--- title: "Peru (PE) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/peru-pe/ source_html: /jurisdictions/peru/index.html description: "Financial integrity intelligence for Peru (PE): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T22:34:26Z content_sha256: 4986f55f751c888fd5ec042e25f6ecd889aa18b819343cf0a0791673b0767718 generator: "fe-fleet/md-twin@1.0" --- # Peru (PE) — 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 # Peru PE Domains covered 8 of 8 Sources 170 Role actions 8 Horizon <90d 2 Jurisdiction profile FATF status: Clean Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed AML/CFT architecture centres on SBS's Unidad de Inteligencia Financiera (UIF-Perú), Law 26702 (Financial System Law) and CONTRALAFT coordination. More Peru underwent a 2018 GAFILAT/FATF on-site evaluation (MER published 2019, FUR 2020). Lawyers, accountants and cooperativas remain weakly supervised; no VASP-specific AML statute exists. Key deficiencies - Lawyers and accountants not yet brought under effective AML/CFT supervision - Beneficial ownership information access and quality gaps for legal persons/arrangements - Risk-based supervision of credit cooperatives (CACs) underdeveloped - No VASP-specific licensing or mandatory AML regime for crypto exchanges - Weak TF investigation capacity and limited common understanding of TF risk across competent authorities - Judicial precedent (2025) constraining criminal investigation of a sitting president Recent developments (18m) - Ollanta Humala and Nadine Heredia sentenced to 15 years for Odebrecht-linked money laundering (April 2025) - Constitutional Tribunal ruling halting all criminal probes against sitting President Boluarte (August 2025) - President Boluarte impeached and removed (October 2025); successor José Jerí removed four months later (February 2026) - Record ~4-tonne mercury seizure targeting illegal gold-mining supply chains (reported July 2025) - APCI Law (April 2025) expanding state oversight of NGOs receiving foreign funding - Contested 2026 presidential runoff under electoral-court review as of mid-2026, with interim President Balcázar in office Brief ## Lead signal #### Lead Signal Peru's financial-crime architecture moved this cycle on a single, structurally significant axis: the gradual widening of the anti-money-laundering obliged-entity perimeter administered by the SBS through its financial intelligence unit, UIF-Peru. The supervisory authority opened a public comment period, closing 14 November 2026, on a draft rule that would formalise customer due diligence, compliance-manual, prevention-code, suspicious-transaction-reporting and annual compliance-officer obligations for entities that already sit within UIF-Peru's informal reporting net but outside the SBS's direct banking-sector perimeter. This is best read as the latest increment in a sequence that began in March 2025 with cash and securities carriers, continued in May 2025 with fund managers and factoring companies, and extended again in May 2026 to leasing companies. Peru is not overhauling its AML regime through a single comprehensive statute; it is closing gaps sector by sector, each addition narrowing the space in which unregulated financial activity can sit outside reporting obligations. Read full brief #### Lead Signal Peru's financial-crime architecture moved this cycle on a single, structurally significant axis: the gradual widening of the anti-money-laundering obliged-entity perimeter administered by the SBS through its financial intelligence unit, UIF-Peru. The supervisory authority opened a public comment period, closing 14 November 2026, on a draft rule that would formalise customer due diligence, compliance-manual, prevention-code, suspicious-transaction-reporting and annual compliance-officer obligations for entities that already sit within UIF-Peru's informal reporting net but outside the SBS's direct banking-sector perimeter. This is best read as the latest increment in a sequence that began in March 2025 with cash and securities carriers, continued in May 2025 with fund managers and factoring companies, and extended again in May 2026 to leasing companies. Peru is not overhauling its AML regime through a single comprehensive statute; it is closing gaps sector by sector, each addition narrowing the space in which unregulated financial activity can sit outside reporting obligations. Sitting alongside this incremental expansion, the standing AML/CFT regime for remote-gaming and online sports-betting platforms, established by Resolucion SBS No. 01015-2026 on 8 April 2026, continues unchanged: a SPLAFT prevention system, twenty-four-hour suspicious-transaction-report filing to UIF-Peru, with supervisory and sanctioning authority resting with MINCETUR's gaming directorate rather than with the SBS itself. That bifurcation of supervisory authority between a financial regulator that sets the AML standard and a sectoral regulator that enforces it is itself a structural feature worth noting, since it creates a dependency on MINCETUR's enforcement capacity that the SBS rule alone cannot guarantee. #### Other Developments No listing action from the Financial Action Task Force. The FATF's 28-30 October 2026 plenary removed four jurisdictions from its increased-monitoring list and added none; Peru was not named on either the increased-monitoring or the call-for-action list at this plenary, consistent with its standing position outside both. Peru's most recent mutual evaluation under the regional FATF-style body for Latin America remains the report adopted in 2018, meaning the country's last comprehensive external assessment is now several years old even as its domestic rulemaking continues to evolve. Crypto legislative track stays dormant. The comprehensive virtual-asset bill, PL 1042/2021-CR, remains in committee, where it has sat since the plenary returned it in March 2025, with no new crypto-specific legislative initiative registered since the bicameral Congress was installed in July 2026. The only operative control in this space remains the AML Travel Rule chapter that entered into force on 1 August 2026, leaving Peru with a partial, obligation-specific crypto framework rather than a licensing regime. #### Cross-Monitor Connections The sectoral widening of AML obligated-entity status intersects directly with payments-sector oversight: several of the entities likely to fall within the scope of the draft UIF-Perou rule, including payment facilitators and fund-related intermediaries, are the same firms whose conduct and safeguarding obligations are being reshaped in parallel by the central bank's payment-acceptance rulemaking. A firm newly brought within AML reporting duties under the SBS's sectoral approach is simultaneously subject to tightening safeguarding and licensing requirements from a separate regulator, and the cumulative compliance burden on non-bank payment entities in Peru is rising from two directions at once rather than one. The stalled state of the comprehensive crypto bill also bears on conflict-finance and extractive-industry monitoring to the extent that virtual-asset flows remain governed only by a narrow Travel Rule obligation rather than a full licensing and supervision regime, leaving a structural gap in oversight capacity for that sector. #### Outlook The SBS comment period closes 14 November 2026, after which the draft rule is expected to move toward finalisation; whether the resulting instrument retains the full scope of CDD, prevention-code and reporting duties as drafted, or is narrowed during the comment process, will determine how much of the informally-supervised sector actually enters formal AML obligation. The crypto bill's prospects remain uncertain, with no indication of near-term revival in the newly installed Congress. Peru's position outside the FATF increased-monitoring list is not expected to change before the next plenary cycle absent a material deterioration in its AML/CFT implementation record, though the now-stale 2018 mutual evaluation leaves an evidentiary gap regarding the country's current effectiveness. Earlier periodic briefs (6) 8 Nov 2026 · fim-2026-11-08 #### Lead Signal Peru's financial-crime architecture moved on a single, structurally significant axis: the gradual widening of the anti-money-laundering obliged-entity perimeter administered by the SBS through its financial intelligence unit, UIF-Peru. The supervisory authority opened a public comment period, closing 14 November 2026, on a draft rule that would formalise customer due diligence, compliance-manual, prevention-code, suspicious-transaction-reporting and annual compliance-officer obligations for entities that already sit within UIF-Peru's informal reporting net but outside the SBS's direct banking-sector perimeter. This is best read as the latest increment in a sequence that began in March 2025 with cash and securities carriers, continued in May 2025 with fund managers and factoring companies, and extended again in May 2026 to leasing companies. Peru is not overhauling its AML regime through a single comprehensive statute; it is closing gaps sector by sector, each addition narrowing the space in which unregulated financial activity can sit outside reporting obligations. Sitting alongside this incremental expansion, the standing AML/CFT regime for remote-gaming and online sports-betting platforms, established by Resolucion SBS No. 01015-2026 on 8 April 2026, continues unchanged: a SPLAFT prevention system, twenty-four-hour suspicious-transaction-report filing to UIF-Peru, with supervisory and sanctioning authority resting with MINCETUR's gaming directorate rather than with the SBS itself. That bifurcation of supervisory authority between a financial regulator that sets the AML standard and a sectoral regulator that enforces it is itself a structural feature worth noting, since it creates a dependency on MINCETUR's enforcement capacity that the SBS rule alone cannot guarantee. #### Other Developments No listing action from the Financial Action Task Force. The FATF's 28-30 October 2026 plenary removed four jurisdictions from its increased-monitoring list and added none; Peru was not named on either the increased-monitoring or the call-for-action list at this plenary, consistent with its standing position outside both. Peru's most recent mutual evaluation under the regional FATF-style body for Latin America remains the report adopted in 2018, meaning the country's last comprehensive external assessment is now several years old even as its domestic rulemaking continues to evolve. Crypto legislative track stays dormant. The comprehensive virtual-asset bill, PL 1042/2021-CR, remains in committee, where it has sat since the plenary returned it in March 2025, with no new crypto-specific legislative initiative registered since the bicameral Congress was installed in July 2026. The only operative control in this space remains the AML Travel Rule chapter that entered into force on 1 August 2026, leaving Peru with a partial, obligation-specific crypto framework rather than a licensing regime. #### Cross-Monitor Connections The sectoral widening of AML obligated-entity status intersects directly with payments-sector oversight: several of the entities likely to fall within the scope of the draft UIF-Perou rule, including payment facilitators and fund-related intermediaries, are the same firms whose conduct and safeguarding obligations are being reshaped in parallel by the central bank's payment-acceptance rulemaking. A firm newly brought within AML reporting duties under the SBS's sectoral approach is simultaneously subject to tightening safeguarding and licensing requirements from a separate regulator, and the cumulative compliance burden on non-bank payment entities in Peru is rising from two directions at once rather than one. The stalled state of the comprehensive crypto bill also bears on conflict-finance and extractive-industry monitoring to the extent that virtual-asset flows remain governed only by a narrow Travel Rule obligation rather than a full licensing and supervision regime, leaving a structural gap in oversight capacity for that sector. #### Outlook The SBS comment period closes 14 November 2026, after which the draft rule is expected to move toward finalisation; whether the resulting instrument retains the full scope of CDD, prevention-code and reporting duties as drafted, or is narrowed during the comment process, will determine how much of the informally-supervised sector actually enters formal AML obligation. The crypto bill's prospects remain uncertain, with no indication of near-term revival in the newly installed Congress. Peru's position outside the FATF increased-monitoring list is not expected to change before the next plenary cycle absent a material deterioration in its AML/CFT implementation record, though the now-stale 2018 mutual evaluation leaves an evidentiary gap regarding the country's current effectiveness. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Peru's financial-intelligence unit extended its anti-money-laundering obliged-entity perimeter on two separate fronts this year, both reaching commencement or operational status in this reporting window. Resolución SBS N.° 01015-2026, effective 8 April 2026, replaced the 2016 AML rule governing physical casinos and slot machines with a single norm that for the first time brings MINCETUR-authorised remote-gaming and remote-sports-betting operators into the obliged-entity perimeter alongside their land-based counterparts, with a 24-hour no-threshold suspicious-transaction report requirement and an operations register triggered at USD 2,500 in cash exchanges. Separately, Chapter VIII of Resolución SBS N.° 02648-2024, the Travel Rule chapter governing virtual-asset service providers, entered into force on 1 August 2026 after a two-year transition period, requiring Proveedores de Servicios de Activos Virtuales to transmit originator and beneficiary information on virtual-asset transfers and to assess money-laundering and terrorist-financing risk on self-hosted-wallet transfers. Peru is not among the 22 jurisdictions on FATF's 19 June 2026 Jurisdictions under Increased Monitoring list. #### Other Developments A gambling-sector ownership change touches an AML-obliged entity. Cirsa, owner of Apuesta Total S.A., an SBS-regulated AML-obliged gambling operator in Peru, together with a wider casino network, agreed an all-share combination with Italy's Lottomatica S.p.A., signed 2 September 2026. No change to the Peru licensee's AML obligations was reported in connection with the transaction, but a beneficial-ownership chain change of this kind in an obliged entity's corporate structure is the kind of development that merits continued monitoring, both for its own sake and because Apuesta Total's standing as an obliged entity under Resolución SBS N.° 01015-2026 does not itself change with a change of ultimate ownership. Peru's crypto regime remains AML-only. No comprehensive crypto-licensing or authorisation regime exists in Peru; a virtual-asset service provider's only regulatory gateway is registration as a UIF-Perú obliged entity with a SPLAFT programme. The RUPIC crypto-exchange licensing bill, Proyecto de Ley N.° 1042/2021-CR, remains stalled in committee with no confirmed enactment timeline, meaning the newly operative Travel Rule duty currently sits on top of an AML-only framework rather than a prudential or conduct-licensing regime. #### Cross-Monitor Connections The gambling-sector AML extension (Resolución SBS N.° 01015-2026) is the same underlying development the advennt gambling monitor is tracking from a licensing and market-entry perspective, and the Travel Rule commencement (Resolución SBS N.° 02648-2024, Chapter VIII) is the same development the crypto monitor is tracking from a cross-border-transfer-regime perspective. Both instruments originate from the same supervisory authority, the SBS acting through UIF-Perú, and both extend AML obliged-entity status into sectors — remote gambling and virtual assets — that previously sat outside or only partially inside the formal AML perimeter. The Cirsa/Lottomatica combination is also a world-payments-adjacent commercial event insofar as it touches a payments-and-settlement-relevant gambling operator's ownership structure, though no payments-specific finding was identified. #### Outlook The primary gap to close is direct retrieval of the El Peruano gazette texts of both Resolución SBS N.° 01015-2026 and N.° 02648-2024; current confidence on both instruments' obligation detail is capped at Probable pending that primary-source verification, having relied on secondary aggregator and vendor reproductions. Separately, whether Proyecto de Ley N.° 1042/2021-CR advances out of committee in the period ahead would be the first step toward closing the licensing gap that currently leaves Peru's virtual-asset sector regulated only through its AML registration requirement. 12 Oct 2026 · fim-2026-10-12 #### Lead Signal Peru's financial-intelligence unit extended its anti-money-laundering obliged-entity perimeter on two separate fronts this year, both reaching commencement or operational status in this reporting window. Resolución SBS N.° 01015-2026, effective 8 April 2026, replaced the 2016 AML rule governing physical casinos and slot machines with a single norm that for the first time brings MINCETUR-authorised remote-gaming and remote-sports-betting operators into the obliged-entity perimeter alongside their land-based counterparts, with a 24-hour no-threshold suspicious-transaction report requirement and an operations register triggered at USD 2,500 in cash exchanges. Separately, Chapter VIII of Resolución SBS N.° 02648-2024, the Travel Rule chapter governing virtual-asset service providers, entered into force on 1 August 2026 after a two-year transition period, requiring Proveedores de Servicios de Activos Virtuales to transmit originator and beneficiary information on virtual-asset transfers and to assess money-laundering and terrorist-financing risk on self-hosted-wallet transfers. Peru is not among the 22 jurisdictions on FATF's 19 June 2026 Jurisdictions under Increased Monitoring list. #### Other Developments A gambling-sector ownership change touches an AML-obliged entity. Cirsa, owner of Apuesta Total S.A., an SBS-regulated AML-obliged gambling operator in Peru, together with a wider casino network, agreed an all-share combination with Italy's Lottomatica S.p.A., signed 2 September 2026. No change to the Peru licensee's AML obligations was reported in connection with the transaction, but a beneficial-ownership chain change of this kind in an obliged entity's corporate structure is the kind of development that merits continued monitoring, both for its own sake and because Apuesta Total's standing as an obliged entity under Resolución SBS N.° 01015-2026 does not itself change with a change of ultimate ownership. Peru's crypto regime remains AML-only. No comprehensive crypto-licensing or authorisation regime exists in Peru; a virtual-asset service provider's only regulatory gateway is registration as a UIF-Perú obliged entity with a SPLAFT programme. The RUPIC crypto-exchange licensing bill, Proyecto de Ley N.° 1042/2021-CR, remains stalled in committee with no confirmed enactment timeline, meaning the newly operative Travel Rule duty currently sits on top of an AML-only framework rather than a prudential or conduct-licensing regime. #### Cross-Monitor Connections The gambling-sector AML extension (Resolución SBS N.° 01015-2026) is the same underlying development the advennt gambling monitor is tracking from a licensing and market-entry perspective, and the Travel Rule commencement (Resolución SBS N.° 02648-2024, Chapter VIII) is the same development the crypto monitor is tracking from a cross-border-transfer-regime perspective. Both instruments originate from the same supervisory authority, the SBS acting through UIF-Perú, and both extend AML obliged-entity status into sectors — remote gambling and virtual assets — that previously sat outside or only partially inside the formal AML perimeter. The Cirsa/Lottomatica combination is also a world-payments-adjacent commercial event insofar as it touches a payments-and-settlement-relevant gambling operator's ownership structure, though no payments-specific finding was identified this cycle. #### Outlook The primary gap to close is direct retrieval of the El Peruano gazette texts of both Resolución SBS N.° 01015-2026 and N.° 02648-2024; current confidence on both instruments' obligation detail is capped at Probable pending that primary-source verification, having relied this cycle on secondary aggregator and vendor reproductions. Separately, whether Proyecto de Ley N.° 1042/2021-CR advances out of committee in the period ahead would be the first step toward closing the licensing gap that currently leaves Peru's virtual-asset sector regulated only through its AML registration requirement. 6 Oct 2026 · fim-2026-10-06 #### Lead Signal Peru's banking and insurance supervisor, the Superintendencia de Banca, Seguros y AFP (SBS), has pushed back the start date for travel-rule obligations under its virtual-asset AML/CTF framework by more than two years. SBS Resolution No. 01917-2026, published in the official gazette El Peruano, extends until 1 January 2029 the validity period before Chapter VIII of SBS Resolution No. 02648-2024 takes effect. That chapter, which transposes FATF Recommendation 16 into Peruvian rules for virtual asset service providers, banks, and payment companies, had previously been due to commence on 1 August 2026. The postponement is confirmed by a direct quotation from the gazetted resolution text and is treated as a Confirmed finding. The practical effect is a widened compliance runway for obliged entities that would otherwise have had to build originator and beneficiary information-transmission capability on the prior timeline. The deferral does not alter the substantive content of the travel-rule chapter, only when it becomes binding, and it leaves the remainder of Resolution No. 02648-2024 unaffected. #### Other Developments No material developments were identified this cycle in Sanctions Architecture and Evasion, Beneficial Ownership and Corporate Transparency, Enabler Jurisdictions and Professional Facilitators, Conflict Finance and Extractive-Industry Integrity, Crypto/Digital Assets and Financial Innovation, or Compliance Technology and Active Defence for Peru. Signal this cycle was confined to the AML/CTF Regime domain. #### Cross-Monitor Connections The travel-rule deferral is directly relevant to payments and crypto monitoring of Peru: any monitor tracking virtual-asset transfer obligations, correspondent exposure for payment companies, or VASP compliance timelines should treat 1 January 2029, not 1 August 2026, as the operative commencement date for originator and beneficiary information requirements under FATF Recommendation 16 as locally implemented. #### Outlook With the chapter's effectiveness now pushed to 1 January 2029, Peru's travel-rule architecture remains enacted but not yet operative for a materially longer period than originally scheduled. The structural question going into subsequent cycles is whether SBS uses the extended runway to issue implementing guidance or technical standards for the affected sectors, or whether the deferral itself becomes a recurring pattern. The exact publication date of the resolution within its El Peruano issue has not been independently confirmed from the gazette header, and that gap remains open. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal The International Monetary Fund has assessed illegal gold mining as Peru's most serious money-laundering risk, drawing on UIF-Peru (SBS) suspicious transaction report data tracked by province. Independent press estimates, attributed to the Instituto Peruano de Economia, put illegally-sourced gold at 54% of Peru's exported gold volume in the first half of 2026, with total 2026 gold exports estimated at USD 16 to 18 billion. This is an architecture finding rather than an incident: it describes a structural laundering channel running through artisanal mining, trade-based mis-invoicing at export, and commingling with legitimate production, not a single enforcement action. Against that structural backdrop, two narrower but concrete developments moved Peru's compliance perimeter this cycle. SUNAT Resolution No. 000168-2025/SUNAT, published 28 May 2025, sets a November 2026 deadline for more than 80,000 legal entities with prior-year income above 100 UIT to file the Beneficial Owner Affidavit under Legislative Decree 1372's beneficial-ownership regime. And Peru's crypto Travel Rule, under SBS Resolution No. 02648-2024 Chapter VIII, took effect 1 August 2026 after a two-year grace period, requiring virtual-asset service providers to obtain, retain and transmit originator and beneficiary information for virtual-asset transfers. #### Other Developments A Tier D mandatory global collection item surfaced during this cycle's search allocation. OFAC, coordinating with a Department of Justice Scam Center Strike Force, designated Cambodian senator Kok An and 28 affiliated entities tied to a casino-and-scam-compound network in Sihanoukville that laundered at least USD 73 million to United States-based co-conspirators. This finding carries no confirmed Peru nexus and is processed here as standing global signal rather than a jurisdiction-specific development. Peru's FATF standing remains unchanged. Peru does not appear on FATF's 19 June 2026 list of jurisdictions subject to a call for action, nor on the February 2026 increased-monitoring update that newly identified Kuwait and Papua New Guinea. Peru continues to be assessed under the GAFILAT framework, following the mutual evaluation conducted by GAFISUD. #### Cross-Monitor Connections The illegal gold mining finding is a natural point of contact for ERM's commodity-flow tracking, given the trade-based laundering mechanism identified by the IMF operates through export mis-invoicing in a physical commodity market. It also intersects with SCEM's extractive-industry integrity work to the extent that artisanal-mining criminal financing structures resemble patterns SCEM tracks in other jurisdictions. The crypto Travel Rule development connects to WDM's interest in state capacity to regulate emergent financial infrastructure, insofar as Peru's SBS has now closed a known two-year gap in its virtual-asset AML perimeter. #### Outlook The November 2026 beneficial-ownership filing deadline for more than 80,000 entities is the nearest concrete date to watch, and will test whether SUNAT's phased BO regime achieves meaningful compliance at scale. The illegal gold mining finding, being structural rather than episodic, is unlikely to resolve on any near-term date; the relevant indicator to track is whether Peru's illegal gold export share, currently estimated at 54% of H1 2026 volume, moves materially in either direction as full-year 2026 trade data becomes available. 21 Sep 2026 · fim-2026-09-05 #### Lead Signal Peru's crypto Travel Rule obligation under Chapter VIII of SBS Resolution 02648-2024 entered into force on 1 August 2026, closing the final phased obligation of the 2023-24 build-out that first brought Virtual Asset Service Providers (VASPs, locally PSAVs) into the AML/CFT perimeter as reporting entities. VASPs domiciled or incorporated in Peru, and Peru branches of foreign VASPs, must now apply FATF Recommendation 15/16-aligned originator and beneficiary information transmission to counterparties. This is a structural completion event rather than a new designation: the underlying reporting-entity obligation has existed since 2023-24, and the Travel Rule provision was always scheduled to take effect after a two-year grace period. The obligation applies specifically to originator and beneficiary information transmission modelled on FATF Recommendations 15 and 16, and its entry into force closes a gap that had been visible since the underlying SBS resolution was issued, giving VASPs a defined two-year runway to build compliant transmission infrastructure. Whether smaller domestic PSAVs have in practice built out compliant systems ahead of the 1 August deadline is not yet confirmed in the evidence base for this cycle, and should be treated as an open operational question rather than an assumed compliance outcome. The architectural significance is that Peru's AML perimeter for digital assets is now fully phased in on the transactional-transparency dimension, even as the country's broader crypto market-conduct and licensing regime remains entirely unaddressed: the Framework Law for the Commercialization of Cryptoassets (Bill 1042/2021-CR), which would create a formal VASP registration regime (RUPIC), has sat in committee without an enactment timeline since March 2025. #### Other Developments Remote-gambling operators onboarded as AML/CFT obligated subjects. Peru's SBS approved a dedicated AML/CFT compliance framework for online-gambling and remote-betting operators, designating them obligated subjects that must report suspicious transactions to UIF-Perú, with a 120-day implementation window. Licensing competence for the sector remains with MINCETUR; this development extends the AML obligated-entity perimeter beyond traditional financial institutions and DNFBPs into a licensed non-financial sector for the first time in this cycle's evidence base. The 120-day implementation window means full operational compliance is not due until roughly November-December 2026, giving both the regulator and the newly designated sector a defined runway; the practical effectiveness of gambling-sector suspicious-transaction reporting to UIF-Perú, once the window closes, is a natural item to revisit. OFAC SDN-list consolidation retains Peru-linked designations. OFAC's 27 July 2026 notice consolidated eighteen duplicate SDN entries; Peru-linked narco-trafficking designations under the Aero Continente network (Winston Ricardo Zevallos Gonzales) remain listed and blocked. This is administrative deduplication rather than a new designation or a delisting, and should not be read as a substantive sanctions-posture shift. Because this is a consolidation of existing entries rather than a new listing, it carries limited independent evidentiary weight for assessing any shift in the underlying sanctions relationship, and is logged here principally for completeness of the standing sanctions-tracker record. Reported UBO record-keeping tightening remains uncorroborated. A single tier-4 commercial-advisory source describes a 2025 AML regulatory amendment requiring suspicious-transaction-report filing above USD 10,000 or for high-risk-jurisdiction exposure, a designated compliance officer above PEN 3 million revenue, and an annually-filed beneficial-ownership register with SUNAT. No fully public UBO registry exists in Peru as of this cycle, and this finding has not been corroborated against a primary SBS or SUNAT text. If corroborated, the reported thresholds would represent a meaningful tightening of Peru's beneficial-ownership architecture relative to the pre-2025 baseline; if not corroborated, the finding should be treated as commercial-advisory market colour rather than a regulatory fact. #### Cross-Monitor Connections The remote-gambling AML onboarding intersects directly with Advennt's licensing and regulation tracking of MINCETUR's parallel enforcement intensification in the same sector, though the two consumers read different dimensions of the same underlying regulatory moment: FIM's interest is in the obligated-subject designation and reporting line to UIF-Perú, while Advennt's is in licensing and platform-level enforcement. The Travel Rule entry into force and the stalled framework crypto bill are the same underlying facts read by the crypto monitor through a licensing-and-token-classification lens; FIM's D5 framing foregrounds the AML-perimeter-completion angle rather than the absence of a market-conduct regime. This divergence in framing across consumers is expected and intentional: each monitor foregrounds the reading of the same underlying claim set most relevant to its own institutional audience, without introducing any claim not already present in the shared evidence base. No World Payments Monitor nexus is identified this cycle beyond the general observation that Peru's payments-regulation modernisation and its AML build-out are proceeding on separate, non-integrated tracks. #### Outlook The near-term outlook is one of AML-perimeter maturation without market-conduct formalisation. The stalled framework crypto bill remains the single variable that would most change Peru's D5 posture if enacted, introducing a formal RUPIC registration regime; absent that, the current cycle's completion of the Travel Rule obligation is likely the last structural AML milestone for the sector for some time. On D7, continued GAFILAT mutual-evaluation exposure and the absence of FATF grey-listing pressure suggest Peru's AML/CFT architecture is being assessed as adequate at the regional level, though the sector-by-sector expansion of obligated-subject status (most recently to remote gambling) signals a broadening rather than a deepening of the compliance perimeter. On D2, the primary gap to watch is corroboration of the reported UBO record-keeping amendment against a primary SBS or SUNAT text; until that corroboration exists, this finding should be treated as a weak signal rather than a settled development. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Peru's sanctions-architecture exposure this cycle is defined not by any Peru-specific listing action but by an asymmetric expansion of US authority over the hemispheric trafficking corridors that pass through the country. OFAC's implementation of Executive Order 14157 in January 2025 designated major international cartels as Foreign Terrorist Organizations and Specially Designated Global Terrorists, an aggressive extension of extraterritorial reach over counter-narcotics networks that touch Peru's VRAEM coca-growing economy. No equivalent blanket EU or UK designation exists, and this divergence is the structural finding: institutions handling Peru-linked correspondent flows now face materially different screening obligations depending on whether they sit under US jurisdiction or under EU/UK regimes, creating an arbitrage and compliance-friction surface that did not previously exist at this scale. Continue reading The underlying financing activity that gives this designation architecture its relevance is the continued operation of Sendero Luminoso remnants across the VRAEM, Alto Huallaga and Aguaytia river basins, where insurgent elements tax coca-paste production and trafficking routes. Proceeds move through cash smuggling and informal exchange networks before reaching formal financial channels, meaning the terrorism-financing risk is largely invisible to transaction monitoring until funds are already layered. This is a CTF-pillar finding that sits alongside, and is reinforced by, the AML-pillar gold-laundering architecture documented under D4: the same VRAEM-adjacent geography and informal-exchange infrastructure that services narco-terrorism financing also services drug-trafficking-linked TBML more broadly, suggesting a shared enabling infrastructure of cash smuggling and informal exchange rather than two unrelated schemes. The absence of Peru itself from any sanctions list, combined with the presence of active, evidenced financing infrastructure inside its borders, illustrates the standing FIM principle that non-enforcement in a jurisdiction is itself a signal worth surfacing. Peru is not a sanctioned jurisdiction, is not the subject of the OFAC action, and has no domestic sanctions-evasion designation of its own; the sanctions-architecture story here is entirely about a foreign regulator's extraterritorial posture creating downstream compliance consequences for flows that touch Peru, not about any Peruvian institution or entity being targeted. This distinction matters for institutions assessing correspondent-banking risk: the compliance burden is generated by US policy choice, not by a Peru-specific enforcement gap, though the underlying terrorism-financing activity the designation responds to is real and evidenced independently by UK, OFAC and UNODC sourcing. The practical effect for financial institutions is a widening screening-obligation gap. A US-regulated institution processing Peru-linked correspondent flows must now screen against a broader FTO/SDGT cartel designation set than an EU or UK counterpart handling the same underlying flow, absent an equivalent blanket designation on the other side of the Atlantic. This is not merely an academic divergence; it creates the potential for regulatory arbitrage where flows are routed through jurisdictions with the less aggressive screening posture, and it places pressure on global institutions to apply the more conservative (US) standard across their book to avoid secondary-sanctions exposure, even where no formal legal requirement to do so exists outside US jurisdiction. #### Outlook The sanctions-architecture divergence affecting Peru-linked flows is unlikely to close in the near term absent a coordinated EU/UK cartel-designation initiative, which is not currently signalled in available sourcing. The more immediate near-term variable is political rather than regulatory: Peru's contested 2026 presidential runoff, under electoral-court review with a transition expected around 28 July 2026, will determine whether counter-narcotics and counter-terrorism-financing enforcement priorities continue with any institutional continuity, given the pattern of four presidential removals since 2018. Illustratively, continued instability in VRAEM-adjacent institutional capacity would tend to reinforce, rather than close, the gap between the informal cash-based financing layer and any formal screening regime built to catch it, regardless of how aggressively that regime is designed on paper. Judgment: No Peru-nexus sanctions-architecture signal found this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency As a non-EEA jurisdiction, Peru sits entirely outside the EU AML Package's direct perimeter: the AML Regulation (AMLR, Regulation (EU) 2024/1624) and the sixth AML Directive (6AMLD) apply within the EU and to EU member-state transposition respectively, while the AMLA Regulation (Reg (EU) 2024/1620) establishes direct and indirect supervisory authority over obliged entities that is likewise confined to the EU's own institutional perimeter. Peru interfaces with this architecture only indirectly, as a potential subject of the EU's third-country high-risk list, on which it does not currently appear. The directly relevant beneficial-ownership story for Peru this cycle is domestic and FATF-adjacent rather than EU-adjacent: Peru remains absent from both the February and June 2026 FATF Jurisdictions Under Increased Monitoring statements, even as GAFILAT's follow-up process continues to flag unresolved beneficial-ownership information quality and DNFBP supervision deficiencies first identified in the 2019 mutual evaluation. Continue reading That divergence, between clean formal listing status and persistent underlying technical-compliance gaps, is the structural core of Peru's D2 exposure. The gaps are not abstract: Peru's mutual evaluation found that beneficial-ownership information access and quality for legal persons and arrangements remains deficient, compounded by the absence of AML supervision over the lawyers and accountants who frequently structure legal-person formations. This is precisely the kind of gap that produced the campaign-finance opacity underlying the now-finalised conviction of former President Ollanta Humala and his wife Nadine Heredia, sentenced to 15 years in prison and ordered to pay civil damages of approximately 2.7 million dollars for aggravated money laundering linked to Odebrecht and Venezuela-linked campaign contributions. The conviction is a definitive enforcement outcome, corroborated across ICIJ and Bloomberg reporting, but it resolves one historical instance of illicit-enrichment layering through electoral-finance vehicles without touching the structural DNFBP and beneficial-ownership supervision gap that made the underlying opacity possible in the first place. Globally, the EU AML Package sets the structural direction that most jurisdictions with EU-adjacent trade or correspondent-banking relationships will eventually have to account for, as AMLA's move toward direct and indirect supervision of cross-border obliged entities reshapes the baseline expectation for beneficial-ownership transparency worldwide. For Peru specifically, however, the currently relevant developments are the FATF/GAFILAT technical-compliance track and the domestic enforcement record, not EU transposition status, which simply does not apply to a non-EEA third country absent a high-risk-list designation. #### Outlook The medium-term horizon for Peru's beneficial-ownership posture turns on the ongoing GAFILAT follow-up process, expected to continue re-assessing progress on beneficial-ownership information quality and DNFBP supervision deficiencies into 2027, a trajectory currently assessed as improving in direction but unconfirmed in timing. Whether this technical-compliance track eventually produces a formal listing change, in either direction, or Peru continues to sit in the gap between clean FATF status and unresolved GAFILAT findings, is the central question to track. Political continuity matters here too: the outcome of Peru's contested 2026 presidential transition will shape whether any legislative closure of the DNFBP and beneficial-ownership gaps becomes a realistic near-term prospect or remains indefinitely deferred amid institutional turnover. Judgment: No Peru-specific beneficial-ownership development identified this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators Peru's enabler-jurisdiction profile worsened materially this cycle on the strength of a political-institutional development that sits squarely in state-capture-adjacent territory. Peru's Constitutional Tribunal ruled to halt all ongoing criminal probes against sitting President Boluarte, spanning illegal enrichment, abandonment of post and homicide allegations, establishing a durable judicial precedent that insulates the executive from prosecution during tenure. This is not a private-actor evasion story; it is the state institution itself creating an accountability gap, and the precedent persists independent of any single administration, meaning future office-holders inherit the same shield regardless of their own conduct. The ruling followed and preceded further turnover: Boluarte was impeached and removed by Congress in October 2025, and her successor Jose Jeri was himself removed within four months, in February 2026, extending a pattern of four presidential removals since 2018 that repeatedly disrupts continuity of anti-corruption enforcement and prosecutorial independence. Continue reading This institutional volatility compounds a structural DNFBP-supervision gap that Peru's 2019 mutual evaluation identified and that GAFILAT follow-up continues to track: the absence of AML supervision over money-changers, notaries, lawyers and accountants creates exploitable space for professional facilitation of illicit flows. A cross-border money-exchange-house laundering corridor illustrates this gap in practice, with drug-trafficking proceeds moved through corrupted money-exchange houses across Peru, Argentina, Uruguay and wider Europe, layered through sham companies and real estate targeting Italy in particular. This finding rests on a single tier-two investigative source (OCCRP) and is pattern-consistent with, but not independently corroborated beyond, the DNFBP gap identified in the mutual evaluation, warranting an assessed rather than high-confidence rating. The enabler-jurisdiction lens applied here is agnostic to Peru's formal reputation: Peru is FATF-clean, yet the combination of a fresh judicial precedent shielding the executive, sustained institutional turnover, and an unsupervised DNFBP sector produces an enablement profile that a formal listing status alone would not capture. This is precisely the kind of structural finding the FIM architecture-over-incident principle is designed to surface, one enforcement action or one conviction does not offset a systemic supervisory and accountability gap that persists across administrations. #### Outlook The near-term trajectory for Peru's enabler-jurisdiction profile is dominated by the contested 2026 presidential runoff, under electoral-court review with transition expected around 28 July 2026. Given the pattern of four presidential removals since 2018 and the fresh executive-immunity precedent, continuity of any anti-corruption enforcement agenda through this transition is genuinely uncertain rather than presumed. The DNFBP supervision gap and the cross-border exchange-house corridor it enables are unlikely to close absent legislative action extending AML obligations to currently unsupervised professional intermediaries, a step that has not yet been signalled as forthcoming in available sourcing. Judgment: No Peru-nexus enabler-jurisdiction signal this cycle. Uncertain #### Conflict Finance and Extractive-Industry Integrity The illegal Amazon gold-mining laundering pipeline is the dominant financial-integrity architecture operating in Peru, and the quantified scale of its footprint this cycle is striking: a UK overseas business risk assessment finds that illegal mining is the predicate crime linked to 57 percent of the total monetary value flagged across Peru's suspicious-transaction reports, a finding corroborated across UK FCDO, UNODC and Bloomberg sourcing at a high-confidence tier. The mechanics are consistent across sourcing: gold extracted informally, often using mercury, from Madre de Dios and northern Amazon regions is sold through informal buyers and layered into the formal export supply chain via exporters and money-changers before reaching international refiners. Drug-trafficking organisations increasingly co-invest directly in mining operations, treating the sector not merely as an adjacent revenue stream but as an active laundering vehicle for narcotics proceeds, which links this domain directly to the VRAEM narco-terrorism financing dynamics tracked under D1. Continue reading Against this architecture, Peruvian customs (SUNAT) executed a record enforcement action, seizing approximately four metric tons of mercury shipped from Mexico, described as the largest mercury seizure reported by any Amazonian country. This is a genuinely significant single disruption of one input-chemical supply chain, and it should be read plainly as a real enforcement success. But applying the architecture-over-incident principle, the seizure disrupts one shipment within an ongoing smuggling flow; it does not alter the underlying laundering architecture that layers informally-sourced gold into formal supply chains, nor does it touch the co-investment relationship between trafficking organisations and mining operations. The distinction matters for risk assessment: a single seizure, however record-setting, is not evidence that the systemic vulnerability has narrowed. The conflict-finance dimension here extends beyond gold to the VRAEM narco-terrorism network, where Sendero Luminoso remnants tax coca-paste production and trafficking routes, moving proceeds through cash smuggling and informal exchange networks. Both the gold-mining pipeline and the VRAEM financing network share a common feature that should concern trade-finance and correspondent-banking compliance functions specifically: value is layered into the formal financial system at the point where informal, cash-based proceeds meet formal exporters, money-changers or correspondent-banking relationships, meaning the highest-value detection opportunity sits at that transition point rather than earlier in the informal supply chain where visibility is inherently limited. #### Outlook The gold-mining laundering architecture is unlikely to see structural disruption from continued interdiction of input chemicals like mercury alone; sourcing indicates no legislative or supervisory reform specific to the gold-export chain is currently scheduled. The domain's trajectory is assessed as worsening, reflecting the scale of SAR-value concentration in this single predicate crime and the absence of any signalled structural intervention beyond periodic seizure actions. Institutions with trade-finance or correspondent-banking exposure to Peru-linked gold exports should treat the exporter/money-changer layering point, rather than the extraction point, as the primary observable control opportunity going forward. Judgment: No Peru-specific conflict-finance signal this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation Chapter VIII of Resolución SBS N.° 02648-2024, Peru's Travel Rule provision for virtual-asset transfers, entered into force on 1 August 2026, following a two-year transition period from the resolution's original adoption. The chapter requires UIF-Perú-registered Proveedores de Servicios de Activos Virtuales to transmit originator and beneficiary information on virtual-asset transfers, and to assess money-laundering and terrorist-financing risk specifically where a transfer involves a self-hosted wallet. The self-hosted-wallet risk-assessment duty is a meaningful addition: it extends AML scrutiny beyond VASP-to-VASP transfers into the harder-to-supervise category of transfers touching wallets outside a regulated custodian's control. Continue reading This AML-perimeter development arrives without a parallel licensing framework. Peru has no comprehensive crypto-licensing or authorisation statute; a PSAV's only regulatory gateway remains registration as a UIF-Perú obliged entity accompanied by a SPLAFT anti-money-laundering programme. The RUPIC crypto-exchange licensing bill, Proyecto de Ley N.° 1042/2021-CR, remains stalled in committee following its return on 19 March 2025, with no confirmed 2026 progress update and no enactment timeline. The practical effect is that Peru's virtual-asset sector now carries a functioning cross-border AML control without a corresponding prudential or conduct-licensing regime sitting alongside it, a structural gap the RUPIC bill is intended to close if it advances. This extension of AML obligations into the virtual-asset sector follows the same pattern as the SBS's parallel extension of AML obligations into the remote-gambling sector via Resolución SBS N.° 01015-2026 (effective 8 April 2026), both instruments issuing from the same supervisory authority within months of each other in 2026. The structural reading is of a single regulator broadening its obliged-entity perimeter across multiple sectors through its AML powers rather than through sector-specific licensing legislation. #### Outlook The principal open question is supervisory practice: how UIF-Perú enforces the originator/beneficiary data-transmission duty and the self-hosted-wallet risk-assessment step now that the transition period has ended and the obligation is live. No enforcement or supervisory guidance specific to Chapter VIII's practical application was located this cycle. The RUPIC bill's progress, or continued stasis, in committee remains the key structural variable for whether Peru's virtual-asset regime acquires a licensing layer to sit alongside its now-active AML perimeter. Judgment: Peru's VASP Travel Rule chapter (in force since 1 Aug 2026) remains the operative control; PL 1042/2021-CR stays stalled in committee with no new initiative since the bicameral Congress was installed in July 2026. Probable Judgment: No RegTech/compliance-technology development specific to Peru identified this cycle. Uncertain #### AML/CTF Regime Peru's AML/CTF regime advanced this cycle through sectoral extension rather than wholesale reform. The SBS, acting through UIF-Peru, opened a public comment period, closing 14 November 2026, on a draft rule that would impose customer due diligence, compliance-manual, prevention-code, suspicious-transaction-reporting and annual compliance-officer obligations on entities already within UIF-Peru's informal reporting net but outside the SBS's direct supervisory perimeter. This continues an incremental sequence: cash and securities carriers were brought in during March 2025, fund managers and factoring companies in May 2025, and leasing companies in May 2026. The pattern is one of narrowing gaps in the obliged-entity perimeter one sector at a time, rather than legislating a single comprehensive overhaul, and the probable-confidence underlying draft resolution itself was not retrieved this cycle, leaving the exact scope of the final instrument to be confirmed once the comment period closes. Continue reading Alongside this expansion, the standing regime for remote-gaming and online sports-betting platforms under Resolucion SBS No. 01015-2026, which took effect in April 2026, continues to operate as the baseline for that sector: a SPLAFT prevention system, twenty-four-hour suspicious-transaction-report filing to UIF-Peru, and supervisory and sanctioning authority resting not with the SBS but with MINCETUR's gaming directorate. That split between standard-setter and enforcer is a structural feature of the gambling-sector AML architecture that persists unchanged this cycle. On the international-standing side, the FATF's 28-30 October 2026 plenary removed four jurisdictions from its increased-monitoring list and added none, with Peru remaining off both the increased-monitoring and call-for-action lists, as it has for some time. Peru's most recent mutual evaluation under the regional FATF-style body for Latin America remains the report adopted in 2018, meaning the formal external assessment of its AML/CFT system predates all of the sectoral expansions described above. #### Outlook The comment period closing 14 November 2026 is the near-term pivot point: the draft rule's final scope, once settled, will determine how far the AML perimeter actually extends into sectors currently supervised only informally. Peru's standing outside the FATF increased-monitoring list is not expected to shift before the next plenary cycle, but the age of the 2018 mutual evaluation leaves an open question about how current external assessors regard the cumulative effect of this incremental sectoral rulemaking on the country's overall AML/CFT effectiveness. Judgment: SBS/UIF-Perú opened a comment period (closing 14 Nov 2026) on a draft rule extending AML obligations to sectors already informally supervised outside SBS's direct banking perimeter, continuing incremental sectoral additions begun in March 2025. The standing casino/remote-gaming AML regime under Resolución SBS N.° 01015-2026 is unchanged. Probable Judgment: No commercial-event signal (M&A, investment, partnership) involving integrity-infrastructure or regulated firms in Peru identified this cycle. Uncertain Regulatory horizon Consultation 14 Nov 2026 · ±quarter ### Draft rule strengthening AML controls for non-SBS-supervised obliged entities CDD, prevention-code, compliance-officer and suspicious-transaction-reporting duties would be formalised for sectors already informally within UIF-Perou's reporting net. source not collected Proposed 2026-Q4 · ±half_year ### ISC Article 53/61 amendment dispute for remote gaming/betting A Congress-passed bill to narrow the ISC base for remote gaming/betting was vetoed by the Executive on 2025-07-16 and remained with the Pleno as of late June 2026 awaiting an insistencia vote or acceptance of the observation. [Congreso de la República / Poder Ejecutivo Source](https://gestion.pe/economia/apuestas-online-ejecutivo-observo-proyecto-del-congreso-pues-reduce-el-pago-del-isc-en-90-noticia/) Proposed 2027 · ±multi_year ### Framework Law for the Commercialization of Cryptoassets (Bill 1042/2021-CR) If enacted, would create Peru's first comprehensive crypto-asset licensing statute and a public VASP registry; as of 19 March 2025 the bill was returned to committee with no enactment timeline. [Congreso de la República Source](https://notabene.id/world/peru) Consultation 2027 · ±multi_year ### RUPIC crypto-exchange licensing bill pending Would create a dedicated crypto-exchange register beyond the existing AML-only PSAV obligation. [Congreso de la República del Perú Source](https://notabene.id/world/peru) 4 dated · 2 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### SBS is extending formal reporting duties to sectors already within informal AML oversight. A draft rule open for comment until 14 November 2026 would formalise CDD, prevention-code and suspicious-transaction-reporting obligations for entities already feeding information to UIF-Peru informally. This continues a sectoral-extension pattern dating to March 2025. 2 evidence refs Compliance ### The obliged-entity perimeter under Peru's AML regime continues to widen sector by sector. Entities not previously formally obliged may fall within scope once the draft rule is finalised, requiring compliance-manual and compliance-officer reporting infrastructure that may not yet exist within those sectors. 1 evidence refs Legal ### No sanctions-list change affecting Peru this cycle; FATF standing unchanged. Peru remains off both FATF lists following the October 2026 plenary, and its last mutual evaluation remains the 2018 report, meaning no new formal international assessment has altered its standing. 2 evidence refs Board ### Peru is tightening financial-crime oversight incrementally rather than through a single reform. The cumulative direction of sectoral AML rulemaking since March 2025 signals a structural widening of regulatory exposure for non-bank financial entities operating in Peru, material to institutions with exposure there. 2 evidence refs CTO ### Peru's crypto licensing framework remains stalled; only a narrow Travel Rule obligation is operative. The comprehensive virtual-asset bill PL 1042/2021-CR remains in legislative committee with no new initiative since July 2026, leaving digital-asset infrastructure governed only by a Travel Rule chapter in force since August 2026. 1 evidence refs Risk ### Sectoral AML perimeter expansion in Peru is a structural, not episodic, trend. The draft rule under comment is the fourth increment in an obliged-entity expansion sequence since March 2025, indicating a durable regulatory trajectory rather than a one-off event, relevant to exposure-concentration assessments for non-bank counterparties. 1 evidence refs Operations ### The standing gambling-sector AML regime remains unchanged this cycle. Resolucion SBS No. 01015-2026's SPLAFT and 24-hour suspicious-transaction-report filing requirements for remote-gaming and online sports-betting platforms continue to apply without modification. 1 evidence refs Audit ### Peru's external AML/CFT assessment record has not been refreshed since 2018. The regional mutual evaluation underpinning Peru's international AML/CFT standing predates the full run of sectoral rulemaking since March 2025, a gap worth noting when assessing the currency of controls-testing benchmarks. 1 evidence refs Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No Peru-nexus signal this cycle. T2 · EU AML Package / AMLA no_change Not applicable — Peru is non-EEA. T3 · FATF Grey List no_change October 2026 plenary removed four jurisdictions and added none; Peru not on either list. T4 · Beneficial-Ownership Register Status no_change No new development for Peru identified this cycle. T5 · Crypto & Digital-Asset Integrity stable Travel Rule chapter in force since 1 Aug 2026; PL 1042/2021-CR remains stalled in committee. T6 · Sanctions Regime Divergence no_change No Peru-specific divergence signal this cycle. Registers ### Enforcement actions - 15 Apr 2025 - 24 Jul 2025 - 19 Aug 2025 - 10 Oct 2025 - 31 May 2026 - National Superior Court convicted former President Ollanta Humala and his wife Nadine Heredia of aggravated money laundering for receiving campaign funds from Odebrecht and Venezuela; Heredia's brother was also convicted as co-author. 15 Apr 2025 - Peruvian customs officials seized roughly four metric tons of mercury shipped from Mexico, intercepting a key input chemical used in illegal Amazon gold mining and its associated laundering economy. 24 Jul 2025 - Peru's Constitutional Tribunal ruled that ongoing criminal probes against sitting President Boluarte — spanning illegal enrichment, abandonment of post, and homicide allegations — must be paused while she remained in office. 19 Aug 2025 - Congress voted by an overwhelming majority to impeach and remove President Boluarte, ending a term marked by illicit-enrichment allegations, an unresolved Rolex-watch scandal, and the earlier Constitutional Tribunal shield on criminal probes. 10 Oct 2025 ### Sanctions changes - 20 Jan 2025 - OFAC implemented Executive Order 14157 (January 2025) designating major international cartels as Foreign Terrorist Organizations and Specially Designated Global Terrorists, expanding the US counter-narcotics sanctions architecture that overlays hemispheric drug-trafficking corridors, including those touching Peru's VRAEM cocaine-trafficking economy. 20 Jan 2025 - Peru itself remained free of any jurisdiction-specific OFAC, EU, or OFSI sanctions programme or listing action during the review window, confirmed by its continued absence from the FATF grey/black lists as of the February and June 2026 plenary statements — a status distinct from regional peers such as Bolivia and Venezuela, which face active grey-list or country-specific sanctions scrutiny. 19 Jun 2026 ### Regulatory horizon (register) - ISC Article 53/61 amendment dispute for remote gaming/betting - Framework Law for the Commercialization of Cryptoassets (Bill 1042/2021-CR) - ISC Article 53/61 amendment dispute for remote gaming/betting - FATF 5th round mutual evaluation of Peru (GAFILAT) - Peru Ley Marco de Comercializacion de Criptoactivos (crypto-market-conduct bill) - Peru Travel Rule chapter (SBS Res. 02648-2024 Ch. VIII) commencement - RUPIC crypto-exchange licensing bill pending - Draft rule strengthening AML controls for non-SBS-supervised obliged entities - Peru presidential transition following contested 2026 runoff - GAFILAT/FATF continued follow-up on Peru's AML/CFT effectiveness - Potential Peru VASP AML licensing framework ### Active schemes - [CRITICAL] Illegal Amazon gold-mining laundering pipeline - [HIGH] VRAEM narco-terrorism financing network - Cross-border money-exchange-house laundering corridor - [HIGH] PEP campaign-finance laundering (Odebrecht legacy) - Unregulated VASP fiat off-ramp exposure Sources - [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) - [https://www.elperuano.pe/noticia/293028-nueva-norma-sobre-lavado-de-activos-para-casinos-y-apuestas-online-verifica-si-eres-sujeto-obligado](https://www.elperuano.pe/noticia/293028-nueva-norma-sobre-lavado-de-activos-para-casinos-y-apuestas-online-verifica-si-eres-sujeto-obligado) - [https://lpderecho.pe/norma-prevenir-lavado-activos-financiamiento-terrorismo-casinos-tragamonedas-apuestas-deportivas-resolucion-sbs-01015-2026/](https://lpderecho.pe/norma-prevenir-lavado-activos-financiamiento-terrorismo-casinos-tragamonedas-apuestas-deportivas-resolucion-sbs-01015-2026/) - [https://notabene.id/world/peru](https://notabene.id/world/peru) - [https://nodomiciliados.sunat.gob.pe/en/node/67](https://nodomiciliados.sunat.gob.pe/en/node/67) - [https://www.businessdataguide.com/blog/jurisdictions/peru-company-search-guide](https://www.businessdataguide.com/blog/jurisdictions/peru-company-search-guide) - [https://www.fatf-gafi.org/en/countries/detail/Peru.html](https://www.fatf-gafi.org/en/countries/detail/Peru.html) - [SBS / UIF-Peru](https://www.sbs.gob.pe/Portals/0/INFORME%20N%2000001%20%202026%20%20UIFSBSPRI.pdf) - [SBS](https://www.sbs.gob.pe/) - [Infobae Peru](https://www.infobae.com/peru/2026/04/08/sbs-endurece-supervision-sobre-casinos-y-juegos-en-linea-para-prevenir-lavado-de-dinero-y-financiamiento-del-terrorismo/) - [Gestion](https://gestion.pe/economia/uif-detalla-preparativos-para-la-quinta-ronda-de-evaluaciones-del-gafi-compliance-camara-de-comercio-de-lima-sunat-sbs-evaluacion-corrupcion-noticia/) - [Metlabs](https://metlabs.io/regulacion-blockchain/peru/) - [Notabene](https://notabene.id/world/peru) - [Yogonet](https://www.yogonet.com/latinoamerica/noticias/2026/04/13/108429-peru-la-sbs-endurece-los-controles-para-prevenir-el-lavado-de-activos-en-el-juego-presencial-y-online) - [Diario Judicial](https://www.diariojudicial.com/news-95343-peru-mas-cerca-de-su-ley-cripto) - [Diario Oficial El Peruano / SBS](https://busquedas.elperuano.pe/api/archivo/file/7O9VQQxW4DO9h4V3C25gvJ/*/2536870-1.PDF) - [https://actualidad.educacionenred.pe/2026/04/res-sbs-01015-2026-aprueban-norma-para-prevencion-lavado-activos-financiamiento-340665.html](https://actualidad.educacionenred.pe/2026/04/res-sbs-01015-2026-aprueban-norma-para-prevencion-lavado-activos-financiamiento-340665.html) - [https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [https://gestion.pe/economia/empresas/apuesta-total-cambia-de-manos-quien-controlara-ahora-las-apuestas-y-los-casinos-de-cirsa-en-peru-noticia/](https://gestion.pe/economia/empresas/apuesta-total-cambia-de-manos-quien-controlara-ahora-las-apuestas-y-los-casinos-de-cirsa-en-peru-noticia/) - [https://www.sbs.gob.pe/Portals/0/INFORME%20N%2000001%20%202026%20%20UIFSBSPRI.pdf](https://www.sbs.gob.pe/Portals/0/INFORME%20N%2000001%20%202026%20%20UIFSBSPRI.pdf) - [https://www.sbs.gob.pe/noticia/detallenoticia/idnoticia/4022](https://www.sbs.gob.pe/noticia/detallenoticia/idnoticia/4022) - [https://elperuano.pe/noticia/303715-declaracion-de-beneficiario-final-quienes-deben-cumplir-esta-obligacion-ante-la-sunat-en-2026](https://elperuano.pe/noticia/303715-declaracion-de-beneficiario-final-quienes-deben-cumplir-esta-obligacion-ante-la-sunat-en-2026) - [https://www.federalregister.gov/documents/2026/10/07/2026-20526/notice-of-ofac-sanctions-actions](https://www.federalregister.gov/documents/2026/10/07/2026-20526/notice-of-ofac-sanctions-actions) - [https://ofac.treasury.gov/recent-actions/20260909](https://ofac.treasury.gov/recent-actions/20260909) - [SBS](https://www.sbs.gob.pe/Portals/5/jer/BOLETIN-INFORMATIVOS/2026/BOLETIN%20UIF%20N%C2%B0%20165.pdf) - [El Peruano](https://www.elperuano.pe/noticia/293028-nueva-norma-sobre-lavado-de-activos-para-casinos-y-apuestas-online-verifica-si-eres-sujeto-obligado) - [Infobae](https://www.infobae.com/peru/2026/04/08/sbs-endurece-supervision-sobre-casinos-y-juegos-en-linea-para-prevenir-lavado-de-dinero-y-financiamiento-del-terrorismo/) - [TokenPost](https://www.tokenpost.com/news/regulation/45407) - [El Noticiero](https://diarioelnoticiero.com/tu-empresa-debe-prevenir-el-lavado-de-activos-estas-son-las-obligaciones-que-debes-revisar/) - [ComplyAdvantage](https://complyadvantage.com/insights/fatf-plenary-october-2026-four-grey-list-exits-a-virtual-asset-review-and-a-new-focus-on-scam-compounds/) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Peru.html) - [Rankia](https://www.rankia.pe/blog/criptomonedas-peru/6700020-regulacion-criptomonedas-peru-que-debes-saber) - [Peru](https://www.fatf-gafi.org/en/countries/detail/Peru.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Mutual Evaluation of Peru](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofperu.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) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [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) - [Countries / Jurisdictions](https://www.fatf-gafi.org/countries/) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.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) - [Peru's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-peru-2019.html) - [Peru Country Guide | Elliptic](https://www.elliptic.co/country-guides/peru) - [International Narcotics Control Strategy Report Volume II Money Laundering](https://syntheticdrugs.unodc.org/uploads/syntheticdrugs/res/library/cybercrime_html/US_International_Narcotics_Control_Strategy_Report_Money_Laundering.pdf) - [Peru's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-peru-2020.html) - [thematic compilation of relevant information submitted](https://www.unodc.org/documents/corruption/WG-Prevention/Art_14_Prevention_of_money-laundering/Peru.pdf) - [Peru’s former president and wife sentenced to 15 years in prison for Odebrecht-linked money laundering scheme - ICIJ](https://www.icij.org/news/2025/04/perus-former-president-and-wife-sentenced-to-15-years-in-prison-for-odebrecht-linked-money-laundering-scheme/) - [Secret Operations: The Peruvian Charged with Laundering Massive Amounts of Drug Money | OCCRP](https://www.occrp.org/en/investigation/secret-operations-the-peruvian-charged-with-laundering-massive-amounts-of-drug-money) - [Fatf-gafi](https://www.fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/GAFILAT-Spanish-Mutual-Evaluation-Peru.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) - [Counter Narcotics Trafficking Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/counter-narcotics-trafficking-sanctions) - [Sanctions List Updates](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [Home | Office of Foreign Assets Control](https://ofac.treasury.gov/) - [Sanctions List Search Tool | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-search-tool) - [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) - [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) - [U.S: Manager Suspected of Laundering Money for Illegal Peruvian Gold Mines | OCCRP](https://www.occrp.org/en/news/us-manager-suspected-of-laundering-money-for-illegal-peruvian-gold-mines) - [With support from UNODC Brazil, workshop at CCPI-Amazon advances operational alignment in combating illegal gold mining in the Amazon](https://www.unodc.org/cofrb/en/noticias/2026/04/-workshop-at-ccpi-amazon-advances-operational-alignment-in-combating-illegal-gold-mining.html) - [Overseas business risk: Peru - GOV.UK](https://www.gov.uk/government/publications/overseas-business-risk-peru--2/overseas-business-risk-in-peru) - [‘Dirty Gold’ chases ‘three amigos’ from Miami to Peru and beyond - ICIJ](https://www.icij.org/inside-icij/2021/03/dirty-gold-chases-three-amigos-from-miami-to-peru-and-beyond/) - [Peru Seizes Mercury Cargo in Battle Against Illegal Gold Mining - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-24/peru-seizes-mercury-cargo-in-battle-against-illegal-gold-mining) - [UNODC: Rising demand for minerals heightening risks of crime, corruption and instability](https://www.unodc.org/unodc/en/press/releases/2025/May/unodc_-rising-demand-for-minerals-heightening-risks-of-crime--corruption-and-instability.html) - [Amazonian territories on the frontlines of the transition minerals race | Global Witness](https://globalwitness.org/en/campaigns/transition-minerals/amazonian-territories-on-the-frontlines-of-the-transition-minerals-race/) - [Newmont’s $4.8 Billion Peru Gold Project Targeted by Illegal Miners - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-12/illegal-miners-are-digging-gold-at-a-4-8-billion-newmont-site-in-peru) - [THE NEXUS BETWEEN DRUGS AND CRIMES THAT AFFECT THE ENVIRONMENT](https://www.unodc.org/res/WDR-2023/WDR23_B3_CH4_Amazon.pdf) - [Watch Gold’s Price Surge Drives Narcos Into Illegal Mining in the Amazon - Bloomberg](https://www.bloomberg.com/news/videos/2025-01-24/gold-s-price-surge-drives-narcos-into-illegal-mining-in-the-amazon) - [Unidad de Inteligencia Financiera del Perú UIF-Perú](https://www.un.org/securitycouncil/ctc/sites/www.un.org.securitycouncil.ctc/files/republic_of_peru.pdf) - [Strategy guidance note on beneficial ownership registries](https://publicadministration.desa.un.org/sites/default/files/cepa-sessions/Strategy%20note%20beneficial%20ownership%20registries%20Oct%202024_0.pdf) - [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports) - [UN DESA Policy Brief No. 148: Beneficial ownership information: Supporting fair taxation and financial integrity | UN DESA Publications](https://desapublications.un.org/policy-briefs/un-desa-policy-brief-no-148-beneficial-ownership-information-supporting-fair-taxation) - [Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/) - [Beneficial Ownership Information Access and Safeguards Requirements](https://www.fincen.gov/system/files/shared/BOI_Access_and_Safeguards_SECG_508C.pdf) - [Interim Final Rule: Questions and Answers | FinCEN.gov](https://www.fincen.gov/boi/ifr-qa) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Guidance on Beneficial Ownership and Transparency of Legal Arrangements](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html) - [Peru invests in British technology in the fight against drug trafficking - GOV.UK](https://www.gov.uk/government/news/peru-invests-in-british-technology-in-the-fight-against-drug-trafficking) - [Safety and security - Peru travel advice - GOV.UK](https://www.gov.uk/foreign-travel-advice/peru/safety-and-security) - [Peru's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/fur-peru-2020.html) - [Mutual Evaluation of Peru](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mutualevaluationofperu.html) - [FATF report highlights evolving terrorist financing risks and warns of gaps in global understanding of the threats](https://www.fatf-gafi.org/en/publications/Methodsandtrends/comprehensive-update-terrorist-financing-risks-2025.html) - [Exploring the Motivation of Sendero Luminoso Militants](https://assets.publishing.service.gov.uk/media/57a08bcd40f0b64974000d96/wp57.pdf) - [Comprehensive Update on Terrorist Financing Risks FATF REPORT July 2025](https://www.fatf-gafi.org/content/dam/fatf-gafi/publications/Comprehensive-Update-on-Terrorist-Financing-Risks-2025.pdf.coredownload.inline.pdf) - [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/) - [FATF urges stronger global action to address Illicit Finance Risks in Virtual Assets](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2025.html) - [2025 LATAM Crypto Adoption: Latin America Emerges as Crypto Powerhouse](https://www.chainalysis.com/blog/latin-america-crypto-adoption-2025/) - [What Is a VASP? Virtual Asset Service Provider - Chainalysis](https://www.chainalysis.com/glossary/virtual-asset-service-provider/) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Virtual Asset Service Provider (VASP): Definition, Compliance & Examples](https://www.trmlabs.com/glossary/virtual-asset-service-provider-vasp) - [Crypto-assets - Finance - European Commission](https://finance.ec.europa.eu/digital-finance/crypto-assets_en) - [Elliptic's 2026 regulatory and policy outlook: 5 crypto trends to expect in 2026](https://www.elliptic.co/blog/regulatory-and-policy-crypto-trends-to-except-in-2026) - [FATF Issues Comprehensive Guidance on Virtual Asset Recovery](https://www.chainalysis.com/blog/fatf-guidance-virtual-asset-recovery-law-enforcement-november-2025/) - [Peru President Dina Boluarte Probed Over How She Can Afford a Rolex Watch - Bloomberg](https://www.bloomberg.com/news/articles/2024-03-22/embattled-peru-president-boluarte-probed-over-how-she-obtained-rolex-watch) - [Why a Scandal Over a Rolex Watch Is Threatening Peru’s President - Bloomberg](https://www.bloomberg.com/news/articles/2024-04-01/why-a-scandal-over-a-rolex-watch-is-threatening-peru-s-president) - [Peru Authorities Raid Boluarte Residence Amid Rolex Scandal - Bloomberg](https://www.bloomberg.com/news/articles/2024-03-30/peru-authorities-raided-boluarte-s-residence-amid-rolex-probe) - [Peru Prosecutors Probe President for Alleged Money Laundering - Bloomberg](https://www.bloomberg.com/news/articles/2023-03-29/peru-prosecutors-probe-president-for-alleged-money-laundering) - [Peru President Dina Boluarte Reshuffles Cabinet Amid Rolex Scandal - Bloomberg](https://www.bloomberg.com/news/articles/2024-04-02/peru-s-boluarte-reshuffles-cabinet-amid-rolex-scandal-ahead-of-key-vote) - [Peru Authorities Raid Boluarte Residence Amid Rolex Probe - Bloomberg](https://www.bloomberg.com/news/articles/2024-03-30/peru-authorities-raided-boluarte-s-residence-amid-rolex-probe?srnd=citylab) - [Peru’s Congress Rejects Impeaching Boluarte Over Rolex Scandal - Bloomberg](https://www.bloomberg.com/news/articles/2024-04-04/peru-s-congress-rejects-impeaching-boluarte-over-rolex-scandal) - [Peru President Hit by Rolex Scandal Seeks Support From Reviled Congress - Bloomberg](https://www.bloomberg.com/news/articles/2024-04-03/peru-president-hit-by-rolex-scandal-seeks-support-from-reviled-congress) - [Government agents raid Peruvian President Boluarte's residence in luxury watch investigation - Bloomberg](https://www.bloomberg.com/en/news/thp/2024-03-30/government-agents-raid-peruvian-president-boluarte-s-residence-in-luxury-watch-investigation) - [Peru’s Top Court Halts All Criminal Probes Against Boluarte - Bloomberg](https://www.bloomberg.com/news/articles/2025-08-19/peru-s-top-court-halts-all-criminal-probes-against-president-boluarte) - [Peru’s Boluarte Ousted and Jerí Sworn in as President - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-10/peru-s-boluarte-ousted-from-office-as-ex-allies-back-impeachment) - [Peru’s Largest Congressional Bloc Backs Ousting Boluarte - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-09/peru-s-largest-congressional-bloc-backs-ousting-boluarte) - [Peruvian President Removed from Office, Arrested After Self-Coup | OCCRP](https://www.occrp.org/en/news/peruvian-president-removed-from-office-arrested-after-self-coup) - [Peru Congress Rejects Impeachment Motion Against President Dina Boluarte - Bloomberg](https://www.bloomberg.com/news/articles/2023-04-04/peru-congress-dismisses-impeachment-motion-against-president) - [Peru Swears In Dina Boluarte as President After Castillo’s ‘Coup’ Attempt Fails - Bloomberg](https://www.bloomberg.com/news/articles/2022-12-07/peru-congress-approves-impeaching-president-pedro-castillo) - [‘Censorship disguised as law’: Investigative journalists in Peru push back against government crackdown - ICIJ](https://www.icij.org/news/2025/11/censorship-disguised-as-law-investigative-journalists-in-peru-push-back-against-government-crackdown/) - [Peru President José Jerí Removed by Congress After Four Months in Office - Bloomberg](https://www.bloomberg.com/news/articles/2026-02-17/peru-s-congress-removes-president-jeri-after-four-months-in-office) - [Peru’s Boluarte Pledges to Stay the Course Until Next Vote - Bloomberg](https://www.bloomberg.com/news/articles/2025-07-28/peru-s-boluarte-pledges-to-stay-the-course-until-next-vote) - [Live: Peru's President Castillo Impeached After Dissolving Congress - Bloomberg](https://www.bloomberg.com/news/live-blog/2022-12-07/peru-s-president-dissolves-congress) - [0 Mutual Evaluation Report of Peru MUTUAL EVALUATION REPORT OF PERU](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/GAFILAT-Mutual-Evaluation-Peru-2019.pdf) - [Peru's Ex-President Humala Sentenced to 15 Years in Prison for Money Laundering - Bloomberg](https://www.bloomberg.com/news/articles/2025-04-15/peru-sentences-ex-president-humala-to-15-years-in-prison-for-money-laundering) - [International Criminal Court-Related Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/international-criminal-court-related-sanctions) - [Fujimori Leads in Peru Vote as Election Extended Over Delays](https://www.bloomberg.com/news/articles/2026-04-12/fujimori-poised-for-peru-presidential-runoff-but-opponent-still-unclear) - [Peru Election: Fighter Jet Controversy Brings Presidency to New Low - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-27/peru-election-fighter-jet-controversy-brings-presidency-to-new-low) - [Peru Election Polls Show Fujimori Leading, Alvarez Gains Before Vote - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-04/peru-s-presidential-front-runners-shift-with-election-days-away) - [Peru 2026 Presidential Election Awaits Court Review of Disputed Votes - Bloomberg](https://www.bloomberg.com/news/articles/2026-06-13/peru-2026-presidential-election-awaits-court-review-of-disputed-votes) - [Peru Presidential Race Led by López-Aliaga With 11% Support, Ipsos Poll Shows - Bloomberg](https://www.bloomberg.com/news/articles/2026-03-12/peru-s-presidential-frontrunner-has-just-11-support-poll-finds) - [Peru Faces Weeks-Long Wait for Final Presidential Election Results - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-20/peru-s-presidential-vote-count-to-drag-on-through-mid-may) - [Peru Presidential Election: 54 Parties Register for 2026 Vote - Bloomberg](https://www.bloomberg.com/news/articles/2024-07-19/peru-presidential-election-54-parties-register-for-2026-vote) - [Peru’s New President Names His Third Prime Minister in a Month - Bloomberg](https://www.bloomberg.com/news/articles/2026-03-17/peru-s-new-president-names-his-third-prime-minister-in-a-month) - [Peru President Race Draws 36 Hopefuls, Elections Board Says - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-24/peru-s-presidential-race-draws-34-hopefuls-elections-board-says) - [Peru Election: Keiko Fujimori Gets Her Best Chance Yet to Win Presidency - Bloomberg](https://www.bloomberg.com/news/articles/2026-04-14/peru-election-keiko-fujimori-gets-her-best-chance-yet-to-win-presidency) - [1 Country: Peru Illicit financial flows from cocaine trafficking](https://www.unodc.org/documents/data-and-analysis/IFF/6_Peru_-_IFFs_from_Cocaine_Trafficking.pdf) - [Peru](https://www.unodc.org/unodc/en/alternative-development/peru.html) - [Peru programme Situation analysis](https://www.unodc.org/pdf/peru_programme.pdf) - [UNODC - Crop Monitoring](https://www.unodc.org/unodc/en/crop-monitoring/) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Key Changes in FinCEN’s Proposed Rule to Refocus AML/CFT Programs on](https://www.fincen.gov/system/files/2026-04/Key-Changes-Program-NPRM.pdf) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [Financial sanctions enforcement and monetary penalties guidance - GOV.UK](https://www.gov.uk/government/publications/financial-sanctions-enforcement-and-monetary-penalties-guidance/financial-sanctions-enforcement-and-monetary-penalties-guidance) - [Instituciones del Estado fortalecen capacidades en el uso de la inteligencia financiera para la investigación de delitos complejos](https://www.unodc.org/rocol/es/noticias/peru/instituciones-del-estado-fortalecen-capacidades-en-el-uso-de-la-inteligencia-financiera-para-la-investigacin-de-delitos-complejos.html) - [Política y Plan Nacional contra el Lavado de Activos y el Financiamiento del Terrorismo (2018-2021)](https://www.unodc.org/cld/es/treaties/strategies/peru/per0002s.html) - [1 COMISION DE ALTO NIVEL ANTICORRUPCION – CAN COORDINACIÓN GENERAL](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup4/2015-August-31-to-September-2/Contributions_NV/Contribution_-_Peru.pdf) - [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) - [Perú](https://www.unodc.org/rocol/es/paises/peru.html) - [Naciones Unidas le apunta a fortalecer la capacidad de las Unidades de Inteligencia Financiera (UIF) en su lucha contra el lavado de activos](https://www.unodc.org/colombia/es/comunicados/com3809.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) - [TRATA DE PERSONAS LAVADO DE ACTIVOS EN PERÚ](https://www.unodc.org/rocol/uploads/res/noticias/peru/ministerio-pblico-presenta-estudio-sobre-la-trata-de-personas-como-delito-fuente-del-lavado-de-activos-en-per_html/Estudio_TdP_2025_web.pdf) - [GUÍA OPERATIVA ESPECIALIZADA EN TRATA Y ...](https://www.unodc.org/rocol/uploads/res/biblioteca/bibliotecadot_html/Guia_Operativa_2026_WEB_v2.pdf) - [COMISIÓN NACIONAL DE BIENES INCAUTADOS](https://www.unodc.org/documents/corruption/AddisEGM2017/Presentations/PRESENTACION_CONABI_ETIOPIA_Peru.pdf) - [Extinción de dominio - Naciones Unidas](https://www.unodc.org/rocol/es/extincin-de-dominio.html) - [lavado2 analistas financieros](https://www.unodc.org/peruandecuador/es/02AREAS/DELITO/lavado2-analistas-financieros.html) - [LEY MODELO SOBRE EXTINCIÓN DE DOMINIO Programa de Asistencia Legal](https://www.unodc.org/documents/colombia/2013/septiembre/Extincion_de_dominio_final.pdf) - [MINISTERIO PÚBLICO FISCALIA DE LA NACIÓN DEL PERÚ](https://www.unodc.org/documents/international-cooperation/News_and_events/PERU_UNTOC_Contributions.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) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Peru.html) - [FATF / GAFILAT](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-peru-2019.html) - [GAFILAT / FATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/GAFILAT-Mutual-Evaluation-Peru-2019.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [UK Government (Department for Business and Trade)](https://www.gov.uk/government/publications/overseas-business-risk-peru--2/overseas-business-risk-in-peru) - [US Treasury OFAC](https://ofac.treasury.gov/sanctions-programs-and-country-information/counter-narcotics-trafficking-sanctions) - [ICIJ](https://www.icij.org/news/2025/04/perus-former-president-and-wife-sentenced-to-15-years-in-prison-for-odebrecht-linked-money-laundering-scheme/) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-07-24/peru-seizes-mercury-cargo-in-battle-against-illegal-gold-mining) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-08-19/peru-s-top-court-halts-all-criminal-probes-against-president-boluarte) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-10-10/peru-s-boluarte-ousted-from-office-as-ex-allies-back-impeachment) - [OCCRP](https://www.occrp.org/en/investigation/secret-operations-the-peruvian-charged-with-laundering-massive-amounts-of-drug-money) - [Elliptic](https://www.elliptic.co/country-guides/peru) - [Chainalysis](https://www.chainalysis.com/blog/latin-america-crypto-adoption-2025/) - [UNODC](https://www.unodc.org/unodc/en/press/releases/2025/May/unodc_-rising-demand-for-minerals-heightening-risks-of-crime--corruption-and-instability.html) - [Global Witness / Amazon Underworld](https://globalwitness.org/en/campaigns/transition-minerals/amazonian-territories-on-the-frontlines-of-the-transition-minerals-race/) - [UK Government (FCDO)](https://www.gov.uk/foreign-travel-advice/peru/safety-and-security) - [Bloomberg](https://www.bloomberg.com/news/articles/2026-06-13/peru-2026-presidential-election-awaits-court-review-of-disputed-votes) - [TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) Coverage gaps fim-int-2026-07-07-G001: Direct verification of sbs.gob.pe o… fim-int-2026-07-07-G001: Direct verification of sbs.gob.pe or gob.pe gazette publications is absent; national-primary coverage currently relies on FATF/GAFILAT multilateral assessments as a substitute. [resolved] fim-int-2026-07-07-G002: No Peru-specific VASP competent-aut… fim-int-2026-07-07-G002: No Peru-specific VASP competent-authority statement beyond an informal SBS disclaimer of regulatory competence is available to confirm the scope of the current legal gap. [resolved] fim-int-2026-07-07-G003: The outcome of the contested 2026 p… fim-int-2026-07-07-G003: The outcome of the contested 2026 presidential runoff and its effect on AML/CFT enforcement continuity is not yet resolved within the research window. [resolved] fim-int-2026-07-07-G004: No quantified data exists on the lo… fim-int-2026-07-07-G004: No quantified data exists on the long-term prosecutorial impact of the Constitutional Tribunal executive-immunity precedent beyond the single ruling event. [resolved] fim-int-2026-07-07-G005: No corroborating second-source (bey… fim-int-2026-07-07-G005: No corroborating second-source (beyond OCCRP) exists for the cross-border money-exchange-house laundering corridor scheme, limiting confidence above Assessed. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No T1 source located for the current status of a formal public beneficial-ownership register for PE beyond the non-public SUNAT filing mechanism. [resolved] fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No T1 corroboration this cycle for the SBS resolution's amendment of PSAV compliance-officer authorisation requirements; only single T3 source. [resolved] fim-int-2026-09-05-G003: Tier D watch jurisdictions (KH/LA/M… fim-int-2026-09-05-G003: Tier D watch jurisdictions (KH/LA/MX/CO) were not actively searched this cycle due to JID-locked dispatch scope for PE. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): The SBS resolution text for the VASP Travel Rule (02648-2024) was not independently re-opened this cycle; commencement date rests on a secondary compliance-commentary source. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): Peru's crypto-market-conduct bill's current procedural status could not be reliably established; sources disagree on its most recent committee action. [resolved] fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D1'}): Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not actively re-run this cycle; pooled union search budget was concentrated on Peru. [resolved] fim-int-2026-10-06-G001: The precise publication date of SBS… fim-int-2026-10-06-G001: The precise publication date of SBS Resolution No. 01917-2026 within the 21-22 July 2026 El Peruano issue has not been independently confirmed from the gazette header; the current recency_date is inferred. [resolved] fim-int-2026-10-12-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-12-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1 (sanctions), D3 (enabler jurisdictions), and D4 (conflict finance) were not substantively searched for Peru this cycle; Tier-1 OFAC/OFSI/UN sources specifically scoped to Peru should be consulted next cycle. [resolved] fim-int-2026-10-12-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-12-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): Primary SBS resolution text for Resolución SBS N.° 01015-2026 and N.° 02648-2024 was not fetched this cycle; reliance on secondary aggregator/vendor reproduction caps confidence at Probable. [resolved] fim-int-2026-10-12-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-12-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): Current status of the RUPIC crypto-exchange licensing bill (Proyecto de Ley N.° 1042/2021-CR) in committee was not confirmed beyond its 2025 return; no 2026 progress update located. [resolved] fim-int-2026-10-25-G001: D3 (enabler jurisdictions) and D4 (… fim-int-2026-10-25-G001: D3 (enabler jurisdictions) and D4 (conflict finance) carried thin or no coverage this cycle for Peru; Tier-D jurisdictions (KH/LA/MX/CO) were not actively searched as the pooled union budget was directed to the bound JID. [open] fim-int-2026-10-25-G002: OFAC actions re Los Tiguerones and … fim-int-2026-10-25-G002: OFAC actions re Los Tiguerones and the Zevallos Gonzales delisting both predate this cycle's recency anchor and could not be confirmed as newly surfaced versus already captured in a prior cycle. [open] fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): The underlying SBS draft resolution text for the new AML-perimeter-extension rule was not retrieved this cycle; only secondary press corroboration was available. [open] fim-int-2026-11-08-G002: No primary source was retrieved thi… fim-int-2026-11-08-G002: No primary source was retrieved this cycle for D1-D4 and D6 Peru-nexus developments; thin coverage carried forward as earned nulls. [open] FIM-GAP-001 (D3): Peru's 2019 FATF/GAFILAT mutual evaluation… FIM-GAP-001 (D3): Peru's 2019 FATF/GAFILAT mutual evaluation found that lawyers and accountants were not yet under AML/CFT supervision, and that risk-based supervision more broadly remained underdeveloped, focused on formal legal-framework compliance rather than effectiveness. FIM-GAP-002 (D3): The Constitutional Tribunal's August 2025 … FIM-GAP-002 (D3): The Constitutional Tribunal's August 2025 ruling halting all criminal probes against a sitting president established a judicial precedent constraining prosecutorial reach over illicit-enrichment and corruption-adjacent investigations during a president's term. FIM-GAP-003 (D5): Peru has no VASP-specific AML/CFT licensin… FIM-GAP-003 (D5): Peru has no VASP-specific AML/CFT licensing statute; SBS has publicly stated it lacks competence to regulate virtual assets, leaving crypto-fiat conversion as an unsupervised private activity with only voluntary AML compliance by exchanges. FIM-GAP-004 (D3): This baseline could not independently veri… FIM-GAP-004 (D3): This baseline could not independently verify a direct sbs.gob.pe or other gob.pe primary-domain publication within the research window; national-primary coverage instead relies on FATF/GAFILAT multilateral assessments of Peru and UN-hosted documents describing Peru's UIF, which is treated per the per-jurisdiction floor rule as an acceptable multilateral first-party assessment substitute. ## Evidence #### Confidence-tiered claims Peru's Travel Rule for virtual-asset service providers commenced on 1 August 2026, two years after its 30 July 2024 publication, binding registered VASPs to data-accompaniment requirements on qualifying transfers. [[Source 1]](#sec-sources) Probable · 1 source Peru's casino and slot-machine operators are covered by SBS Resolution N 01015-2026 (8 April 2026), replacing Resolution 1695-2016, requiring a risk-based SPLAFT programme, a maximum 24-hour STR deadline to UIF-Peru, five-year record retention, and tiered penalties up to 8 UIT, with Mincetur as sanctioning authority. [[Source 1]](#sec-sources) Probable · 1 source Peru's crypto-market-conduct bill remains in consultation stage and unenacted, opposed on the record by SBS, BCRP and MEF; its most recent committee action could not be reliably dated this cycle. [[Source 1]](#sec-sources) Uncertain · 1 source Peru has begun a self-assessment ahead of the FATF fifth round of mutual evaluations commencing 2026, following partial-compliance findings in its 2018 evaluation [[Source 1]](#sec-sources) Probable · 1 source Ley Marco de Comercializacion de Criptoactivos (PL 1042/2021-CR) remains stalled in plenary, opposed by MEF/SBS/BCRP [[Source 1]](#sec-sources) Probable · 1 source MINCETUR-authorised remote gaming and remote sports-betting operators, repealing Resolución SBS N.° 1695-2016 [[Source 1]](#sec-sources) Probable · 1 source ROS to UIF within 24 hours with no minimum monetary threshold; RO mandatory for cash exchanges from USD 2,500 [[Source 1]](#sec-sources) Probable · 1 source Travel Rule chapter requiring PSAVs to transmit originator/beneficiary data on virtual-asset transfers and assess ML/TF risk on self-hosted-wallet transfers, effective 2026-08-01 [[Source 1]](#sec-sources) Probable · 1 source Peru is not among the 22 jurisdictions on FATF's 19 June 2026 Jurisdictions under Increased Monitoring list [[Source 1]](#sec-sources) Probable · 1 source All-share combination of Cirsa (owner of Apuesta Total S.A., an SBS-regulated AML-obliged gambling operator in Peru) into Lottomatica S.p.A., signed 2026-09-02 [[Source 1]](#sec-sources) Probable · 1 source 7th Semana de Prevención de Lavado de Activos (SPLA 2026), 26-30 Oct 2026, covering illegal mining, extortion, human trafficking, virtual assets and AI [[Source 1]](#sec-sources) Probable · 1 source Tiered 2026 Final Beneficial Owner Declaration schedule under Decreto Legislativo N.° 1372 and Resolución N.° 000168-2025/SUNAT, covering approximately 60,000 taxpayers in bands through July, September and November 2026 [[Source 1]](#sec-sources) Probable · 1 source Los Tiguerones (a.k.a. Los Fenix, Los Igualitos), operating in Ecuador and Peru, designated under E.O. 13224 secondary-sanctions-risk provisions [[Source 1]](#sec-sources) Probable · 1 source Anchored in Ley N.° 27693; PSAV obliged entities since 2024 under Resolución SBS N.° 02648-2024; FATF Travel Rule (Chapter VIII) in force since 1 Aug 2026; UIF self-assessment reports compliance with 35 of 40 FATF Recommendations with outstanding request to upgrade R.24 [[Source 1]](#sec-sources) Probable · 1 source Winston Ricardo Zevallos Gonzales (and related Lima-based aviation/investment companies) removed from the SDN List [[Source 1]](#sec-sources) Probable · 1 source Peru's AML/CFT regime is anchored on Ley N.° 27693 and 29038 (UIF-Perú within SBS) and its Reglamento (DS N.° 020-2017-JUS); SBS Resolución N.° 01015-2026 (8 Apr 2026) extended obligated-entity status to remote-gaming and remote-sports-betting operators, requiring a risk-based AML programme, EDD and 24-hour suspicious-activity reporting to UIF-Perú. [[Source 1]](#sec-sources) Probable · 1 source draft AML rule expanding reporting duties for non-SBS-supervised obliged entities [[Source 1]](#sec-sources) Probable · 1 source Resolución SBS N.° 01015-2026 extends AML/CFT regime to remote-gaming and online sports-betting platforms via SPLAFT with 24-hour STR filing [[Source 1]](#sec-sources) Probable · 1 source PL 1042/2021-CR remains in committee since March 2025, no new crypto-specific initiative since July 2026 bicameral Congress [[Source 1]](#sec-sources) Probable · 1 source Peru not added to or removed from grey/black list at October 2026 plenary [[Source 1]](#sec-sources) Probable · 1 source Peru's last GAFILAT mutual evaluation remains the 2018-adopted Fourth Round report [[Source 1]](#sec-sources) Probable · 1 source