CFATF Guyana Anti Money Laundering Reprt

Anti-money laundering
and counter-terrorist
financing measures
The Cooperative
Republic of Guyana
Mutual Evaluation Report
July 2024

| 2
MUTUAL EVALUATION REPORT OF GUYANA
The Caribbean Financial Action Task Force (CFATF) is an inter-governmental body consisting of twenty-
four member states and territories of the Caribbean Basin, Central and South America which have agreed
to implement common countermeasures to address money laundering, terrorist financing and the financing
of proliferation of weapons of mass destruction. For more information about the CFATF, please visit the
website: www.cfatf.org.
This report was adopted by the Caribbean Financial Action Task Force (CFATF) at its May, 2024
Plenary held in Port of Spain, Trinidad and Tobago.
Citing reference:
© 2024 CFATF. All rights reserved. No reproduction or translation of this publication may be made without
prior written permission. Requests for permission to further disseminate, reproduce or translate all or part
of this publication should be obtained from the CFATF Secretariat at cfatf@cfatf.org
CFATF (2024) - Anti-money laundering and counter-terrorist financing measures – The Cooperative
Republic of Guyana, Mutual Evaluation Report.
https://www.cfatf-gafic.org/documents/4th-round-meval-reports

| 3
Table of Contents
Executive Summary.....................................................................................................................................9
Key Findings.............................................................................................................................................9
Risks and General Situation.................................................................................................................... 11
Overall Level of Compliance and Effectiveness..................................................................................... 11
Assessment of risk, coordination and policy setting (Chapter 2; IO.1, R.1, 2, 33 & 34)....................12
Financial intelligence, ML investigations, prosecutions and confiscation (Chapter 3; IO.6, 7, 8; R.1,
3, 4, 29–32) .........................................................................................................................................12
Terrorist and proliferation financing (Chapter 4; IO.9, 10, 11; R. 1, 4, 5–8, 30, 31 & 39.)................13
Preventive measures (Chapter 5; IO.4; R.9–23) .................................................................................13
Supervision (Chapter 6; IO.3; R.14, R.26–28, 34, 35)........................................................................14
Transparency and beneficial ownership (Chapter 7; IO.5; R.24, 25)..................................................14
International cooperation (Chapter 8; IO.2; R.36–40)........................................................................15
Priority Actions.......................................................................................................................................16
Effectiveness & Technical Compliance Ratings .....................................................................................17
MUTUAL EVALUATION REPORT..........................................................................................................18
Preface ....................................................................................................................................................18
Chapter 1. ML/TF RISKS AND CONTEXT..............................................................................................19
1.1 ML/TF Risks and Scoping of Higher Risk Issues...................................................................19
1.1.1 Overview of ML/TF Risks..................................................................................................19
1.1.2 Country’s Risk Assessment & Scoping of Higher Risk Issues .............................................20
1.2 Materiality...............................................................................................................................22
1.3 Structural Elements.................................................................................................................22
1.4 Background and Other Contextual Factors.............................................................................23
1.4.1 AML/CFT strategy ..............................................................................................................23
1.4.2 Legal & institutional framework.........................................................................................23
1.4.3 Financial sector, DNFBPs and VASPs................................................................................27
1.4.4 Preventive measures............................................................................................................31
1.4.5 Legal persons and arrangements........................................................................................31
1.4.6 Supervisory arrangements ..................................................................................................32
1.4.7 International cooperation ...................................................................................................33
Chapter 2. NATIONAL AML/CFT POLICIES AND COORDINATION..................................................34
2.1. Key Findings and Recommended Actions.......................................................................................34

| 4
2.2. Immediate Outcome 1 (Risk, Policy and Coordination)..................................................................35
2.2.1. Country’s understanding of its ML/TF risks.................................................................................36
2.2.2. National policies to address identified ML/TF risks.....................................................................39
2.2.3. Exemptions, enhanced and simplified measures...........................................................................41
2.2.4. Objectives and activities of competent authorities........................................................................42
2.2.5. National coordination and cooperation.........................................................................................44
2.2.6. Private sector’s awareness of risks................................................................................................46
Chapter 3. LEGAL SYSTEM AND OPERATIONAL ISSUES .................................................................48
3.2. Immediate Outcome 6 (Financial Intelligence ML/TF)...................................................................52
3.2.1. Use of financial intelligence and other information .................................................................52
3.2.2. STRs received and requested by competent authorities ............................................................57
3.2.3. Operational needs supported by FIU analysis and dissemination ...........................................61
3.2.4. Cooperation and exchange of information/financial intelligence.............................................64
3.3. Immediate Outcome 7 (ML investigation and prosecution) ............................................................66
3.3.1. ML identification and investigation ..........................................................................................66
3.3.2. Consistency of ML investigations and prosecutions with threats and risk profile, and national
AML policies .......................................................................................................................................70
3.3.3. Types of ML cases pursued .......................................................................................................71
3.3.4. Effectiveness, proportionality and dissuasiveness of sanctions ................................................74
3.3.5. Use of alternative measures......................................................................................................74
3.4. Immediate Outcome 8 (Confiscation)..............................................................................................76
3.4.1. Confiscation of proceeds, instrumentalities and property of equivalent value as a policy
objective..............................................................................................................................................76
3.4.2. Confiscation of proceeds from foreign and domestic predicates, and proceeds located abroad
............................................................................................................................................................77
3.4.3. Confiscation of falsely or undeclared cross-border transaction of currency/BNI ....................81
3.4.4. Consistency of confiscation results with ML/TF risks and national AML/CFT policies and
priorities..............................................................................................................................................83
Chapter 4. TERRORIST FINANCING AND FINANCING OF PROLIFERATION ................................85
4.2. Immediate Outcome 9 (TF investigation and prosecution)..............................................................88
4.2.1. Prosecution/conviction of types of TF activity consistent with the country’s risk-profile.........88
4.2.2. TF identification and investigation...........................................................................................89

| 5
4.2.3. TF investigation integrated with –and supportive of- national strategies................................91
4.2.4. Effectiveness, proportionality and dissuasiveness of sanctions ................................................91
4.2.5. Alternative measures used where TF conviction is not possible (e.g. disruption) ....................91
4.3. Immediate Outcome 10 (TF preventive measures and financial sanctions) ....................................92
4.3.1. Implementation of targeted financial sanctions for TF without delay ......................................92
4.3.2. Targeted approach, outreach and oversight of at-risk non-profit organisations ......................96
4.3.3. Deprivation of TF assets and instrumentalities ........................................................................97
4.3.4. Consistency of measures with overall TF risk profile...............................................................97
4.4. Immediate Outcome 11 (PF financial sanctions).............................................................................98
4.4.1. Implementation of targeted financial sanctions related to proliferation financing without delay
............................................................................................................................................................98
4.4.2. Identification of assets and funds held by designated persons/entities and prohibitions..........99
4.4.3. FIs, DNFBPs and VASPs’understanding of and compliance with obligations ......................100
4.4.4. Competent authorities ensuring and monitoring compliance.................................................101
Chapter 5. PREVENTIVE MEASURES..................................................................................................103
5.1. Key Findings and Recommended Actions.....................................................................................103
5.2. Immediate Outcome 4 (Preventive Measures)...............................................................................105
Chapter 6. SUPERVISION ....................................................................................................................... 119
6.1. Key Findings and Recommended Actions..................................................................................... 119
6.2. Immediate Outcome 3 (Supervision) .............................................................................................121
6.2.1. Licensing, registration and controls preventing criminals and associates from entering the
market ...............................................................................................................................................123
6.2.2. Supervisors’understanding and identification of ML/TF risks...............................................127
6.2.3. Risk-based supervision of compliance with AML/CFT requirements .....................................130
6.2.4. Remedial actions and effective, proportionate, and dissuasive sanctions ..............................135
6.2.5. Impact of supervisory actions on compliance.........................................................................137
6.2.6. Promoting a clear understanding of AML/CFT obligations and ML/TF risks .......................141
Chapter 7. LEGAL PERSONS AND ARRANGEMENTS ......................................................................144
7.2. Immediate Outcome 5 (Legal Persons and Arrangements)............................................................145
7.2.1. Public availability of information on the creation and types of legal persons and arrangements
..........................................................................................................................................................145
7.2.2. Identification, assessment and understanding of ML/TF risks and vulnerabilities of legal
entities...............................................................................................................................................148

| 6
7.2.3. Mitigating measures to prevent the misuse of legal persons and arrangements.....................149
7.2.4. Timely access to adequate, accurate and current basic and beneficial ownership information
on legal persons................................................................................................................................151
7.2.5. Timely access to adequate, accurate and current basic and beneficial ownership information
on legal arrangements ......................................................................................................................155
7.2.6. Effectiveness, proportionality and dissuasiveness of sanctions..............................................155
Chapter 8. INTERNATIONAL COOPERATION ....................................................................................159
8.2. Immediate Outcome 2 (International Cooperation).......................................................................160
8.2.1. Providing constructive and timely MLA and extradition ........................................................161
8.2.2. Seeking timely legal assistance to pursue domestic ML, associated predicates and TF cases
with transnational elements ..............................................................................................................165
8.2.3. Seeking other forms of international cooperation for AML/CFT purposes ............................166
8.2.4. Providing other forms international cooperation for AML/CFT purposes.............................169
8.2.5. International exchange of basic and beneficial ownership information of legal persons and
arrangements ....................................................................................................................................170
Recommendation 1 – Assessing risks and applying a risk-based approach..................................172
Weighting and Conclusion ..............................................................................................................175
Recommendation 2 - National Cooperation and Coordination......................................................175
Recommendation 3 - Money laundering offence..............................................................................176
Recommendation 4 - Confiscation and provisional measures ........................................................178
Recommendation 5 - Terrorist financing offence ............................................................................179
Recommendation 6 - Targeted financial sanctions related to terrorism and terrorist financing 181
Recommendation 7 – Targeted financial sanctions related to proliferation..................................187
Recommendation 8 – Non-profit organisations................................................................................191
Recommendation 9 – Financial institution secrecy laws .................................................................194

| 7
Recommendation 10 – Customer due diligence ...............................................................................195
Recommendation 11 – Record-keeping.............................................................................................200
Recommendation 12 – Politically exposed persons..........................................................................202
Recommendation 13 – Correspondent banking...............................................................................203
Recommendation 14 – Money or value transfer services................................................................205
Recommendation 15 – New technologies ..........................................................................................205
Recommendation 16 – Wire transfers...............................................................................................208
Weighting and Conclusion .............................................................................................................. 211
Recommendation 17 – Reliance on third parties ............................................................................. 211
Recommendation 18 – Internal controls and foreign branches and subsidiaries .........................213
Recommendation 19 – Higher-risk countries...................................................................................214
Recommendation 20 – Reporting of suspicious transaction ...........................................................215
Recommendation 21 – Tipping-off and confidentiality...................................................................215
Recommendation 22 – DNFBPs: Customer due diligence ..............................................................216
Recommendation 23 – DNFBPs: Other measures ...........................................................................217
Recommendation 24 – Transparency and beneficial ownership of legal persons.........................218
Recommendation 25 – Transparency and beneficial ownership of legal arrangements ..............222
Recommendation 26 – Regulation and supervision of financial institutions.................................224

| 8
Recommendation 27 – Powers of supervisors ..................................................................................227
Recommendation 28 – Regulation and supervision of DNFBPs.....................................................228
Recommendation 29 - Financial intelligence units...........................................................................230
Weighting and conclusion ...............................................................................................................232
Recommendation 30 – Responsibilities of law enforcement and investigative authorities ..........232
Recommendation 31 - Powers of law enforcement and investigative authorities .........................233
Recommendation 32 – Cash Couriers...............................................................................................235
Recommendation 33 – Statistics ........................................................................................................237
Recommendation 34 – Guidance and feedback ...............................................................................237
Recommendation 35 – Sanctions .......................................................................................................238
Recommendation 36 – International instruments............................................................................239
Recommendation 37 - MLA...............................................................................................................240
Recommendation 38 – MLA: freezing and confiscation .................................................................241
Recommendation 39 – Extradition....................................................................................................243
Recommendation 40 – Other forms of international cooperation..................................................244
Summary of Technical Compliance – Key Deficiencies ..........................................................................248
Glossary of Acronyms...............................................................................................................................253

| 9
Executive Summary
1. This report summarises the anti-money laundering/counter financing of terrorism
(AML/CFT) measures in place in The Cooperative Republic of Guyana (“Guyana”) as at the
date of the on-site visit from September 4th
– 15th
2023. It analyses the level of compliance
with the FATF 40 Recommendations and the level of effectiveness of Guyana’s AML/CFT
system and provides recommendations on how the system could be strengthened.
Key Findings
a) Guyana has made significant efforts to improve its understanding of AML/CFT
risk via the conduct of multiple risk assessments including (i) a national money
laundering (ML) risk assessment in 2017, that was updated in 2021; (ii) a 2022
Non-Profit Organisation (NPO) terrorist financing (TF) risk assessment; (iii) a
2023 TF risk assessment; (iv) a 2023 sectoral risk assessment on the Extractive
Industries; (v) a 2023 Legal Persons (LP) and Legal Arrangements (LP) risk
assessment; and (vi) a 2023 Virtual Assets and Virtual Asset Service Providers
risk assessment. However, the risk assessment on the Extractive Industries was
not finalised and approved prior to the end of the onsite. Notwithstanding,
Guyana has made significant strides in the implemented activities and objectives
contained within the National Policy and Strategy Plan (NPSP) to address
identified risks such as strengthening cooperation and coordination amongst CAs
and enactment of new, as well as revisions, to key legislation.
b) Guyana has a strong TFS-TF legislative framework and CAs have a general
understanding of the TF risk profile established pursuant to the second NRA and
the updated TF/PF Risk Assessment. However, there are shortcomings regarding
the NPO sector, implementation of TFS without delay and the freezing of assets.
c) CAs in Guyana are able to access a wide range of financial intelligence and other
information in the conduct of ML, TF and other predicate offences investigations.
The FIU of Guyana has access to a wide range of information including suspicious
transactions reports (STRs), threshold transaction reports (TTRs) from reporting
entities (REs), monthly currency declarations from GRA and monthly updates on
basic and beneficial ownership from the Commercial and Deeds Registry. The
FIU of Guyana has, notwithstanding the limited feedback to REs on the quality
of the STRs, demonstrated through intelligence reports, feedback from LEAs and
successful case studies, the good quality of the STRs received. While not all
sectors are reporting, the work of the FIU of Guyana and the products produced,
such as its operational and strategic analysis, support the work of LEAs and CAs.
d) There are multiple LEAs in Guyana investigating associated predicate offences
including GPF-CID, SOCU, CANU and GRA. All ML and TF investigations are
done by SOCU. While CANU, GPF-CID and GRA demonstrated awareness of the
requirement to submit associated predicate offences to SOCU for parallel ML
investigations, the AT was unclear of the parameters used. There was no clear
coordinated effort between the GPF-CID and SOCU for the conduct of parallel
ML investigations. In relation to TF offences, Guyana has had limited TF
investigations with no prosecutions or convictions, and as such the AT was

| 10
unable to determine whether sanctions for TF offences were effective,
proportionate and dissuasive.
e) Guyana pursues confiscation to some extent as a policy objective. Guyana has at
its disposal both criminal and civil asset forfeiture and while all LEAs have
demonstrated the use of confiscation measures, this was not done consistently.
Guyana also does not have any mechanism in place to facilitate the repatriation,
sharing and restitution of proceeds of crime nor does it have a policy to treat with
the management of confiscated assets to ensure value is maintained.
f) AML/CFT supervisors have been designated for FIs and DNFBPs in Guyana.
Overall, risk-based supervision is at a developing stage. For the period of the
mutual evaluation, there was no supervision of some DNFBP sectors (attorneys-
at-law, notaries, accountants and non-financial TCSPs) while for the real estate
sector, supervision was found to be progressing. There was no evidence of
AML/CFT inspections or risk-based supervision of credit unions. For the FIs, the
BOG and GSC have recently revised their respective supervision manuals for a
more risk-based focus and have a range of supervision tools whereby entities are
subject to supervision based on risk assessment or inspections. The GA, GGB
and GGMC have all implemented a strong risk based supervisory framework.
g) The BOG, GSC, GA, GGB and GGMC apply strong licensing, registration and
other controls at market entry, and in some instances during license renewal, to
prevent criminals and their associates from owning or controlling FIs and
DNFBPs. There are adequate mechanisms to detect when FIs and some DNFBPs
breach the licensing and registration requirements.
h) Overall, FIs, with the exception of credit unions, have a good understanding of
their ML/TF risk and AML/CFT obligations and apply mitigating measures to a
large extent. The DPMS and casinos are adequately supervised and have
demonstrated a good understanding of their ML/TF risk and AML/CFT
obligations. There is need for improvement in the understanding and application
of risk-based measures by credit unions, attorneys-at-law, notaries, accountants,
real estate and non-financial TCSPs. STR reporting by the DNFBP sectors has
been low, considering the sectors’ ML/TF risk.
i) There are measures in place to ensure that information on the creation of the
types of legal persons (LPs) in Guyana is publicly available. However, no
information is publicly available on the creation of legal arrangements (LAs).
Also, Guyana is in the process of bolstering its AML/CFT regime inclusive of
legislative amendments, digitization of systems and enhanced domestic
cooperation to mitigate against the misuse of LPs and LAs.
j) The Mutual Assistance in Criminal Matters Act (MACMA), the Fugitive Offenders
Act and the AML/CFT Act provide a strong framework which enables the CAs in
Guyana to seek and provide MLA, extradition and other forms of international
cooperation to foreign counterparts. However, there is no guidance to CAs as to
when either the MACMA or AML/CFT Act, 2009 should be utilized to facilitate
timely international cooperation. Guyana has demonstrated its ability to seek
and provide international cooperation. However, the case management system
could not demonstrate that this was provided in a timely manner.

| 11
Risks and General Situation
2. Guyana, with a landmass of 214, 969 km sq, is located on the north-eastern coast of the continent
of South America. It is bordered by the Atlantic Ocean to the north, Suriname to the east,
Venezuela to the west and Brazil to the south. The location of the country, with most of its
borders situated in the heavily forested hinterland region, makes Guyana vulnerable to drug
trafficking and smuggling of its minerals (such as gold and diamond) as well as wildlife and
lumber. The 2021 NRA mentioned the high value of estimated proceeds from drug trafficking
(US$14.4 million) and gold smuggling (US$2.2 million). These were among the predicate
offences posing the highest ML threat along with tax evasion, fraud, corruption & bribery and
human trafficking. However, the NRA noted that while there were no ML convictions related to
these predicate offences, there were intelligence reports disseminated by the FIU of Guyana
indicating suspicion of ML related to the predicates.
3. Guyana is not an international financial centre but its Gross Domestic Product (GDP) per capital
is quickly increasing with the recently booming oil and gas activity. According to the NRA, in
2015 Guyana became one of the top 20 largest oil and gas reserve holders in the world following
the discovery of oil. Since oil production commenced in 2020, the Guyanese economy registered
growth of real oil and non-oil (mining and quarrying, construction, agriculture and forestry and
the manufacturing sector) GDP of 62.3% and 11.5%, respectively. At the end of December 2022,
the financial sector (comprising the banks, non-banks FIs, insurance brokers and companies,
MTAs, cambios, and pension funds as well as securities companies and brokers) remained a
significant contributor to GDP, with the total financial sector assets equivalent to 92.6% of
Guyana’s non-oil GDP. The banking sector’s assets were equivalent to 60.5% of non-oil GDP.
4. With regard to terrorist financing, the NRA of 2021 rated this as medium risk given the absence
of a national strategic framework for countering TF, minimum cooperation among the key
agencies responsible for analysing, investigating and prosecuting TF and terrorism matters, and
the need for improved legal and institutional frameworks for identifying and combatting TF.
Since the 2021 NRA, Guyana has established a TF Strategy, CTF guidelines were issued,
legislative amendments related to TF were enacted and the NCC sub-committee on TF and PF
was established. Guyana also conducted an assessment of the PF risk. Both the TF and PF risk
assessments were updated giving consideration to data for 2020 to July 2023 against data used
for the 2021 NRA.
Overall Level of Compliance and Effectiveness
5. Guyana has good results on technical compliance with the FATF Standards having made
improvements since the 3rd
Round assessment in 2010 (Report dated July 2011). The country
made significant changes to its AML/CFT legislative regime in 2018, 2022 and in 2023.
However, there remain deficiencies in relation to FATF Recommendations such as TFS, New
Technologies, NPOs and Transparency and Beneficial Ownership of LPs. Guyana made
changes and implemented efforts to improve effectiveness of its AML/CFT system subsequent
to the AML/CFT legislative restructuring. There is a good understanding of its ML risk and fair
understanding of TF risk and the jurisdiction has developed policies and structures to combat
ML and TF. Domestically, there is good coordination and cooperation among CAs but there is
need for improved coordination, particularly among some LEAs (GPF and SOCU). International
cooperation is facilitated by a strong legislative framework, but timeliness was not demonstrated
by the case management system. Risk-based AML/CFT supervision of FIs (except credit

| 12
unions) and some DNFBPs (DPMS, casinos and real estate) is evident and has started to show
results, while it was incipient for credit unions and other DNFBP sectors such as attorneys-at-
law, notaries, accountants and non-financial TCSP.
Assessment of risk, coordination and policy setting (Chapter 2; IO.1, R.1, 2, 33 &
34)
6. Guyana has demonstrated a good understanding of its ML risk and a fair understanding of its
TF risks. Significant efforts were made since 2017 when the first NRA was conducted. Since
then, the country has updated its risk assessment in 2021 and have completed topical risk
assessments of the NPO sector in 2022, LPs and LAs and virtual assets/virtual asset service
providers in 2023.
7. Emerging from the 2021 NRA, Guyana developed, and Cabinet approved the ML/TF/PF NPSP
for the period 2021-2025 that outlined eight key objectives to address identified risks. The
objectives sought to strengthen cooperation and coordination among CAs, improve the
AML/CFT regime (legislative framework, CAs, etc), enhance regional and international
cooperation and ensure transparency of LPs and LAs. By the end of the onsite visit, Guyana
was well on the way to full achievement of these objectives. The AT observed the strong
cooperation and coordination among domestic CAs (particularly in the extractive industries),
a strong awareness of ML/TF risk by the FIs and DNFBPs and improvements in the operational
procedures and resources to some agencies. The NPSP has since been updated with the
conduct of topical risk assessments in 2022 and 2023.
8. Notwithstanding, minor deficiencies remain, as the country needs to have a better
understanding of the ML/TF risk of DNFBPs, particularly that of the attorneys-at-law,
accountants, notaries and TCSP sectors, the extractive industries and the NPO sector. Also,
there are some action items of the NPSP that have not been achieved and domestic
coordination and cooperation among domestic law enforcement agencies must be improved.
Financial intelligence, ML investigations, prosecutions and confiscation (Chapter
3; IO.6, 7, 8; R.1, 3, 4, 29–32)
9. The FIU of Guyana is an administrative type of FIU with responsibility for requesting,
receiving, analysing and disseminating STRs and other information relating to ML, TF or the
proceeds of crime. The FIU of Guyana has access to a wide range of information to assist in
the development of its products. LEAs in Guyana have access to a wide range of information
to develop evidence and trace criminal proceeds. The work of the FIU of Guyana supports the
operational needs of CAs, and Guyana has demonstrated good cooperation and exchange of
information amongst CAs.
10. In Guyana, there are multiple LEAs involved in the investigation and prosecution of ML, TF
and associated predicate offences including SOCU, GPF-CID, CANU and GRA. While LEAs
are aware of the requirement to submit associated predicate offences to SOCU for parallel ML
investigations and have submitted matters, clearer parameters should be developed to ensure
relevant matters are submitted for parallel investigation. Guyana, to some extent, is
investigating in line with its risk profile, and is not pursuing different types of ML, except third
party ML. Guyana has had no convictions for ML in the jurisdiction and while Guyana has a
wide range of forfeiture tools, alternative measures were not consistently pursued where ML
convictions could not be secured.

| 13
11. LEAs in Guyana have demonstrated that they are pursing confiscation to some extent, whether
civil or criminal. However, this is not being consistently done. Guyana has legislation to
facilitate the confiscation of falsely or undeclared cross border transactions of currency and
BNI but has only been confiscating currency, as the inclusion of BNI was recently introduced.
Guyana has no confiscations recorded for ML.
Terrorist and proliferation financing (Chapter 4; IO.9, 10, 11; R. 1, 4, 5–8, 30, 31
& 39.)
12. Guyana has had no convictions for TF during the period under review. Notwithstanding,
Guyana has a strong legislative framework to criminalise TF and there is a general
understanding by the CAs of the TF risk profile. TF matters in Guyana are investigated by
SOCU based on reports from the FIU of Guyana and referrals from other entities. Prosecutions
of TF matters are done by the DPP. The DPP, SOCU and the Judiciary require additional
specialised training to treat with the investigation and prosecution of TF matters. Guyana to a
limited extent demonstrated the use of alternative measures where a TF conviction is not
possible.
13. Guyana has a TFS framework for TF and PF as evidenced in its AML/CFT Act. Some key CAs
in Guyana have not demonstrated a good understanding of the TFS-TF regime.
Notwithstanding, the FIs and DNFBPs within the regulated sectors have a good understanding
of their obligations to implement TFS without delay and to screen against the respective UNSCR
lists.
14. Guyana has implemented some measures to mitigate against the potential abuse of NPOs for
TF purposes. However, there is no focused or proportionate regulation of the NPOs deemed
vulnerable to TF abuse and substantial work remains as it relates to the conduct of a full NPO
sector review, sustained and targeted outreach.
Preventive measures (Chapter 5; IO.4; R.9–23)
15. Preventive measures are applicable to all FIs, DNFBPs as well as VASPs, which were
prohibited by the end of the on-site. The understanding of ML/TF risks and AML/CFT
obligations varied among the FIs and DNFBPs. With regard to understanding ML/TF risks,
banks, insurance providers, the sole payment service provider and securities sector have a good
understanding based on the AML/CFT frameworks implemented and the implementation of
AML/CFT controls, while for credit unions and some cambios, the understanding was limited.
The DPMS and casino sectors demonstrated a good understanding of ML/TF risks but there was
need for improvement among the other DNFBP sectors (real estate agents, attorneys-at-law,
notaries, accountants and non-financial TCSPs).
16. Generally, FIs and DNFBPs understand the AML/CFT obligations and have applied mitigating
measures at varied degrees depending on their maturity and international affiliation. FIs, with
the exception of credit unions, have developed and implemented satisfactory AML/CFT
frameworks and controls such as CDD procedures and the application of EDD with the use of
technology and other tools. This was better among larger MTAs (with franchise operations).
DPMS and casinos are applying mitigating measures commensurate to their risk. The assessment
of implementation of preventive measures by attorneys-at-law, notaries, accountants and non-
financial TCSPs sectors varies depending on affiliation and maturity of the entity.

| 14
17. FIs and DNFBP sectors (casinos and DPMS) have a good understanding and have implemented
TFS screening to a good extent and there is general awareness of reporting obligations with
practical measures implemented to prevent tipping off. While REs understand their reporting
obligations and have controls, there is low STR reporting by the DNFBP sectors which was not
commensurate with sector risk.
Supervision (Chapter 6; IO.3; R.14, R.26–28, 34, 35)
18. AML/CFT supervisors have been designated for all FIs and DNFBPs. However, AML/CFT
supervision for attorneys-at-law, notaries, accountants and non-financial TCSPs was at a nascent
stage with the recent designation of the Guyana Compliance Commission (GCC) via the
Compliance Commission Act, 2023. There was limited supervision of the sectors during the
assessment period, by way of outreach conducted by the FIU of Guyana. Supervision of the credit
union sector by the CCD was at an infancy stage and risk-based supervision was developing.
19. There are licensing, registration and other market entry controls for FIs and DNFBPs. AML/CFT
supervisors of the FIs, Casinos and DPMS (the BOG, GSC, GA, GRA, GGB and GGMC) have
strong controls to prevent criminals and their associates from holding or being the BO of a
significant or controlling interest in an entity. License renewals systems for DPMS and casinos
allows for controls to be implemented on an ongoing basis. The BOG, GSC, GGB and GGMC
have sound systems and sufficient resources to detect licensing breaches.
20. The BOG, GSC, GA, GRA, GGB and GGMC have developed and are implementing risk-based
supervision mechanisms which reflect the ML/TF risks identified in the 2021 NRA, sectoral risk
assessments (BOG) and entity assessments. The supervision framework is continuously
improving as sectoral risk assessments are completed. Supervision includes onsite and offsite
monitoring, training and publication of guidelines and sanctions. The SAs (BOG, GSC, GA,
GRA, GGB and GGMC) have applied remedial action and sanctions (Table 6.6) to some extent,
subsequent to the conduct of inspections or supervisory activities and have demonstrated
consequential improvements in compliance. Supervisors in Guyana have not applied a wide range
of effective, proportionate and dissuasive sanctions.
21. AML/CFT supervision of some DNFBP sectors will intensify with the institution of the GCC.
Transparency and beneficial ownership (Chapter 7; IO.5; R.24, 25)
22. Guyana has various types of LPs that can be created. Guyana also has measures in place to ensure
the collection and public availability of information on the creation of LPs but this does not exist
for LAs. The Deeds and Commercial Registry Authority (DCRA) is the agency responsible for
LPs created under the Companies Act. Information on other types of LPs formed under the
Friendly Societies Act (Friendly Societies) and under the Cooperative Societies Act
(Cooperatives) is maintained by the respective Registrars.
23. The Commercial Registry holds adequate, accurate and current basic information which is shared
with CAs in a timely manner upon request. However, this requirement is not applied to other
types of LPs (Friendly Societies and Cooperatives). CAs can obtain basic and BO information
from FIs and DNFBPs on LPs and LAs and this has been accessed in a timely manner.
24. Guyana has demonstrated to some extent the application of effective, proportionate and
dissuasive sanctions against persons who do not comply with information requirements.

| 15
International cooperation (Chapter 8; IO.2; R.36–40)
25. International cooperation is facilitated by a strong legal framework in place in Guyana (the
Mutual Assistance in Criminal Matters Act, Chap. 15:05 (MACMA), the Fugitive Offenders Act
and the AML/CFT Act). The Minister of Home Affairs is the Central Authority for mutual legal
assistance (MLA) and extradition in Guyana. The manual case management system utilised has
not proven to be efficient to aid in demonstrating timely exchange of information. Also, the
Treaty Office needs to be better resourced to improve the ability to provide and seek timely
international cooperation.
26. Guyana has received MLA and extradition requests from regional and international jurisdictions
relative to various predicate offences. While the overall quality and usefulness of the information
provided could not be ascertained from the feedback provided by the global community, Guyana
did receive positive feedback from some jurisdictions on the quality of assistance provided.
Additionally, there is need to bolster the case management system (CMS) to ensure efficient
management of international cooperation matters and to allow for sufficient details to assess
efforts to seek and provide other forms of international cooperation.
27. CAs, such as the AML/CFT supervisors of FIs, FIU of Guyana and law enforcement agencies,
have sought other forms of international cooperation via bilateral and multilateral agreements,
networks and diplomatic channels. Similarly, there are mechanisms that provide for the CAs to
provide other forms of international cooperation, and this was shared in an appropriate and timely
manner. While there are mechanisms in Guyana to share basic and BO information with foreign
counterparts, there were no instances where such requests were made.

| 16
Priority Actions
Guyana should:
a) Upon completion and approval of the extractive industries risk assessment, update
the NPSP as well as develop or enhance the policies of the respective CAs. There
should be continued implementation of the objectives outlined in the NPSP ensuring
all outstanding activities are completed.
b) Take the necessary measures to strengthen cooperation and coordination among law
enforcement agencies responsible for the investigation of ML, TF and ML/TF related
offences to ensure improved alignment of investigations.
c) Prioritise ML investigations and ensure that all types of ML matters are investigated,
in alignment with the risk profile.
d) Ensure that LEAs are consistently pursuing confiscation in all matters.
e) Provide specialised training on prosecuting TF matters to the ODPP and on treating
with both ML and TF matters to the Judiciary.
f) Establish measures to ensure information on the creation and types of LPs and LAs
are publicly available; maintain adequate, accurate and current records of basic and
BO information; and establish an effective framework to make such information
available to CAs in a timely manner.
g) Upon institution of the GCC and the Real Estate Authority, implement risk-based
supervision of attorneys-at-law, notaries, accountants, Non-Financial TCSP sectors
and efficient transition of risk-based supervision of the real estate sector.
h) For DNFBPs, take measures (i) for supervisors to understand the ML/TF risk of all
sectors and strengthen risk-based AML/CFT supervision; (ii) to improve the STR
reporting by DNFBP sectors; and (iii) to enhance the sectors’ understanding of
ML/TF risk and application of AML/CFT obligations.
i) Ensure that remedial measures and sanctions are proportionate and dissuasive and
applied in a timely and effective manner to ensure a positive effect on compliance by
FIs and DNFBPs.
j) Provide the necessary resources and take steps to improve the maintenance of
relevant statistics and records relating to all forms of international cooperation,
investigations and prosecutions.
k) Ensure that steps are taken to address all technical deficiencies related to TFS related
to TF (including risk-based measures for the NPO sector) and PF and mechanisms
are implemented to give effect to the mandatory freezing of assets and funds without
delay.

| 17
Effectiveness & Technical Compliance Ratings
Table 1. Effectiveness Ratings
IO.1 IO.2 IO.3 IO.4 IO.5 IO.6 IO.7 IO.8 IO.9 IO.10 IO.11
SE ME ME ME ME SE ME ME ME ME ME
Note: Effectiveness ratings can be either a High- HE, Substantial- SE, Moderate- ME, or Low – LE, level of
effectiveness.
Table 2. Technical Compliance Ratings
R.1 R.2 R.3 R.4 R.5 R.6 R.7 R.8 R.9 R.10
LC C C C C LC PC PC LC LC
R.11 R.12 R.13 R.14 R.15 R.16 R.17 R.18 R.19 R.20
LC C LC C PC LC C LC C C
R.21 R.22 R.23 R.24 R.25 R.26 R.27 R.28 R.29 R.30
C LC LC PC PC LC LC LC C C
R.31 R.32 R.33 R.34 R.35 R.36 R.37 R.38 R.39 R.40
LC C C C LC LC LC C C C
Note: Technical compliance ratings can be either a C – compliant, LC – largely compliant, PC – partially
compliant or NC – non compliant.

| 18
MUTUAL EVALUATION REPORT
Preface
This report summarises the AML/CFT measures in place as at the date of the on-site visit. It analyses
the level of compliance with the FATF 40 Recommendations and the level of effectiveness of the
AML/CFT system and recommends how the system could be strengthened.
This evaluation was based on the 2012 FATF Recommendations and was prepared using the 2013
Methodology. The evaluation was based on information provided by the country, and information
obtained by the evaluation team during its on-site visit to the country from 4th
to 15th
September
2023.
The evaluation was conducted by an assessment team (AT) consisting of:
i. Casandra Seetahal, Senior Legal Counsel, Office of Attorney General and Ministry of Legal
Affairs, Trinidad and Tobago (Legal Expert)
ii. Teron Greenidge, Financial Investigator/Analyst, Royal Grenada Police Force, Grenada
(Law Enforcement Expert)
iii. Nikala Bazil, Senior Examiner, Financial Services Unit, Ministry of Finance, Dominica
(Financial Expert)
iv. Shaná Donovan, AML Chief Risk and Policy Officer, Cayman Islands Monetary Authority
(CIMA), Grand Cayman (Financial Expert);
with the support from:
i. Avelon Perry, Financial Advisor, CFATF Secretariat (Mission Leader) and
ii. Sunita Ramsumair, Legal Advisor, CFATF Secretariat (Co-Mission Leader).
The report was reviewed by Tiffany Moss (The Bahamas), Susan Watson Bonner (Jamaica),
Arindam Misra (India), Nazerke Zhampeiis (EAG Secretariat) and the FATF Secretariat.
Guyana previously underwent a FATF Mutual Evaluation in 2010, conducted according to the 2004
FATF Methodology. The 2010 evaluation and the 2011 to 2016 follow-up reports have been
published and are available at https://www.cfatf-gafic.org/.
The 2010 Mutual Evaluation concluded that the country was compliant with one (1)
Recommendation; largely compliant with five (5); partially compliant with fifteen (15); and non-
compliant with nineteen (19). Guyana had all sixteen Core and Key Recommendations rated partly
compliant (PC) and non-compliant (NC) and was placed in expedited follow-up.
Guyana enacted several pieces of key legislation comprising statutes and regulations to strengthen
its AML/CFT framework. In 2016, Guyana presented the Eleventh Follow-up report in which all
the deficiencies identified in the Core and Key Recommendations, initially rated as PC/NC, were
addressed. Having reached a level of compliance comparable to at least LC Guyana applied to exit
the CFATF ICRG and the follow-up process, which was successfully approved by the CFATF
Plenary in Providenciales, Turks and Caicos Islands in November 2016.

| 19
Chapter 1. ML/TF RISKS AND CONTEXT
28. The Cooperative Republic of Guyana (“Guyana”) is the only English-speaking country on the
continent of South America with a landmass of 214,969 square kilometres. It is bordered by
Suriname on the east, Brazil on the south, Venezuela on the west, and the North Atlantic Ocean to
the north and east.
29. Guyana is divided into three counties; Essequibo, Demerara and Berbice and has four geographical
regions; the interior savannahs, the highland region, the hilly sand and clay area and the low coastal
plain. For administrative purposes, Guyana is divided into ten regions. The country participates in
Caribbean regional organizations, and its capital, Georgetown, serves as headquarters for the
Caribbean Community (CARICOM). Guyana has a unicameral parliament known as the National
Assembly. The head of state is an executive president indirectly elected as part of the party list
system and is usually the leader of the majority party. The national assembly has 65 members
elected for a five-year period: 40 elected by proportional representation and indirectly elected by
regional assemblies. The presidential candidate of the party or coalition receiving the most votes
becomes the President, who then appoints the Prime Minister and Cabinet.
30. The judicial system is based on English common law with elements of Roman-Dutch Law and is
presided over by the Supreme Court. Appeals are to the High Court, then the Court of Appeal, and
finally to the Caribbean Court of Justice.
31. Guyana has a small open economy largely based on agriculture and mining and the country’s three
main export commodities are sugar, rice and minerals such as gold, diamond and bauxite. Other
main sectors include fishing and forestry. Guyana’s development prospects have shifted
significantly since the discovery of large offshore oil deposits in 2015. The commencement of oil
production in early 2020 has significantly improved Guyana’s medium-and long-term outlook and
this sector is projected to grow rapidly. Despite a global recession in 2020 as a result of the COVID-
19 crisis, Guyana’s economy grew almost 44%, according to the International Monetary Fund
(IMF). The economy grew 20.1% in 2021 and 62.3% in 2022; the forecast for 2023 is 37.2%
growth. Following record real GDP growth in 2022, the IMF expects real GDP will continue to
grow extremely fast in 2023 (38%) and sustained real non-oil GDP growth of 5.5% is projected.
1.1 ML/TF Risks and Scoping of Higher Risk Issues
1.1.1 Overview of ML/TF Risks
32. Guyana indicated in the 2021 NRA, that the four (4) predicate offences posing the highest ML
threat are smuggling (including gold smuggling), tax evasion, illicit trafficking (in narcotic drugs
and psychotropic substances) and fraud. The estimated value of proceeds generated from these
offences totalled just under US$2.3 billion between 2016 and 2020. Corruption/bribery, terrorism
and trafficking (in humans and migrant smuggling; illicit arms and ammunition) were also predicate
offences identified in the NRA as having medium to medium/high risk. The overall ML threat was
deemed medium-high risk, due to the significant estimated value of proceeds of crime generated
from predicate offences committed in Guyana, as well as the lack of ML convictions.
33. As a result of its geographical location, Guyana is a transit country for cocaine destined to North
America, Europe, West Africa and the Caribbean and is used by the major exporters of illegally
caught and traded wildlife from the South American continent (such as birds, reptiles and wild cats

| 20
including the national animal-the jaguar). Due to the porous borders and remote airstrips and ports,
Guyana is attractive to drug traffickers and smugglers.
34. The NRA identified the Dealers in Precious Metals and Stones (DPMS) sector as highly vulnerable
to ML because of the cash intensiveness of the sector, the nature of business where transactions are
conducted in the interior locations and the lack of adequate identification documentation by both
customers and dealers.
35. The national TF risk is rated as medium in the 2021 NRA, given the absence of a national strategic
framework for countering TF, minimum cooperation among the key agencies responsible for
analysing, investigating and prosecuting TF and terrorism matters, and the need for improved legal
and institutional frameworks for identifying and combatting TF. According to the 2023 updated
TF/PF risk assessment, Guyana increased its understanding of the TF risk (inter alia conduct of
NPO risk assessment and intensified outreach in 2023) and have implemented mitigation measures
(for instance, Memoranda of Understanding [MOUs] to facilitate sharing among relevant CAs and
enhanced scope of supervision). Notwithstanding, the TF risk remains medium.
1.1.2 Country’s Risk Assessment & Scoping of Higher Risk Issues
36. Guyana’s second NRA, which was completed in July 2021, was an update of the 2017 NRA. A
working group (WG) which comprised seventy (70) key experts/professionals representing over
forty (40) public and private sector organisations in Guyana was established to conduct the NRA.
The WG utilized quantitative methods (such as questionnaires sent to key public and private sector
organizations) and qualitative methods (such as focused group interviews and meetings) data to
arrive at the findings. The NRA Report, which was published in August 2021, identifies
vulnerabilities, threats and consequences associated with risks.
37. Notwithstanding challenges posed by the COVID-19 pandemic and responding emergency
measures instituted by the government, the WG reorganized its work plan and utilized virtual
platforms to obtain information from the private and public sector organisations and to finalize the
report.
38. Additionally, Guyana conducted several topical risk assessments subsequent to the 2021 NRA: a
risk assessment on NPOs (2022), Legal Persons and Arrangements (2023), Virtual Assets and
Virtual Asset Service Providers (2023) and Extractive Industries (2023). Guyana also updated its
TF/PF risk assessment which sets out how the implementation of several measures helped strengthen
mitigation actions relative to TF and PF.
39. The assessors reviewed material provided by Guyana on its national ML/TF risks and information
from reliable open sources (e.g., reports of other international organisations). As such, the AT
focused on the following priority issues:
a. FIs and DNFBPs’ implementation of AML/CFT obligations and risk-based supervision of the
sectors: The financial sector in Guyana comprises the banks, non-banks FIs, insurance
companies and brokers, MTAs, cambios, and pension funds, which are all regulated and
supervised by Bank of Guyana (BOG); and securities companies and brokers which are
regulated and supervised by the Guyana Securities Council (GSC). The banking sector
comprises the largest contributor to the non-oil & gas GDP. The AT focused on the preventive
measures implemented by FIs, particularly the banking and MTA sectors. The AT placed greater
focus on the effectiveness of their CDD framework and their STR reporting mechanisms.

| 21
b. The DNFBP sector in Guyana consists of Dealers in Precious Metals, Dealers in Precious and
Semi-Precious Stones/Licensed Traders (collectively referred to as Dealers in Precious Metals
and Stones [DPMS]), casinos, betting shops, lotteries, real estate (includes agents and
developers), attorneys-at-law, accountants, notaries/Commissioners of Oaths to Affidavits, non-
financial trust and company service providers (TCSPs), and used car dealers/car parts dealers.
While the sectors are required to comply with AML/CFT/PF obligations, the true size and value
of the various sectors (excluding casinos and DPMS) are unknown, and the attorneys-at-law and
accountants are not subject to AML/CFT supervision. The AT focused on the development of
the AML/CFT/PF risk understanding of the DNFBP sectors, the effectiveness of the preventive
measures implemented and the supervisory framework, including the sanctions regime and
extent of cooperation among SAs.
c. Beneficial Ownership (BO) information: The Assessors examined the procedures in place to
obtain and verify the accuracy of BO information at the Commercial Registry, the capacity of
the Commercial Registry to carry out its functions, the mechanisms in place at supervised
entities to obtain, verify and maintain accurate and up-to-date BO information and the CAs’
ability to access such BO information in a timely manner.
d. ML proceeds from Corruption: The AT focused on (i) the understanding of the ML risks
associated with corruption offences; (ii) the extent to which CAs are identifying, tracing,
confiscating and taking other provisional measures relative to proceeds generated from
corruption offences; (iii) mitigation measures implemented by law enforcement authorities and
other agencies responsible for corruption; (iv) the extent to which law enforcement authorities
are conducting parallel financial investigations into corruption offences to identify ML offences;
and (v) the alignment with resources provided for the investigation and prosecution of ML
activities related to corruption and confiscation of illicit proceeds.
e. ML proceeds from Drug Trafficking: Focus was placed on (i) CAs’ understanding of the ML
risks associated with the threat of drug trafficking and the implementation of risk mitigation
measures; (ii) the extent to which CAs are conducting parallel investigations into drug
trafficking offences to identify potential ML cases; and (iii) the extent to which CAs trace,
seize/restrain and forfeit proceeds from drug trafficking. The extent and the level of
effectiveness of domestic as well as international cooperation was also examined.
f. Cross Border Smuggling: Guyana’s borders continue to pose a challenge for the authorities who
find it extremely difficult to monitor the borders linked to Suriname, Venezuela and Brazil. It is
estimated that approximately 25% to 35% of the borders are effectively controlled and regulated
by local authorities. On a national level, the army, border police, immigration officers and
customs coordinate the country’s border control and security. The Assessors examined
Guyana’s approach to border controls and mechanisms, including cooperation (domestic and
international), to prevent, detect and prosecute the illegal cross border activities such as the
smuggling of wildlife, migrants, gold and other minerals. There was also focus on the extent to
which CAs are (i) conducting parallel investigations into these offences to identify potential ML
cases and (ii) tracing, seizing/restraining and forfeiting proceeds from these offences. The extent
and level of effectiveness of domestic and international cooperation regarding these offences
was also considered.
g. Human Trafficking: The AT focused on the risk mitigation measures and the effectiveness of
CAs’ ability and efforts to trace, seize/restrain and forfeit proceeds from human trafficking.

| 22
h. Terrorist Financing (TF): TF was rated medium in the 2021 NRA and while Guyana had not
yet completed a counter TF strategy, there are mechanisms in place to mitigate the risk. There
are also ongoing investigations and persons/entities before the courts for terrorism and TF
related offences. The AT focused on the effectiveness of Guyana’s counter terrorism
mechanisms (including the regulation of the NPO sector) as well as efforts to mitigate and
prosecute TF.
40. Through the scoping exercise, the following area was identified for lesser focus:
a. ML proceeds from tax evasion: While tax evasion is not a legislated offence, Guyana recognizes
that it poses a high threat of ML. Over the period 2016 to 2019 the Guyana Revenue Authority
(GRA) confiscated property in relation to offences such as failure to declare and dealing with
goods to defraud revenue and duties. There were also reports that concealed precious metals
are transported across Guyana’s borders to avoid payment of the relevant taxes and duties. The
focus of the AT was the legal framework for tax evasion, reporting on STRs related to the
offence and the effectiveness of investigations, prosecutions and convictions related to tax
evasion.
41. The following was identified as an emerging issue:
a. Guyana completed its risk assessment of virtual assets (VA) and virtual asset service providers
(VASPs) in August 2023 and took a policy decision to prohibit the activities in the jurisdiction.
With the potential increase in foreign investors because of the growing oil and gas economy, it
is likely that the use of VAs for payment of goods and services can emerge in Guyana. The
Assessors examined this prohibition and the extent to which Guyana is effectively implementing
the prohibition in practice to identify illicit VA/VASP activities.
1.2 Materiality
42. Guyana is an English-speaking country located on the north-eastern coast of the continent of South
America with a total landmass of 214,969 square kilometres. Guyana shares borders with Venezuela,
Brazil and Suriname. Most of the borders are situated in the hinterland region which is heavily
forested. The banking sector comprises the largest contributor to the non-oil & gas GDP. By the end
of December 2022, the financial sector remained a significant contributor to GDP with the total
financial sector assets equivalent to 92.6% of Guyana’s non-oil GDP. The banking sector assets
were equivalent to 60.5% of non-oil GDP. The economy of Guyana, up until recently, has been
largely based on agriculture and mining, with the country’s three main export commodities being
sugar, rice and minerals such as gold, diamond and bauxite. However, with the recent oil and gas
activity, Guyana’s GDP per capita is quickly increasing. The IMF has predicted that oil GDP can
grow by approximately 30% on average per year during 2023 to 2026. According to the NRA,
Guyana is named a transit point for illegal narcotics. The risk of illicit funds associated with illegal
drug trade being transferred through the Guyana financial system is high, notwithstanding there are
effective controls and mechanisms for official cross border money transfers. The value of transfers
by the Money Transfer Agencies (MTA) sector amounted to USD$388.8 million at the end of 2022
which was a 0.09% decrease from the previous year. It is noted that a typology published by the FIU
of Guyana indicated MTAs are used to create layering of transactions to facilitate the distancing of
illicit funds from its source through a series of complex transfers.
1.3 Structural Elements
43. Guyana has all the key structural elements required for an effective AML/CFT system, including
political and institutional stability, governmental accountability, the rule of law, and an independent

| 23
judiciary. The independence of the judiciary is premised on the separation of powers, principles of
natural justice and procedural fairness in the judicial process. The political hierarchy of the
jurisdiction is committed to the improvement of the AML/CFT regime. Similarly, Guyana exhibited
political and institutional stability which demonstrates a high-level commitment to addressing
AML/CFT concerns and deficiencies.
1.4 Background and Other Contextual Factors
44. Guyana made significant changes to its AML/CFT legislative framework inclusive of amendments
in 2010, 2015, 2016, 2017, 2018, 2022 and 2023 to the AML/CFT Act, 2009 and its Regulations;
and enacted the (i) Combatting of Trafficking in Persons Act (which establishes a Counter-
Trafficking in Persons Unit), (ii) the Compliance Commission Act, 2023 and (iii) the Real Estate
Agents and Brokers Act, 2023. The latter two legislation introduced two (2) new SAs for DNFPB
sectors (see section 1.4.6) to Guyana’s AML/CFT regime. By the end of the on-site these two SAs
were not yet constituted.
45. Guyana has low bank density and many remote communities without access to modern
telecommunication and banking systems. Therefore, financial inclusion is critical to Guyana
achieving its Sustained Development Goals and consequentially reducing the influence of the
underground and informal delivery channels for financial services. A financial inclusion evaluation1
of ML/TF risk new and existing products offered in Guyana, identified 8 financial inclusion product
categories: micro-loans (pawnbroker loans), mobile payments, low-income mortgage, money
remittance services, kid’s savings accounts, passbook savings, senior citizens account and statement
savings account. The evaluation sought to, among others, design risk- based approaches to CDD and
regulation and to implement risk mitigating measures. Simplified due diligence can be permitted as
a measure to remove some of the impediments to financial inclusion.
1.4.1 AML/CFT strategy
46. Guyana’s National Policy and Strategy Plan (NPSP) is informed by the NRA of 2021. The NPSP
which was approved by Cabinet on March 2, 2023, is a five-year plan (2021 – 2025) that aims to
further enhance and improve Guyana’s AML/CFT/PF regime. The fundamental objectives of the
Strategy are to ensure that Guyana achieves a high level of compliance with the FATF Standards on
combating ML, TF and PF. The document provides a guide to the AML/CFT CAs and agencies of
actions required to improve the effectiveness of the AML/CFT framework.
47. The NPSP comprises eight (8) key objectives (See Box 1.1) and outlines the action items, timeframe
and primary agency with responsibility. The Anti-Money Laundering/Countering the Financing of
Terrorism/Proliferation Financing National Coordination Committee (NCC) is mandated to monitor
progress and achievement of initiatives.
1.4.2 Legal & institutional framework
48. The principal laws relevant to Guyana’s AML/CFT systems are as follows:
1
According to the NRA (2021) the evaluation followed the guidance of the World Bank’s Financial Inclusion Product
Risk Assessment Tool.

| 24
Table 1.1. Legislative Framework
Title of Legislation
Purpose
Anti-Money Laundering and Countering the
Financing of Terrorism Act, 2009 (including
subsequent amendments)
An Act to provide for the establishment and management of a Financial
Intelligence Unit; to provide for unlawful proceeds of all serious offences to
be identified, traced, frozen, seized and forfeited; to provide for
comprehensive powers for the prosecution of money laundering, terrorist
financing and other financial crimes; and the forfeiture of the proceeds of
crime and terrorist property; to require REs to take preventive measures to
help combat money laundering and terrorist financing; to provide for civil
forfeiture of assets and for matters connected therewith.
Anti-Money Laundering and Countering
Financing of Terrorism Regulation, 2010
Provides guidance to regulated entities
Anti-Money Laundering and Countering
Financing of Terrorism Regulation, 2015
Provides guidance on targeted financial sanctions
Anti-Money Laundering and Countering the
Financing of Terrorism (Miscellaneous)
Regulations, 2023
Provides for miscellaneous changes inter alia risk-based approach to NPOs,
issuance of beneficial ownership guidelines.
Anti-Terrorism and Terrorist Related Activities
Act, 2015
An Act to criminalise terrorism, and terrorist related activities and to provide
for the detection, prevention, prosecution, conviction and punishment of
terrorism and terrorist related activities.
Compliance Commission Act, 2023 An Act to provide adequate supervision to REs for compliance with
obligations under the Anti-Money Laundering and Countering the Financing
of Terrorism Act; to enhance the compliance, guidance and training regime
on money laundering, terrorism financing and proliferation financing in
Guyana; to provide domestic and international cooperation; prohibition of
VAs/VASPs; and to provide for other related matters.
Real Estate Agents and Brokers Act, 2023 An Act to provide for the registration and regulation of Real Estate Agents
and Brokers in Guyana; to promote transparency, accountability and integrity
in the Real Estate profession; to protect and assist persons engaged in
transactions with Real Estate Agents and to assist in the detection and
prevention of money laundering, terrorist financing and proliferation financing
and to provide for other related matters.
49. The agencies responsible for the formulation and implementation of Guyana’s AML/CFT
system are as follows:
a. Ministry of Legal Affairs, Attorney General’s Chambers: The Attorney General’s
Chambers and Ministry of Legal Affairs is the Ministry of the Government of Guyana with
the responsibility of being the Government’s Chief Legal Advisor; being the Prime Contact
for Guyana in AML/CFT/CPF related matters and facilitating the Secretariat of the NCC.
b. Ministry of Natural Resources (MNR): The MNR is responsible for developing,
implementing and overseeing policies for the responsible exploration, development and
utilisation of natural resources. This includes petroleum resources, precious metals and
stones and forest products. The MNR provides policy direction and guidance to the Guyana
Geology and Mines Commission, the Guyana Gold Board and the Guyana Forestry
Commission.
c. Ministry of Home Affairs (MOHA): The MOHA oversees the following agencies- Guyana
Police Force, Guyana Fire Service, Guyana Prison Service, General Registrar Office,
Juvenile Justice Department, Customs Anti-Narcotic Unit, Guyana Forensic Science Lab,
National Community Policing of Guyana and Immigration Support Services. The Minister

| 25
of Home Affairs is the central authority for Guyana and was established under the Mutual
Assistance in Criminal Matters Act 2009 which is an Act to give effect to the scheme relating
to Mutual Assistance in Criminal matters within the commonwealth; and to provide for
mutual assistance in criminal matters between Guyana and countries that have a treaty with
Guyana concerning assistance.
d. Office of the Director of Public Prosecutions (ODPP): The ODPP is a constitutional body
established under Article 116 of the Constitution of Guyana with its functions set out under
Article 187 of the Constitution. Such functions include: (a) instituting and undertaking
criminal proceedings against any person before any court other than a court-martial, in
respect of any offence against the laws of Guyana; (b) taking over and continuing any such
criminal proceedings that may have been instituted by any other person or authority; and (c)
discontinuing, at any stage before judgement is delivered, any such criminal proceedings
instituted or undertaken by the Director of Public Prosecutions or any other person or
authority.
e. Guyana Police Force (GPF): The GPF is an agency established under the Police Act 1957
and is a CA in relation to the fight against crime and the protection of life, and preservation
of law and order in Guyana. The Immigration Department is part of the GPF with
responsibility for passport and other services at the various ports of entry.
f. Financial Intelligence Unit of Guyana (FIU of Guyana): The FIU of Guyana is established
under section 9(1) of the Anti-Money Laundering and Countering the Financing of
Terrorism Act 2009, as an agency responsible for requesting, receiving, analysing suspicious
transaction reports and dissemination of financial intelligence reports and other information
relating to money laundering, terrorist financing or proceeds or crime, and associated serious
offence.
g. Customs Anti-Narcotic Unit (CANU): The CANU is a body established by Cabinet
Decision in 1994 which was implemented in 1995 and empowered to discharge various
functions under the Narcotic Drugs and Psychotropic Substances (Control) Act 1998, Cap
10:10 as amended. This body deals with the fight against drug trafficking and effects seizures
of such and its instrumentalities.
h. Special Organised Crime Unit (SOCU): The SOCU is a unit of the Guyana Police Force
and a CA appointed under the Anti-Money Laundering and Countering the Financing of
Terrorism Act 2009 to carry out investigation into money laundering, terrorist or
proliferation financing, serious offences or proceeds of criminal activity.
i. The Deeds and Commercial Registries: The Deeds and Commercial Registries Authority is
a corporate body established under the Deeds and Commercial Registries Authority Act
2013 with functions assigned to the Registrar of Deeds; and the Registrar of the Commercial
Registry under Section 4 of the Act. The Purpose of the Deeds and Commercial Registry is
to efficiently and expeditiously administer the laws enacted by Parliament affecting land,
whether by way of transport, leases, mortgages or any other alienation thereof; as well as
those laws relating to trademarks, patents and designs, geographical indications, copyrights,
trade unions, companies, partnerships, business names, powers of attorney, bills of sale
contracts and other deeds.
j. Bank of Guyana (BOG): The BOG is established under section 3 of the Bank of Guyana
Act No. 19 of 1998 as an autonomous institution governed by the Act. The BOG may

| 26
exercise any of its functions entrusted to it by or in accordance with the Act or any other Act
or by or under any international agreement to which Guyana is a party or which is otherwise
binding on Guyana and may do any other banking business incidental or ancillary to or
consequential upon the performance of its functions. The BOG is the prudential supervisor
for banks licensed under section 4 of the Financial Institution Act 1995; insurance businesses
licensed under section 40 of the Insurance Act No. 17 of 2016; money transfer agencies
registered under section 4(1) of the Money Transfer Agency (Licensing) Act No. 20 of 2009;
dealers in foreign currency licensed under section 4(1) of the Dealers in Foreign Currency
(Licensing) Act 1989 (No. 19 of 1989); payment service providers licensed under sections
10 and 11 of the National Payment Systems Act No. 13 of 2018. The BOG is the AML/CFT
SA for banks, insurance companies (including pensions), money transfer agencies, dealers
in foreign currency (cambios), and payment service providers.
k. Guyana Revenue Authority (GRA): The GRA was established on January 27, 2000,
following the merger of the Inland Revenue and Customs & Excise Departments and draws
its overall mandate from the Revenue Authority Act, the Customs Act and the Income Tax
Act of Guyana. As Guyana’s tax authority, the GRA has responsibility for, amongst other
things, collecting domestic and customs tax revenues, issuing licences, and collecting fees
for other agency functions. The Customs, Excise and Trade Operations of the GRA has the
responsibility for facilitating trade while effectively administering the Customs, Trade and
Boarders Laws of Guyana. It has a Customs Division responsible for the administration of
import and export of goods, and application of a tariff regime according to the laws of
Guyana and its international obligations under various agreements. GRA also functions as
the AML/CFT SA for used car dealers, real estate agents and pawnbrokers.
l. Guyana Geology and Mines Commission (GGMC): The GGMC was created in 1979 from
the Department of Geological Surveys and Mines which itself was the successor to the
Geological Survey of British Guiana. Currently the GGMC is divided into the following
technical divisions- Geological Services, Mines, Environment, Petroleum and Land
Management. The GGMC issues licences to trade in valuable minerals and precious stones
and is the AML/CFT SA for Dealers in Precious and Semi-Precious Stones referred to in
Guyana as Diamond Dealers and Licensed Traders.
m. Gaming Authority of Guyana (GA): The GA was launched on December 1, 2008. The
functions of the Gaming Authority as a Regulatory body in keeping with the Gambling
Prevention Act, Cap 9:02 (As Amended by The Gambling Prevention (Amendment) Act No.
5 of 2007, and under the Gambling Prevention (Establishment of Gaming Authority)
Regulations 2008 are as follows: Issuance of Licenses under Section 32 of the Act;
monitoring of Casino Operators in Guyana; administration of regulations made under the
Act; advising the relevant Minister with respect to the administration of the regulation; and
any other relevant matter. The Gaming Authority is the AML/CFT SA for the following
REs- Casinos, Lotteries and Betting Shops.
n. Guyana Gold Board (GGB): The GGB was established pursuant to the Guyana Gold Board
Act as the agency responsible for issuing licences to dealers to sell, buy and export gold. The
Board was established primarily to carry on the business of trading in gold and regulate the
purchase and sale of gold in Guyana. Under the Act, all gold produced in Guyana must be
sold to the Board or an authorised dealer. The Guyana Gold Board is the AML/CFT SA for
Dealers in Precious Metals referred to a Gold Dealers, in Guyana.

| 27
o. Guyana Securities Council (GSC): The GSC is the regulatory body established under the
Securities Industry Act 1998 (SIA) as amended, to ensure orderly growth and development
of the securities market. The GSC is the AML/CFT SA for securities companies related
activity as set out in the Fourth Schedule of the AML/CFT Act.
p. Department of Cooperative & Friendly Societies: The Chief Cooperative Development
Officer (CCDO) and Registrar of Friendly Societies (RFS) are appointed as a SA under the
Anti-Money Laundering and Countering the Financing of Terrorism Act 2009. Under the
Cooperatives and Friendly Societies Act, Friendly Societies and Cooperatives are registered
subject to fulfilling the necessary conditions.
q. Guyana Wildlife Conservation and Management Commission: The Guyana Wildlife
Conservation and Management Commission is a body corporate established under the
Wildlife Conservation and Management Act 2016 and is responsible for the protection,
conservation, management, sustainable use, internal and external trade of Guyana’s wildlife.
1.4.3 Financial sector, DNFBPs and VASPs
50. This section gives general information on the size and make-up of the financial institutions (FIs)
and Designated Non-Financial Businesses and Professionals (DNFBPs) in Guyana. Not all
sectors are of equal importance given Guyana’s risks and context.
51. The AT ranked the sectors based on their relative importance based on their importance,
materiality and level of ML/TF risks, as well as Guyana’s contextual factors. Rankings were
used to inform the Assessor’s conclusions throughout this report, weighting positive and
negative issues more heavily for important sectors than for less important sectors. This approach
applies throughout the report but is most evident in Chapters 6 (IO.3) and 5 (IO.4).
52. Banks, MTAs and DPMS were weighted highly important based on the following factors:
a. Banking sector: The banking sector comprises six (6) commercial banks and accounts for
65% of financial sector assets. The sector, regulated by the BOG, offers a wide range of
products and services and serves a broad spectrum of corporate and individual customers,
including higher-risk customers such as politically exposed persons (PEPs). In the 2021
NRA the sector risk was rated Medium.
b. Money Transfer Agencies (MTAs): MTAs are FIs licensed under the Money Transfer
Agencies (Licensing) Act, to carry on the business of money transfers. As such, an MTA
performs the activities of Money Value Transfer Services (MVTS) defined in the FATF
Standards. There were three (3) MTAs licensed to operate in Guyana as at December 31,
2022. MTAs in Guyana can have agents. The Guyana Post Office operates as an agent for
one of the licensed MTAs. The client base of MTAs includes local as well as foreign natural
and LPs as well as PEPs. The level of cash activity by MTAs is high and the aggregated
value of transfers by MTAs at the end of 2019 amounted to USD 282.1 million. The sector
risk was rated Medium in the NRA (2021).
c. DPMS: The DPMS sector in Guyana is made up of (i) dealers in precious metal (gold
dealers), licensed by the GGB, (ii) dealers in precious and semi-precious stones and (iii)
traders in valuable minerals and precious stones which comprise dealers in precious metals
and/or dealers in precious and semi-precious stones, licensed by the GGMC. The dealers
trade in gold, smelted gold, rough diamonds and other minerals. Their suppliers are mainly
miners, and the customers include refineries in countries such as Belgium, Dubai and India.

| 28
In order to export gold, precious stones and minerals, a certificate from the GGB and GRA
must be presented at the port and an inspection of the goods conducted. The NRA indicated
one major concern with the sector was that transactions are conducted in interior locations,
under conditions where miners and/or licensed traders may not always have (in their physical
possession), their identification documents. This makes it difficult for some dealers to
establish business relationships in the absence of customer identity. The sub-sectors’ risks
were rated (i) Medium, (ii) Medium Low and (iii) Medium in the NRA respectively.
53. Real estate, casinos, cambios, attorneys-at-law, accountants, notaries, non-financial trust and
company service providers and credit unions were weighted moderately important based on the
following factors:
a. Real Estate: In Guyana, real estate business falls into the category of informal economic
activities nonetheless to a lesser extent than other businesses. The GRA issues house agent
licences pursuant to S.29 of the Tax Act, Cap 81:01 to every person who acts as or carries
on the business of a house agent or commission agent for the sale of houses, tenements or
immovable property. The number of real estate market participants is approximately sixty-
five (65). Based on tax and financial information, the real estate sector contributed 0.3% to
total tax revenue in 2022. It was noted, however, that the real estate market is experiencing
a surge with the new economic activity resulting from oil and gas production. The sector
risk was rated Medium in the NRA, notwithstanding the sector’s lack of participation.
b. Casinos: Casinos are licensed by the Gaming Authority, with a total asset size of
US$12,777,439 as of 2021, providing both table and slot machines games. Notwithstanding
the attraction and ML/TF threats and vulnerabilities applicable to casino operations, the
sector in Guyana is not as attractive given the low tourist traffic and domestic customer base.
There are two (2) casinos licensed to operate in Guyana. The sector risk was rated Medium
Low in the NRA.
c. Cambios: Cambios are businesses authorized to buy and sell foreign currencies pursuant to
Regulation 13 of the Dealers in Foreign Currency [Licensing] Act. Cambios do not use
agents and their customer base includes local as well as foreign natural and LPs including
PEPs. The majority of currency transactions involve the USD. A precautionary measure
instituted by the BOG is to ensure that no one person can be licensed as an MTA and a
Cambio Dealer at the same time. The sector risk was rated Medium in the NRA.
d. Attorneys-at-Law: The Legal Practitioners’ Act, Cap 4.01 provides for the acceptance of an
eligible person to the Bar. There is an average of one thousand, one hundred and twenty
(1,120) attorneys-at-law registered on the court’s roll (inclusive of deceased, members of the
judiciary, migrated, in public and private practice) and one hundred and fifty-seven (157)
law firms registered with the Commercial Registry. However, the number of attorneys-at-
Law in Guyana who perform the activities defined in the FATF Standards is unknown.
While the sector did not participate in the 2021 NRA, the sector was rated in the NRA
considering that three (3) attorneys-at-law were subject to ML investigations and the sector
has a medium-high ML vulnerability. In the absence of information about the nature of the
sector (activities and services provided, types of clients serviced, asset size or contribution
to GDP, etc), the sector risk was rated Medium in the NRA. The AT also noted that the
sector was not supervised for AML/CFT compliance during the assessment period.
e. Accountants: To provide accounting/auditing services as a public practitioner, the
practitioner must be Association of Chartered Certified Accountants (ACCA) qualified. The

| 29
Institute of Chartered Accountants of Guyana (ICAG) grants a practice certificate to
members who are eligible to provide public accounting or auditing services. The number of
accountants performing the activities as per the definition in the FATF Standards is
unknown. However, the ICAG reported a total of one hundred and forty-nine (149) members
in its 2019 annual report. It was noted that 33% of the members are actively in practice.
The sector risk was rated Medium High in the NRA.
f. Notary Public: Notaries are appointed by warrant under seal by the President of Guyana in
accordance with the Public Notaries Act, Cap 4:02. A notary must be a legal practitioner
for ten years to be appointed but notarial services are different from those provided by
attorneys-at-law. Services include: authenticate, by their signature and official seal or stamp,
and certify the due execution in their presence of some deed or document (powers of attorney
and Deed Polls for name change); prepare certain instruments and agreements for clients
(legal and natural persons); or verify something done in their presence. Based on the 2017
NRA, there are approximately twenty-nine (29) notaries public. Table 1.3 shows the number
believed to be operating at December 2022. The sector risk was rated Medium Low in the
2021 NRA.
g. Non-Financial Trust and Company Services Provider (TCSP): At the time of the 2021 NRA,
the size of this sector was unknown and an AML/CFT supervisor was not appointed. The
AT was informed during the onsite that one or more of the services are usually performed
by attorneys-at-law and accountants. These entities are not FIs. The Compliance
Commission Act (2023) makes provision for the registration of the entities, AML/CFT
supervision of the sector and describes the nature of activities performed, which aligns with
the FATF definition of Trust and Company Service Provider. The ML/TF risk of the sector
was rated as Medium in the NRA.
h. Credit Unions: A credit union is a financial cooperative society established according to the
Cooperative Societies Act. credit unions contribute a minor fraction to the country’s GDP.
The number cooperatives registered in Guyana includes 26 credit unions as at December
2022. The majority of credit unions are closed bond, with a large segment of the membership
as employees of the affiliated organisation, and a few with an open bond making the sector
one of low cash intensiveness. Upon retirement or resignation, the employee has the option
to remain a member or close their accounts. As such, contributions and payments by
members are made via standing orders with the company. Guyana does not deem credit
unions as FIs and they are not treated as such. The Office of the Chief Cooperative
Development Officer (CCDO) is the appointed AML/CFT supervisor. However, there is
limited AML/CFT supervisory framework in place nor does the CCDO have an
understanding of the ML/TF threats, vulnerability or risks to the sector. The sector risk was
rated Low in the NRA.
54. Building Society, Insurance and Pension sector, Payment Service Providers and Securities and
Trust Company were weighted of least importance based on the following factors:
a. Building Society: There is one building society in Guyana that provides services to members
such as mortgages, purchasing of real estate, and deposits which members apply towards
shares within the society. The activities in this sector are not significant. The sector risk was
assessed with banks and collectively rated as Medium.
b. Insurance and Pensions: The insurance sector provides traditional insurance. At the end of
2022, there were seventeen (17) companies licensed to conduct insurance business in

| 30
Guyana with six (6) licensed brokers. Assets accounted for 8.9% of total financial assets and
10.9% of the national GDP. Five (5) of the companies were licensed to conduct life / long-
term insurance business, while the other eleven (11) were licensed for general insurance
business. The insurance companies are locally incorporated, except for the operation of two
foreign branches. Cash payment of premiums was lower for all insurance products. The
sector risk was rated Medium Low in the NRA.
c. Payment Service Provider (PSP): There is one entity licensed by the BOG, under the
National Payments System Act of 2018, to provide “payment services (i.e. services of
enabling cash deposits and withdrawals, execution of payment transactions, issuing or
acquisition of payment instruments, the provisions of money transfer services or any other
service functional to the transfer of money and includes the issuance of electronic money
and electronic funds transfers but does not include the provision of solely online or
telecommunication services or network access). The sole PSP is a subsidiary of a utility
company. However, it was noted that the 6 banks are exempt from licensing and shall be a
direct participant under the National Payments Systems Act. The sector was not assessed in
the 2021 NRA.
d. Securities and Trust Company: There are 6 companies that offer securities services within
the sector and provide brokerage, investment advisory services, underwriting and securities
companies dealing, which are regulated by the GSC. The NRA indicated that the volume of
trades on the Stock Exchange is relatively small as it represents 0.11% of the GDP of Guyana
as at 2019. The securities sector was risk rated Medium Low. The trust company is a FI
licensed by the GSC that also performs TCSP, cambio, pension administration, loans and
property management services.
Table 1.2. Financial Sector and DNFBP Type, Number of entities and weight
Sector Number of entities
Asset Size
(as at Dec 2022)
Weighting
Financial Institutions
Banks 6 GUY$ 801,886,107
US$ 3,845,977
High Importance
Building Society 1 GUY$ 81,317,189
US$ 390,010
Least Importance
Money Transfer Agencies 3 GYD 6,288,683,252
USD 30,161,550
High Importance
Cambios 13 GYD 19,256,144,442
USD 92,355,609
Moderate Importance
Insurance 17 G$146,958,400
US$704,836
Least Importance
Insurance Brokers 11 Least Importance
Pension - - Least Importance
Payment Service Providers 1 GYD 807,352,595
USD 4,036,763
Least Importance
Securities 6 GYD 3,871,450,889
USD18,568,110
Least Importance
Trust Company 1 G$ 11,534,339
US$ 55,321
Least Importance
Credit Unions 26 GYD 8,886,417,618
USD 2,620,708
Moderate Importance

| 31
1.4.4 Preventive measures
55. Preventive measures are set out in the Anti-Money Laundering and Counter Financing of
Terrorism (AML/CFT) Act, of 2009 and its accompanying Regulations. The AML/CFT Act has
undergone several amendments. The preventive measures extend to those entities (FIs and
DNFBPs) defined as REs in the First Schedule of the AML/CFT Act, 2009 wherein provisions
for the requirements applicable to CDD (S.15), record keeping (S.16), STR reporting (S.19),
wire transfers (S.20) and other internal controls such as training, audit, etc (S.19) are outlined.
There are no exempted sectors or activities from the scope of Guyana’s AML/CFT legislation.
1.4.5 Legal persons and arrangements
56. Guyana’s legal framework provides for the creation of a wide range of legal persons (LPs) as
illustrated in Table 1.3. The total number of companies ever registered in Guyana amounts to
15,254. Notably, Guyana is currently in the process of striking off companies from the
Commercial Registry for failure to comply with filing obligations in respect of basic and BO
information, which results in the number of active companies being less than the total number
of registered companies.
2
This represents the number of attorneys-at-law practicing in the jurisdiction that may be performing the activities
stated at R.22
Sector Number of entities
Asset Size
(as at Dec 2022)
Weighting
DNFBPs
Real Estate 65 Moderate Importance
Casino 2 GYD 2,555,487,802
USD 12,256,536.22
Moderate Importance
Dealers in Precious Metals 7 GYD 134,519,616,153
USD 646,795,002.63
High Importance
Dealers in Precious and Semi-Precious Stones 10 Gold
GYD 688,666,671
Diamonds
GYD 739,970,428.05
USD 3,549,018.84
High Importance
Dealers in Precious Minerals/Licensed Traders 50 Gold
GYD 18,191,504,239
Diamonds
GYD 6,833,794,067.51
USD 14,003,760.52
High Importance
Attorneys at Law 2262 Not available Moderate Importance
Accountants 143 GYD 14,490,568
USD 69,499
Moderate Importance
Notary Public 23 - Moderate Importance
Non-Financial Trust and Company Service
Provider
Unknown - Moderate importance

CFATF Guyana Anti Money Laundering Reprt

CFATF Guyana Anti Money Laundering Reprt

Related slideshows

More Related Content

Similar to CFATF Guyana Anti Money Laundering Reprt

Similar to CFATF Guyana Anti Money Laundering Reprt (20)

More from Steven Jasmin

More from Steven Jasmin (18)

Recently uploaded

Recently uploaded (20)

CFATF Guyana Anti Money Laundering Reprt