliged entities, and the Circular N62 consolidation resets record-keeping and training baselines for all obliged entities operating in Chile. 2 evidence refs Legal ### A Santiago appellate court upheld a UAF administrative sanction against a remittance firm on review. Judicial deference to UAF sanction decisions in this instance suggests limited prospects for successfully challenging similar administrative findings, though the finding rests on secondary reporting rather than the judgment text itself. 1 evidence refs Board ### Chile's financial-integrity regulators are tightening both crypto-asset perimeter definition and AML/CFT sanction architecture in the same cycle. The combined effect is a more clearly defined and more consequential compliance environment for any institution with Chilean crypto-asset or AML/CFT exposure, without any single enforcement event driving reputational risk this cycle. 2 evidence refs CTO ### CMF confirms that self-custody wallets without provider key control fall outside the custody perimeter under Ley Fintec. This gives a concrete technical criterion, key control, that determines regulatory treatment, with direct implications for how custody architecture is designed for any crypto-asset platform serving Chilean users. 1 evidence refs Risk ### The automotive sector has been identified as carrying a disproportionate share of Chile's recent money-laundering convictions. A sector outside the traditional financial-services AML frontline now sits on the regulator's own risk map, which should factor into concentration and typology-exposure assessments for any institution with automotive-sector-linked exposure. 1 evidence refs Operations ### Circular N62 sets a five-year record-retention duty and annual staff training requirement for obliged entities. Operational workflows around document retention periods and training cadence should be checked against these consolidated requirements. 1 evidence refs Audit ### A tiered, triplable sanction ladder now applies under Circular N62, and a prior UAF sanction has survived judicial review. Audit scope should account for the new sanction-tier structure when assessing control-testing adequacy, and the upheld judicial decision indicates UAF administrative findings carry practical weight once issued. 2 evidence refs Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change T2 · EU AML Package / AMLA no_change T3 · FATF Grey List no_change T4 · Beneficial-Ownership Register Status no_change T5 · Crypto & Digital-Asset Integrity material_change T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 3 Dec 2025 - 2 Jun 2026 - 8 Apr 2026 - 6 Aug 2025 - 24 Apr 2026 - 18 Mar 2026 - OFAC designated multiple individuals and entities tied to a money-laundering network supporting the Venezuela-based Tren de Aragua criminal organization, previously designated a Foreign Terrorist Organization/Specially Designated Global Terrorist group; one designee's location was recorded as Chile. 3 Dec 2025 - Chilean authorities arrested 18 suspects, including a Banco Santander Chile employee, in an investigation into an alleged $85 million money-laundering network linked to Tren de Aragua that moved funds through accounts at nearly every major bank in the country. 2 Jun 2026 - Chilean investigators disarticulated a criminal network responsible for stealing, processing and exporting an estimated $917 million in copper to Peru and China, described as an unprecedented scale of organized copper theft. 8 Apr 2026 ### Sanctions changes - 3 Dec 2025 - 4 Dec 2025 - 23 Jul 2026 - 16 Jun 2026 - OFAC designated a Tren de Aragua money-laundering network under counter-terrorism and transnational-criminal-organization authorities, with a designated individual's location recorded as Chile, extending U.S. secondary-sanctions exposure into the Chilean financial system without Chile itself being subject to a country-level sanctions program. 3 Dec 2025 - The EU Commission's December 2025 update to its high-risk third-country list added Bolivia and the British Virgin Islands (and earlier in 2025 added Venezuela, among others) while Chile remained unlisted throughout the window, widening the classification gap between Chile and several GAFILAT/regional peers now facing EU enhanced-due-diligence treatment. 4 Dec 2025 ### Regulatory horizon (register) - Chile Sistema de Inteligencia Economica contra el Delito (Boletin 15975-25) - FATF UK Presidency strategic priorities take effect - Chile Sistema de Inteligencia Economica contra el Delito (Boletin 15975-25) - GAFILAT Fifth Round Mutual Evaluation of Chile - Ley Fintec Sistema de Finanzas Abiertas (Open Finance) entry into force - Chile's next FATF/GAFILAT mutual evaluation under 2022 Methodology - Potential legislative reform of Chile's bank-secrecy rules - Continued rollout of Chile's Política Nacional contra el Crimen Organizado ### Active schemes - Bank-insider laundering network exploiting Chilean secrecy rules - Copper-theft-to-China/Peru smuggling and laundering pipeline - Tren de Aragua TCO financial infrastructure operating from Chile - CEX-dominant crypto value transfer exposure in Chile Sources - [Protecting the EU’s financial system - Finance - European Commission](https://finance.ec.europa.eu/news/protecting-eus-financial-system-2025-07-16_en) - [Chambers and Partners](https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/chile) - [UAF Chile](https://www.uaf.cl/es-cl/normativa/nuestra-ley) - [Diario El America](https://elamerica.cl/2026/07/28/senador-velasquez-impulsa-fuertes-sanciones-contra-empresas-que-faciliten-el-lavado-de-activos/) - [Diario Constitucional](https://www.diarioconstitucional.cl/2025/08/06/corte-suprema-respalda-sancion-de-la-uaf-por-incumplimientos-en-deber-de-prevencion-de-lavado-de-activos/) - [FATF](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [US Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0547) - [TRM Labs](https://www.trmlabs.com/resources/blog/ofac-sanctions-cambodian-senator-and-scam-center-network-targeting-americans-with-digital-asset-fraud) - [Wikipedia (Cambodia 2026 timeline)](https://en.wikipedia.org/wiki/2026_in_Cambodia) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Lao-People-s-Democratic-Republic.html) - [IMTF (citing FinCEN Aug 2025 advisory)](https://imtf.com/blog/when-trade-becomes-a-cover-unpacking-trade-based-money-laundering/) - [Baker McKenzie Sanctions News](https://sanctionsnews.bakermckenzie.com/uk-expands-russia-sanctions-to-further-target-shadow-fleet-military-procurement-and-financial-networks/) - [Tech Times](https://www.techtimes.com/articles/321441/20260723/eu-passes-218-russia-sanctions-targets-vessels-that-refuel-shadow-fleet-tankers.htm) - [Holland & Knight](https://www.hklaw.com/en/insights/publications/2026/01/ofac-sanctions-top-5-trends-for-2026) - [https://www.fatf-gafi.org/en/countries/detail/Chile.html](https://www.fatf-gafi.org/en/countries/detail/Chile.html) - [https://www.uaf.cl/es-cl/sistema-nacional-alacftcfp/que-es-el-financiamiento-del-terrorismo](https://www.uaf.cl/es-cl/sistema-nacional-alacftcfp/que-es-el-financiamiento-del-terrorismo) - [https://chocale.cl/2026/09/ojo-con-estas-dos-plataformas-que-no-estan-registradas-ni-autorizadas-para-operar-en-chile/](https://chocale.cl/2026/09/ojo-con-estas-dos-plataformas-que-no-estan-registradas-ni-autorizadas-para-operar-en-chile/) - [https://www.cooperativa.cl/noticias/economia/cmf-cancelo-inscripcion-a-ley-fintech-de-empresa-ligada-al-tren-de-aragua/2026-06-26/151226.html](https://www.cooperativa.cl/noticias/economia/cmf-cancelo-inscripcion-a-ley-fintech-de-empresa-ligada-al-tren-de-aragua/2026-06-26/151226.html) - [https://www.df.cl/economia-y-politica/pais/las-claves-de-la-propuesta-de-primer-registro-publico-de-duenos-y](https://www.df.cl/economia-y-politica/pais/las-claves-de-la-propuesta-de-primer-registro-publico-de-duenos-y) - [https://microservicio-documentos.senado.cl/v1/archivos/685ccb51-f6fb-40fc-a923-6b7c1f466834?includeContent=true](https://microservicio-documentos.senado.cl/v1/archivos/685ccb51-f6fb-40fc-a923-6b7c1f466834?includeContent=true) - [https://www.yogonet.com/latinoamerica/noticias/2026/07/31/110018-la-scj-y-la-uaf-actualizan-la-normativa-para-fortalecer-la-prevencion-del-lavado-de-activos-en-los-casinos](https://www.yogonet.com/latinoamerica/noticias/2026/07/31/110018-la-scj-y-la-uaf-actualizan-la-normativa-para-fortalecer-la-prevencion-del-lavado-de-activos-en-los-casinos) - [https://www.uaf.cl/es-cl/normativa/circulares-uaf](https://www.uaf.cl/es-cl/normativa/circulares-uaf) - [https://www.uaf.cl/es-cl/](https://www.uaf.cl/es-cl/) - [https://www.latamfintech.co/articles/fintech-chilena-blanco-cierra-ronda-semilla-de-us-5-2-millones-para-fortalecer-su-negocio-de-factoring-digital](https://www.latamfintech.co/articles/fintech-chilena-blanco-cierra-ronda-semilla-de-us-5-2-millones-para-fortalecer-su-negocio-de-factoring-digital) - [Unidad de Análisis Financiero (UAF)](https://www.uaf.cl/es-cl/sistema-nacional-alacftcfp/evaluaciones-a-chile-gafilat) - [Unidad de Análisis Financiero (UAF)](https://www.uaf.cl/es-cl/noticia-detalle?id=422) - [G5 Noticias](https://g5noticias.cl/2026/10/22/cavem-e-icompliance-capacitan-al-sector-automotor-sobre-las-nuevas-exigencias-de-la-uaf-y-la-ley-de-delitos-economicos/) - [Unknown Gravity](https://www.unknowngravity.com/en/articulos/chile-fintec-law) - [Diario Constitucional](https://www.diarioconstitucional.cl/2026/03/18/corte-de-santiago-confirma-multa-de-40-uf-a-empresa-de-remesas-por-incumplimientos-en-prevencion-de-lavado-de-activos) - [UAF](https://www.uaf.cl/es-cl/noticia-detalle?id=47285) - [Banco Central de Chile](https://www.bcentral.cl/en/areas/financial-policy/informe-de-sistemas-de-pago) - [MER Chile](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Merchile.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html) - [Chile](https://www.fatf-gafi.org/en/countries/detail/Chile.html) - [Chile's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-chile-2021.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up Universal Procedures](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Universal-procedures.html) - [Financial Action Task Force of Latin America (GAFILAT)](https://www.fatf-gafi.org/en/countries/global-network/financial-action-task-force-of-latin-america--gafilat-.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [CHILE LAVADO DE ACTIVOS Y UAF LEY NUM. 19.913 ...](https://www.unodc.org/cld/uploads/res/document/chl/2005/ley_num__19_913_que_crea_la_unidad_de_analisis_financiero_y_modifica_diversas_disposiciones_en_materia_de_lavado_y_blanqueo_de_activos_html/Chile_Ley_Num_19.913.pdf) - [Articulo 8](https://sherloc.unodc.org/cld/es/legislation/ecu/reglamento_-_ley_de_lavado_de_activos_y_del_financiamiento_de_delitos/titulo_i_-_capitulo_i/articulo_8/articulo_8.html) - [Articulo 6](https://www.unodc.org/cld/es/legislation/ecu/reglamento_-_ley_de_lavado_de_activos_y_del_financiamiento_de_delitos/titulo_i_-_capitulo_i/articulo_6/articulo_6.html) - [Articulo 73](https://www.unodc.org/cld/es/legislation/slv/ley_organica_de_la_fiscalia_general_de_la_republica/articulo_73/articulo_73.html) - [Lavado de Activos - United Nations Office on Drugs and Crime](https://www.unodc.org/peruandecuador/es/02AREAS/DELITO/lavado-de-activos.html) - [INFORME DEL GAFI Lavado de activos provenientes de delitos ambientales](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/reports/Spanish-Money-Laundering-from-Environmental-Crime.pdf) - [Nueva guía nacional estandariza la información financiera para mejorar investigaciones de lavado de activos en Ecuador](https://www.unodc.org/rocol/es/noticias/ecuador/nueva-guia-nacional-estandariza-la-informacin-financiera-para-mejorar-investigaciones-de-lavado-de-activos-en-ecuador.html) - [Articulo 15](https://sherloc.unodc.org/cld/es/legislation/ecu/reglamento_-_ley_de_lavado_de_activos_y_del_financiamiento_de_delitos/titulo_i_-_capitulo_ii/articulo_15/articulo_15.html) - [Lavado de activos](https://www.unodc.org/ropan/es/lavado-de-activos.html) - [Investigaciones Financieras contra el Lavado de Activos: Fortaleciendo Capacidades en Ecuador para Combatir el Crimen Organizado Transnacional](https://www.unodc.org/rocol/es/noticias/ecuador/investigaciones-financieras-contra-el-lavado-de-activos_-fortaleciendo-capacidades-en-ecuador-para-combatir-el-crimen-organizado-transnacional.html) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [UK Cambridge fintech experts visit Chile to share regulatory expertise - GOV.UK](https://www.gov.uk/government/news/uk-cambridge-fintech-experts-visit-chile-to-share-regulatory-expertise) - [What Is a VASP? Virtual Asset Service Provider - Chainalysis](https://www.chainalysis.com/glossary/virtual-asset-service-provider/) - [Digital Assets in Digital Finance Regulatory Standards and Law](https://uncitral.un.org/sites/uncitral.un.org/files/media-documents/uncitral/en/castellano_updated.pdf) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Road to Crypto Regulation Part 2: Stablecoins](https://www.chainalysis.com/blog/the-road-to-crypto-regulation-part-2-stablecoins/) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [2025 LATAM Crypto Adoption: Latin America Emerges as Crypto Powerhouse](https://www.chainalysis.com/blog/latin-america-crypto-adoption-2025/) - [FSB thematic review 2025: Global crypto regulation remains fragmented despite market growth](https://www.elliptic.co/blog/fsb-thematic-review-2025) - [MEJORES PRÁCTICAS SOBRE BENEFICIARIOS FINALES PARA PERSONAS JURÍDICAS](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/guidance/GAFILAT-Best-Practices-Beneficial-Ownership-Legal-Persons.pdf) - [GUÍA SOBRE EL BENEFICIARIO FINAL DE LAS PERSONAS JURÍDICAS MARZO 2023](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/guidance/Spanish%20Guidance-Beneficial-Ownership-Legal-Persons.pdf.coredownload.pdf) - [BENEFICIARIO FINAL Y TRANSPARENCIA DE OTRAS ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/reports/Spanish-Guidance%20on%20Beneficial%20Ownership%20and%20Transparency%20of%20Legal%20Arrangements.pdf.coredownload.inline.pdf) - [MEJORES PRÁCTICAS SOBRE BENEFICIARIOS ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/guidance/GAFILAT-Best-Practices-Beneficial-Ownership-Legal-Persons.pdf.coredownload.inline.pdf) - [Chile - Directory of Open-Source Registries](https://globenetwork.unodc.org/globenetwork/en/directory-of-open-source-registries/chile.html) - [Cuestionario sobre la información relativa a los ...](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2022-November-7-11/Chile_Responses_to_Questionnaire_on_BOT_Regimes_SP.pdf) - [Chile](https://unstats.un.org/unsd/demographic-social/meetings/2017/new-york--egm-on-management-and-evaluation-of-crvs-systems/Session18-Chile-Civil-Registration.pdf) - [Reporte de información de beneficiarios finales](https://www.fincen.gov/system/files/shared/BOI-FAQs-Q&A-09.28.23-Spanish-508C.pdf) - [CHILE LOS SISTEMAS DE REGISTRO CIVIL Y ESTADISTICAS VITALES* INDICE Página l.](https://unstats.un.org/unsd/demographic/meetings/wshops/1991_Argentina_CRVS/Docs/Chile.pdf) - [Registro Nacional de Beneficiario | Department of Economic and Social Affairs](https://sdgs.un.org/partnerships/registro-nacional-de-beneficiario) - [1 [Traducción de Cortesía] Informe del GAFI Activos Virtuales](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/reports/GAFILAT-Spanish-Virtual%20Assets-Red%20Flag%20Indicators.pdf.coredownload.inline.pdf) - [FINTECH LTD overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/10184221) - [Fatf-gafi](https://fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/GAFILAT-Spanish-Mutual-Evaluation-Report-Chile-2021.pdf) - [Transacciones digitales en mundos virtuales](https://digital-strategy.ec.europa.eu/en/policies/virtual-worlds-digital-transactions) - [DIRECTRICES PARA UN ENFOQUE BASADO EN RIESGO MONEDAS VIRTUALES JUNIO 2015](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/guidance/Directrices-para-enfoque-basada-en-riesgo-Monedas-virtuales.pdf) - [Redes chinas de lavado de dinero (CMLN)](https://www.fincen.gov/system/files/2026-01/FinCEN-FTA-CMLN-Spanish.pdf) - [Actualizado: 24 de julio de 2024 1 Red de cumplimiento de delitos financieros](https://www.fincen.gov/system/files/shared/BOI_FAQs_QA_01.2024_Spanish_v2.pdf) - [Riesgo de Lavado de Activos en Instrumentos Fiancieros Embajada Británica](https://www.unodc.org/documents/colombia/2013/diciembre/Riesgo_de_Lavado_de_activos_version_I.pdf) - [Estrategia Nacional para la Prevención y Combate al Lavado de Activos y al Financiamiento del Terrorismo](https://www.unodc.org/cld/es/treaties/strategies/chile/chl0001s.html) - [Política Nacional contra el Crimen Organizado](https://www.unodc.org/cld/es/treaties/strategies/chile/chl0004s.html) - [1 La Red de Control de Delitos Financieros (FinCEN) del](https://www.fincen.gov/system/files/2026-01/FinCEN-Advisory-CMLN-Spanish.pdf) - [Unodc](https://www.unodc.org/cld/es/treaties/strategies/chile/chl0003s.html) - [REPORTE DEL GAFI Riesgos del Lavado de Dinero y Financiamiento](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/reports/Riesgos-del-lavado-de-dinero-y-financiamiento-al-terrorismo-derivados-del-trafico-de-migrantes.pdf) - [Informe Mundial sobre las Drogas 2025 de UNODC: La inestabilidad mundial agrava el impacto social, económico y de seguridad del fenómeno mundial de las drogas](https://www.unodc.org/unodc/es/press/releases/2025/June/unodc-world-drug-report-2025_-global-instability-compounding-social--economic-and-security-costs-of-the-world-drug-problem.html) - [El Departamento del Tesoro emite históricas órdenes bajo una nueva y poderosa facultad para combatir el fentanilo | FinCEN.gov](https://www.fincen.gov/news/news-releases/el-departamento-del-tesoro-emite-historicas-ordenes-bajo-una-nueva-y-poderosa) - [Lavado de dinero y financiamiento del terrorismo en el ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/reports/Spanish-ML-TF-Art-Antiquities-Market.pdf.coredownload.pdf) - [Segundo Informe de Recalificación de Cumplimiento Técnico de Bolivia](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Bolivia-Spanish-GAFILAT-Follow-Up-Report-2025.pdf.coredownload.inline.pdf) - [Informe de país de Chile](https://track.unodc.org/uploads/documents/UNCAC/CountryVisitFinalReports/2025_05_22_Chile_Cycle_II_Country_Report_SP.pdf) - [GUÍA DEL GAFI EN LA LUCHA CONTRA EL FINANCIAMIENTO DE LA PROLIFERACIÓN](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/guidance/GAFILAT-Spanish-FATF-Guidance-on-Proliferation-Financing.pdf.coredownload.inline.pdf) - [Informe de Seguimiento Regular y Recalificación de ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GAFILAT-Cuba-ESP-2024.pdf.coredownload.pdf) - [Documento del Presidente del GAFI Antilavado de activos y contra el](https://www.fatf-gafi.org/content/dam/fatf-gafi/translations/reports/GAFILAT-Spanish-AML-CFT-Judges-Prosecutors.pdf.coredownload.inline.pdf) - [Primer Informe de Seguimiento Intensificado y ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GAFILAT-Bolivia-Sp-First-Follow-up-Report.pdf) - [0 │ TERCER INFORME DE SEGUIMIENTO INTENSIFICADO DE GUATEMALA Octubre 2018](https://www.fatf-gafi.org/content/dam/fatf/documents/reports/fur/GAFILAT-Spanish-3rd-Follow-Up-Report-Guatemala-2018.pdf) - [REPORTE DEL GAFI Riesgos del Lavado de Dinero y Financiamiento](https://www.fatf-gafi.org/media/fatf/documents/reports/Riesgos-del-lavado-de-dinero-y-financiamiento-al-terrorismo-derivados-del-trafico-de-migrantes.pdf) - [PREVENCIÓN DEL LAVADO DE DINERO Una Guía para Empresas de Servicios Monetarios](https://www.fincen.gov/system/files/shared/mlp_spa_prevention_guide.pdf) - [UNODC y Superintendencia de Bancos fortalecen la normativa contra el lavado de activos](https://www.unodc.org/rocol/es/noticias/ecuador/unodc-y-superintendencia-de-bancos-fortalecen-la-normativa-contra-el-lavado-de-activos.html) - [Reglamento de la Ley Contra el Lavado de Dinero u Otros ...](https://www.unodc.org/documents/archive/imolin/Guatrlcd.pdf) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service) - [Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions) - [OFAC - Sanctions List Site](https://ofac.treasury.gov/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists) - [Counter Terrorism Designations; Transnational Criminal Organizations Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251203) - [United Nations Security Council Consolidated List | Security Council](https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list) - [Program Tag Definitions for OFAC Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/specially-designated-nationals-list-sdn-list/program-tag-definitions-for-ofac-sanctions-lists) - [Office of Foreign Assets Control - Sanctions Programs and Information | Office of Foreign Assets Control](https://ofac.treasury.gov/office-of-foreign-assets-control-sanctions-programs-and-information) - [Archive of Changes to OFAC's Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/specially-designated-nationals-list-sdn-list/archive-of-changes-to-the-sdn-list) - [Counter Narcotics and Counter Terrorism Designations and Designation Updates; Cyber-related Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250814) - [lucha contra el crimen organizado, el lavado de activ](https://track.unodc.org/track/uploads/res/track/resourcehub/2025/safeguarding_strategic_resources_in_latin_america_and_the_caribbean_html/UNODC_2025_Safeguarding_strategic_resources_in_Latin_America_and_the_Caribbean-_countering_organized_crime_money_laundering_and_corruption_in_the_mining_sector_SPA.pdf) - [Chile desarticula red criminal que robó US$917 millones en cobre y lo enviaba a China](https://www.bloomberg.com/news/articles/2026-04-08/mafias-del-cobre-en-chile-asi-operan-y-exportan-a-china) - [Chile Uncovers Criminal Networks Shipping Millions of Dollars of Copper to Peru and China](https://www.bloomberg.com/news/articles/2026-04-08/chile-uncovers-917-million-copper-theft-ring-shipping-to-china) - [Un alto a la ciberdelincuencia organizada](https://www.unodc.org/lpomex/es/articulos/2025/un-alto-a-la-ciberdelincuencia-organizada.html) - [Lavado de activos](https://www.unodc.org/rocol/es/lavado-de-activos.html) - [Detienen a ejecutivo de Santander Chile vinculado al Tren de Aragua - Bloomberg](https://www.bloomberg.com/news/articles/2026-06-02/detienen-a-ejecutivo-de-santander-chile-vinculado-al-tren-de-aragua) - [Investigación sobre el “Tren de Aragua” en Chile reaviva el debate sobre el secreto bancario](https://www.bloomberg.com/news/articles/2026-06-08/chile-debate-secreto-bancario-tras-caso-de-tren-de-aragua) - [Chile’s Tren de Aragua Probe Revives Bank Secrecy Debate - Bloomberg](https://www.bloomberg.com/news/articles/2026-06-08/chile-s-tren-de-aragua-probe-revives-bank-secrecy-debate) - [Santander Employee Is Arrested in Chile Tren de Aragua Sting - Bloomberg](https://www.bloomberg.com/news/articles/2026-06-02/santander-employee-is-arrested-in-chile-tren-de-aragua-sting) - [The Rapid Rise of Venezuela's 'Tren de Aragua' Gang ...](https://www.occrp.org/en/project/narcofiles-the-new-criminal-order/the-rapid-rise-of-venezuelas-tren-de-aragua-gang-leaves-destruction-and-death-in-its-wake) - [Lucha contra Tren de Aragua de Chile ofrece lección a EE.UU. - Bloomberg](https://www.bloomberg.com/news/articles/2025-01-29/lucha-contra-tren-de-aragua-de-chile-ofrece-leccion-a-ee-uu) - [Chile Touts Experience Fighting Tren de Aragua to Win Over Trump - Bloomberg](https://www.bloomberg.com/news/articles/2025-01-29/president-trump-needs-chile-in-fight-against-venezuelan-gangs) - [Colombia detiene a presunto líder de la pandilla Tren de Aragua - Bloomberg](https://www.bloomberg.com/news/articles/2024-07-01/colombia-detiene-a-presunto-lider-de-la-pandilla-tren-de-aragua) - [Colombia Detains Alleged Leader of Venezuela Gang Tren de Aragua](https://www.bloomberg.com/news/articles/2024-07-01/tren-de-aragua-leader-larry-changa-detained-in-colombia) - [Chile Is Fighting Tren de Aragua, Gang Violence as Xenophobia Grows - Bloomberg](https://www.bloomberg.com/news/articles/2024-10-30/chile-is-fighting-tren-de-aragua-gang-violence-as-xenophobia-grows) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [High-Risk Jurisdictions subject to a Call for Action - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-june-2026.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [Outcomes FATF Plenary, 17-19 June 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-fatf-plenary-june-2026.html) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [News](https://www.fatf-gafi.org/en/the-fatf/news.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html) - [Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Finance Deficiencies | FinCEN.gov](https://www.fincen.gov/news/news-releases/financial-action-task-force-identifies-jurisdictions-anti-money-laundering-5) - [Guía de Cumplimiento para Pequeñas Entidades](https://www.fincen.gov/sites/default/files/shared/BOI_Small_Compliance_Guide-en_us-spanish_September_508C.pdf) - [Reporte de información de beneficiarios finales](https://www.fincen.gov/sites/default/files/shared/BOI-FAQs-Q&A-09.28.23-Spanish-508C.pdf) - [Red de Control de Delitos Financieros Departamento del Tesoro de EE. UU.](https://www.fincen.gov/system/files/shared/BOI_Small_Compliance_Guide-en_us-spanish_September_508C.pdf) - [VERSIÓN 1 - PUBLICADA EL 3/24/23 Red de cumplimiento de delitos financieros](https://www.fincen.gov/system/files/shared/BOI_Reporting_Key_Questions_Spanish_508C.pdf) - [Digital finance - consilium.europa.eu](https://www.consilium.europa.eu/en/policies/digital-finance/) - [Proyecto de Real Decreto por el que se desarrolla la Ley ...](https://technical-regulation-information-system.ec.europa.eu/es/notification/25464/print) - [Departamento de Asuntos Económicos y Sociales División de Estadística](https://unstats.un.org/UNSDWebsite/nqaf/NQAF-Manual-Spanish.pdf) - [THEMATIC COMPILATION OF RELEVANT INFORMATION SUBMITTED BY CHILE](https://www.unodc.org/documents/corruption/WG-Prevention/Art_10_Transparency_and_integrity_in_public_administration/Chile.pdf) - [Transparencia retributiva en la UE - Consilium.europa.eu](https://www.consilium.europa.eu/en/policies/pay-transparency/) - [Introducción al reporte de información de beneficiarios ...](https://www.fincen.gov/system/files/shared/2024_BOI_Informational_Brochure_es.pdf) - [Cómo la Ley de Servicios Digitales mejora la transparencia ...](https://digital-strategy.ec.europa.eu/en/policies/dsa-brings-transparency) - [Due diligence explained - Internal Market, Industry, Entrepreneurship and SMEs](https://single-market-economy.ec.europa.eu/sectors/raw-materials/due-diligence-ready/due-diligence-explained_en) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [Commission adds Russia to list of high-risk jurisdictions to strengthen international fight against financial crime](https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2910) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [Anti-Money Laundering and Terrorist Financing Directive 4 - Finance](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en) - [Protecting the EU’s financial system - Finance - European Commission](https://finance.ec.europa.eu/news/protecting-eus-financial-system-2025-07-16_en) - [FATF (in conjunction with GAFILAT)](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Merchile.html) - [Government of Chile (Ley 19.913), hosted via UNODC](https://www.unodc.org/cld/uploads/res/document/chl/2005/ley_num__19_913_que_crea_la_unidad_de_analisis_financiero_y_modifica_diversas_disposiciones_en_materia_de_lavado_y_blanqueo_de_activos_html/Chile_Ley_Num_19.913.pdf) - [UNODC / UNCAC Implementation Review Mechanism (Chile country report)](https://track.unodc.org/uploads/documents/UNCAC/CountryVisitFinalReports/2025_05_22_Chile_Cycle_II_Country_Report_SP.pdf) - [Government of Chile (Política Nacional contra el Crimen Organizado)](https://www.unodc.org/cld/es/treaties/strategies/chile/chl0004s.html) - [U.S. Department of the Treasury, OFAC](https://ofac.treasury.gov/recent-actions/20251203) - [Bloomberg](https://www.bloomberg.com/news/articles/2026-06-08/chile-s-tren-de-aragua-probe-revives-bank-secrecy-debate) - [Bloomberg](https://www.bloomberg.com/news/articles/2026-04-08/chile-uncovers-917-million-copper-theft-ring-shipping-to-china) - [Chainalysis](https://www.chainalysis.com/blog/latin-america-crypto-adoption-2025/) - [European Commission (DG FISMA)](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) Coverage gaps fim-int-2026-07-08-G001: No confirmation was located of how … fim-int-2026-07-08-G001: No confirmation was located of how UAF oversight or prosecutorial subpoena powers interact with Chile's bank-secrecy statute, leaving the structural scope of the secrecy-driven AML blind spot unconfirmed beyond the Santander case. [resolved] fim-int-2026-07-08-G002: No primary-source confirmation of a… fim-int-2026-07-08-G002: No primary-source confirmation of a centralized, verified beneficial-ownership register for Chilean legal persons was located, beyond the UNCAC review's note of reliance on general transparency-of-public-administration law. [resolved] fim-int-2026-07-08-G003: Direct CMF (Comision para el Mercad… fim-int-2026-07-08-G003: Direct CMF (Comision para el Mercado Financiero) primary-source material on VASP registration status, RegTech/SupTech adoption, or perpetual-KYC initiatives could not be located within the research window. [resolved] fim-int-2026-07-08-G004: Chile's slot in the FATF/GAFILAT 5t… fim-int-2026-07-08-G004: Chile's slot in the FATF/GAFILAT 5th-round (2022 Methodology) mutual evaluation sequence has not been confirmed against the assessment calendar. [resolved] fim-int-2026-08-05-G001: No conflict-finance findings (Sahel… fim-int-2026-08-05-G001: No conflict-finance findings (Sahel, DRC, oil-revenue corruption) were located this cycle; the D4 domain is flagged as thin coverage rather than inferred quiet. [resolved] fim-int-2026-08-05-G002: No compliance-technology/RegTech de… fim-int-2026-08-05-G002: No compliance-technology/RegTech developments beyond Chile's CMF conduct framework were located this cycle. [resolved] fim-int-2026-08-05-G003: EU AML Package (AMLR/6AMLD/AMLA) in… fim-int-2026-08-05-G003: EU AML Package (AMLR/6AMLD/AMLA) instrument-level transposition delta not established this cycle. [resolved] fim-int-2026-08-05-G004: Colombia: no material current-cycle… fim-int-2026-08-05-G004: Colombia: no material current-cycle finding located in the Tier D mandatory sweep. [resolved] fim-int-2026-08-05-G005: Primary NBC/US DOJ corroboration of… fim-int-2026-08-05-G005: Primary NBC/US DOJ corroboration of the Prince Bank liquidation was not independently retrieved; single Tier-4 aggregator source only. [resolved] fim-int-2026-10-04-G001: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-10-04-G001: Tier D jurisdictions (KH, LA, MX, CO) were not actively refreshed this cycle; research effort was concentrated on the CL-bound scope of this run. [resolved] fim-int-2026-10-04-G002: CMF's own press-release URL for the… fim-int-2026-10-04-G002: CMF's own press-release URL for the 2026-09-06 alert was not independently retrieved this cycle; only secondary (T4) reporting was found. [resolved] fim-int-2026-10-04-G003: D1, D2, D3, D4 and D6 had thin cove… fim-int-2026-10-04-G003: D1, D2, D3, D4 and D6 had thin coverage this cycle; research effort was concentrated on D5 and D7 CL-specific signals. [resolved] fim-int-2026-10-11-G001: Tier D jurisdiction collection (Cam… fim-int-2026-10-11-G001: Tier D jurisdiction collection (Cambodia, Laos, Mexico, Colombia) was out of scope for this CL-bound dispatch and not actively searched this cycle. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): GAFILAT Fifth Round methodology and Chile's confirmed evaluation slot remain unpublished; preliminary 2031 estimate is from an older UAF planning document, not reconfirmed this cycle. [resolved] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): No Chile-specific sanctions designations, delistings or general licences located this cycle; D1/D2/D3/D4/D6 global sweep returned thin coverage for this jurisdiction. [resolved] fim-int-2026-10-25-G001: D1-D6 and D8 domain sweeps for CL w… fim-int-2026-10-25-G001: D1-D6 and D8 domain sweeps for CL were not performed this cycle; budget was concentrated on D7, so absence of findings there should not be read as no-material-change for those domains. [open] fim-int-2026-10-25-G002: Tier D jurisdiction watch (KH/LA/MX… fim-int-2026-10-25-G002: Tier D jurisdiction watch (KH/LA/MX/CO) was not researched this cycle as the run was bound to a single JID (CL). [open] fim-int-2026-10-25-G003: No primary UAF notice of a new inst… fim-int-2026-10-25-G003: No primary UAF notice of a new instrument was located this cycle to corroborate the T4 automotive-sector training article; confidence capped at Probable. [open] fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): CMF's own Official Letter 101082 text was not directly retrieved this cycle; crypto-asset classification claim rests on secondary legal commentary only. [open] fim-int-2026-11-08-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-08-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): UAF's own Circular N°62 text was not directly retrieved this cycle; sanction-tier figures rest on secondary trade-press reporting only. [open] fim-int-2026-11-08-G003: Tier D jurisdiction watch (KH, LA, … fim-int-2026-11-08-G003: Tier D jurisdiction watch (KH, LA, MX, CO) was not researched this cycle because this run was bound to the single jurisdiction CL under the union dispatch. [open] FIM-GAP-001 (D2): Chile's bank-secrecy protections, describe… FIM-GAP-001 (D2): Chile's bank-secrecy protections, described in reporting as among the strictest in the world, reportedly allowed an $85 million laundering network to operate undetected for years using an insider at a major bank, indicating the secrecy regime outpaces AML monitoring capability. FIM-GAP-002 (D2): Chile's UNCAC Cycle II country review (202… FIM-GAP-002 (D2): Chile's UNCAC Cycle II country review (2025) notes Chile lacks a dedicated international criminal-cooperation statute, relying instead on the Penal Code, Criminal Procedure Code, bilateral treaties and reciprocity, and does not describe a centralized public beneficial-ownership register comparable to post-2020 EU/US standards. FIM-GAP-003 (D6): This baseline was unable to locate direct … FIM-GAP-003 (D6): This baseline was unable to locate direct primary-source material from Chile's Comisión para el Mercado Financiero (CMF) on virtual-asset-service-provider registration status, RegTech/SupTech supervisory adoption, or perpetual-KYC initiatives within the research window; findings rely on UNODC-hosted legislative texts, FATF/GAFILAT documents, and Tier-2 investigative/financial press. ## Evidence #### Confidence-tiered claims Public alert naming SUXXESS FX LTD and a Bakkt-impersonating platform as unregistered and unauthorised to provide regulated financial services in Chile [[Source 1]](#sec-sources) Probable · 1 source CMF Resolucion Exenta N6825 (25 June 2026) cancelled the RPSF registration; prosecutors link the platform to a Tren de Aragua laundering network moving over USD 84 million through stablecoins [[Source 1]](#sec-sources) Probable · 1 source Ley N19.913 (UAF), as amended by Ley 20.818 and Ley 21.732; UAF Circular N62 (19 March 2026) consolidates AML/CFT/CPF supervisory instructions [[Source 1]](#sec-sources) Probable · 1 source Not on the FATF increased-monitoring list following the 19 June 2026 plenary [[Source 1]](#sec-sources) Probable · 1 source No centralised public beneficial-ownership register exists; a SII-administered BO register bill (10% ownership threshold) has been introduced to Congress but not enacted [[Source 1]](#sec-sources) Probable · 1 source If enacted, online-betting-platform operators (PAL) would become new UAF-obliged reporting entities with beneficial-ownership and source-of-funds disclosure duties [[Source 1]](#sec-sources) Probable · 1 source Risk-based AML/CFT/CPF approach for Chile's 25 licensed casinos, entered force 1 October 2026 [[Source 1]](#sec-sources) Probable · 1 source Circular N63 introduces mandatory Comite de Prevencion and reinforced Compliance Officer function for casino operators [[Source 1]](#sec-sources) Probable · 1 source UAF officials participated in GAFILAT Fifth Round preparatory/strategic-commission sessions in Honduras, late September 2026 [[Source 1]](#sec-sources) Probable · 1 source Remained in CMF registration/authorisation process ('en tramite') as of 6 October 2026, not yet fully authorised PSAV [[Source 1]](#sec-sources) Probable · 1 source Closed a US$5.2m seed round led by Credicorp's Krealo venture arm for digital factoring business [[Source 1]](#sec-sources) Probable · 1 source UAF is FIU and AML/CFT supervisor for sujetos obligados under Ley N°19.913 Art. 3 [[Source 1]](#sec-sources) Probable · 1 source 917 UAF-obliged financial-sector entities must hold an internal beneficial-ownership register of clients, in force since 1 October 2026 [[Source 1]](#sec-sources) Probable · 1 source Automotive sector (car dealers, rental firms) trained on existing Circular N°62 AML/CFT obligations; UAF data shows 73.9% of 2019-2023 money-laundering convictions involved vehicle-market transactions; 471 automotive entities are UAF-obliged [[Source 1]](#sec-sources) Probable · 1 source Crypto-assets are financial instruments for the purposes of Ley Fintec (Ley 21.521); a self-custody wallet where the provider does not control private keys is not custody. [[Source 1]](#sec-sources) Probable · 1 source UAF Circular N°62 consolidates AML/CFT/CPF instructions: 5-year record retention, annual staff training, and administrative sanctions tiered minor (up to 800 UF), less-serious (up to 3,000 UF), serious (up to 5,000 UF), triplable on repetition. Automotive sector flagged as disproportionate laundering vector (73.9% of 2019-2023 convictions). [[Source 1]](#sec-sources) Probable · 1 source Confirmed UAF written-warning-plus-40-UF-fine sanction against a remittance firm for AML/CFT programme failures (Rol N°249-2025, Contencioso Administrativo). [[Source 1]](#sec-sources) Uncertain · 1 source