Countries › Guatemala › Guide › 10. Capital markets and finance › Capital markets, banking and credit in Guatemala: bank licensing, free interest rates, capital and deposit rules, securities offerings and movable collateral

Capital markets, banking and credit in Guatemala: bank licensing, free interest rates, capital and deposit rules, securities offerings and movable collateral

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Last verified: 2026-10-28 · Status: Stable

Guatemalan banking runs on Decreto 19-2002: only banks licensed by the Junta Monetaria, after an opinion of the Superintendencia de Bancos, may take money from the public to lend it, foreign banks may open licensed branches or registered representative offices, and anyone buying 5 percent or more of a bank needs prior approval. Banks set interest rates and fees freely but must state the effective annual rate in every contract, hold capital of at least 10 percent of risk weighted assets, keep depositors' identity confidential, and fund a deposit guarantee of Q20,000 per depositor per bank. Public offers of securities must first be registered with the Registro del Mercado de Valores y Mercancías (Decreto 34-96 as reformed by Decreto 49-2008), private placements to up to 35 named investors or to institutional investors are exempt, and since 2008 lenders can take registered security over any movable asset, including inventory and receivables, under the Ley de Garantías Mobiliarias.

USD figures use Q7.64427 per US dollar, the Banco de Guatemala reference rate for 28 October 2026, retrieved from the Banguat exchange rate web service on the verification date. Fines in the banking law are set in unidades de multa worth US$1 each (Decreto 19-2002 art. 103). Conversions are for orientation only.

Key facts

Banking and financial supervisor	Superintendencia de Bancos, under the general direction of the Junta Monetaria (licensing by the Junta Monetaria) textDecreto 18-2002 art. 1; Decreto 19-2002 art. 7, as of 2026-10-28 · in force
Securities registry and supervisor	Registro del Mercado de Valores y Mercancías (Ministry of Economy) textDecreto 34-96 art. 8, as of 2026-10-28 · in force
Minimum capital adequacy ratio	10 %Decreto 19-2002 art. 64, as of 2026-10-28 · in force
Bank stake needing prior Superintendencia approval	5 %Decreto 19-2002 art. 19, as of 2026-10-28 · in force
Foreign bank branches and representative offices	Allowed, with Junta Monetaria authorization (branch) or Superintendencia registration (representative office) textDecreto 19-2002 art. 6 and 7, as of 2026-10-28 · in force
Interest rate cap on bank lending	None: banks agree rates freely; effective annual rate must be disclosed textDecreto 19-2002 art. 42, as of 2026-10-28 · in force
Deposit guarantee per depositor per bank	20000 GTQDecreto 19-2002 art. 87, as of 2026-10-28 · in force
Deposit guarantee fixed contribution	0.2 (2 per thousand of average deposits a year, paid monthly) plus up to 0.2 risk based %Decreto 19-2002 art. 88, as of 2026-10-28 · in force
Bank secrecy	Yes: depositor identity confidential; exceptions for Junta Monetaria, Banguat, Superintendencia, SAT (Código Tributario procedure), interbank exchange and AML duties textDecreto 19-2002 art. 63 (Decreto 37-2016), as of 2026-10-28 · in force
Prison for unlicensed financial intermediation	5 to 10 years yearsDecreto 19-2002 art. 96, as of 2026-10-28 · in force
Public offers need prior registration	Yes, Registro del Mercado de Valores y Mercancías textDecreto 34-96 art. 4 and 27 (Decreto 49-2008), as of 2026-10-28 · in force
Private placement investor limit	35 named persons in total for all series (per calendar year for debt), or institutional investors without limit personsDecreto 34-96 art. 3 (Decreto 49-2008 art. 2), as of 2026-10-28 · in force
Securities Registry tariff cap	0.001 of nominal value of the issue %Decreto 34-96 art. 16 literal d, as of 2026-10-28 · in force
Electronic movable collateral registry	Yes, Registro de Garantías Mobiliarias; priority by time of publicity; no public deed required textDecreto 51-2007 art. 15, 54 and 79, as of 2026-10-28 · in force
Out of court enforcement of movable collateral	Allowed by agreement, before or after default textDecreto 51-2007 art. 58 (Decreto 4-2018), as of 2026-10-28 · in force
Annual bank inspection fee cap	0.1 (1 per thousand of assets net of cash and Banguat reserve deposits) %Decreto 19-2002 art. 111, as of 2026-10-28 · in force

The rule

1. Financial intermediation (habitually taking money from the public, by deposits, bonds, notes or any other instrument, to fund lending of any kind, whatever the legal form) is reserved to banks authorized under this law or special laws. National banks must be sociedades anónimas; foreign banks may either establish a branch or register a representative office limited to promoting business and granting financing in Guatemala, with a legal representative registered with the Superintendencia de Bancos. The Junta Monetaria grants or denies the license only after an opinion of the Superintendencia, which checks the feasibility study, the origin and amount of capital, and the solvency and reputation of founders, directors and managers; for a foreign branch the home country must supervise to international standards, the home supervisor must consent and the two supervisors must be able to exchange information. Applications for banks and branches are published in the official gazette and another major newspaper at the applicant's cost, corporate shareholders must disclose the individuals holding more than 5 percent, and the bank must start operating within six months of the authorization (extendable once).
Cost to do it: No license fee is set in the law; the applicant bears the cost of publishing the application in the Diario de Centro América and a second national newspaper (art. 8), plus the minimum paid capital fixed by the Superintendencia, paid fully in cash (art. 16).
Example: A foreign bank that only wants to originate loans to Guatemalan corporates can register a representative office (art. 6 literal b) instead of capitalizing a branch, avoiding deposit taking rules. / No paid capital requirement for a representative office appears in the law; a branch must bring in and keep its capital in Guatemala (art. 18).Decreto Nº 19-2002 del Congreso, Ley de Bancos y Grupos Financieros (published 15 May 2002, in force 1 June 2002; reformed by Decretos 26-2012, 28-2016 and 37-2016), Art. 3, 6, 7, 8 (as reformed by Decreto 26-2012) and 9, 2002-05-15 official text · verified 2026-10-28

2. The minimum initial paid capital of banks and foreign bank branches is fixed by the Superintendencia de Bancos under a mechanism approved by the Junta Monetaria, revised at least yearly and published in the official gazette, and must be paid entirely in cash. Shares of national banks must be registered (nominativas). A foreign branch's paid capital must enter, stay and be kept in Guatemala and cannot be withdrawn without prior express Junta Monetaria authorization, and the foreign bank answers without limit with all its assets for the branch's operations. Any person acquiring, directly or indirectly, 5 percent or more of a bank's paid capital, or crossing 5 percent by increasing a stake, needs prior authorization from the Superintendencia; without it the bank may not admit or register the shares above that percentage. Banks report their shareholders each January as of 31 December.
Cost to do it: Cash capital at the amount published by the Superintendencia for the year (the 2026 figure was not reachable on an official source in this session); no fee for the 5 percent change of control approval is set in the law.
Example: A fund buying 6 percent of a Guatemalan bank on the market must obtain Superintendencia approval first; if it does not, the bank cannot register the 1 percent above the threshold. / The threshold is a percentage, not an amount: 5 percent of a bank with Q500 million paid capital is Q25 million (about US$3.27 million).Decreto Nº 19-2002 del Congreso, Ley de Bancos y Grupos Financieros (published 15 May 2002, in force 1 June 2002; reformed by Decretos 26-2012, 28-2016 and 37-2016), Art. 15, 16, 17, 18 and 19, 2002-05-15 official text · verified 2026-10-28

3. Banks agree interest rates, commissions and other charges freely with their customers; there is no statutory interest rate ceiling for bank lending in this law. They may not charge commissions or expenses for services not actually provided or costs not actually incurred, and every financial contract must state expressly the effective annual equivalent rate (tasa efectiva anual equivalente) and any later change to it. Banks may operate in quetzales or foreign currency (deposits, loans, credit cards, leasing, factoring, trust services, buying and selling foreign currency), keeping global foreign currency asset and liability proportions set by the Junta Monetaria. Separately, the Ley Monetaria lets parties agree expressly to use a currency other than the quetzal, and courts and authorities must enforce what was agreed.
Cost to do it: No regulatory cost; rates and fees are a commercial matter between bank and client.
Example: A Q7,644,270 working capital line priced at a 9 percent nominal rate paid monthly must show the effective annual rate (about 9.38 percent) in the contract. / The same line can be written directly in dollars, for example US$1,000,000, and repaid in dollars (Ley Monetaria art. 6).Decreto Nº 19-2002 del Congreso, Ley de Bancos y Grupos Financieros (published 15 May 2002, in force 1 June 2002; reformed by Decretos 26-2012, 28-2016 and 37-2016); Decreto Nº 17-2002, Ley Monetaria (published 13 May 2002), Ley de Bancos art. 41, 42 and 44; Ley Monetaria art. 6, 2002-05-15 official text · verified 2026-10-28

4. Banks and financial companies must always hold computable capital (patrimonio computable: primary plus complementary capital, the latter capped at the amount of primary capital, net of stakes of 25 percent or more in other financial entities) of not less than 10 percent of risk weighted assets and contingencies. The Junta Monetaria sets the weights by general regulation, with a three quarters vote and based on international best practice, and any change applies gradually and with prudent notice. Capital shortfalls trigger regularization plans and, ultimately, suspension and the special exclusion regime of the law.
Cost to do it: Capital cost of holding at least Q10 of computable capital per Q100 of risk weighted assets.
Example: A bank with Q1,000 million of risk weighted assets needs at least Q100 million of computable capital. / About US$130.8 million of risk weighted assets requires at least about US$13.1 million of capital.Decreto Nº 19-2002 del Congreso, Ley de Bancos y Grupos Financieros (published 15 May 2002, in force 1 June 2002; reformed by Decretos 26-2012, 28-2016 and 37-2016), Art. 64, 65 (as reformed by Decreto 26-2012), 67 and 70, 2002-05-15 official text · verified 2026-10-28

5. Bank directors, managers, legal representatives, officers and employees may not disclose any information revealing the identity of depositors of banks, financial institutions and financial group companies, or information supplied by customers, except the duties under anti money laundering rules. The exceptions are information that banks must give to the Junta Monetaria, the Banco de Guatemala, the Superintendencia de Bancos and the tax administration (SAT, following the Código Tributario procedure) and exchanges between banks and financial institutions. Officials who receive it may not disclose it without a court order. A breach is a serious offence causing immediate removal, plus civil and criminal liability.
Cost to do it: No fee; compliance cost lies in handling SAT and supervisory information requests.
Example: A foreign shareholder cannot obtain a Guatemalan subsidiary's customers' deposit data from the bank, but SAT can under the Código Tributario procedure. / Not monetary.Decreto Nº 19-2002 del Congreso, Ley de Bancos y Grupos Financieros (published 15 May 2002, in force 1 June 2002; reformed by Decretos 26-2012, 28-2016 and 37-2016); article reworded by Decreto Nº 37-2016 (published 23 August 2016), Art. 63 (as reformed by Decreto 37-2016 art. 48), 2016-08-23 official text · verified 2026-10-28 · changed: Decreto 37-2016, published 23 August 2016, added SAT to the authorities entitled to bank information, subject to the Código Tributario procedure.

6. The Fondo para la Protección del Ahorro guarantees each individual or legal entity with deposits in a private national bank or foreign bank branch the recovery of up to Q20,000, or its equivalent in foreign currency, per bank, excluding interest not yet capitalized; joint accounts count as one holder unless a holder differs. The Junta Monetaria must raise the cover when fewer than 90 percent of deposit accounts have balances at or below it. Banks pay monthly one twelfth of a fixed 2 per thousand of their average total deposits, plus a risk based variable component of up to 2 per thousand a year, debited by the Banco de Guatemala within the first five days of the following month, until their accumulated contributions reach 5 percent of deposits.
Cost to do it: For a bank: fixed contribution of 0.2 percent of average deposits a year plus up to another 0.2 percent risk based.
Example: A bank with Q1,000 million average deposits pays a fixed Q2,000,000 a year (about Q166,667 a month) plus the variable part; a depositor with Q50,000 in one failed bank is covered for Q20,000. / Q20,000 is about US$2,616 of cover per depositor per bank; Q2,000,000 is about US$261,634 a year of fixed contribution.Decreto Nº 19-2002 del Congreso, Ley de Bancos y Grupos Financieros (published 15 May 2002, in force 1 June 2002; reformed by Decretos 26-2012, 28-2016 and 37-2016), Art. 85, 87, 88 (as reformed by Decreto 26-2012) and 89, 2012-09-26 official text · verified 2026-10-28 · changed: Decreto 26-2012, published 26 September 2012, rewrote the contribution formula in art. 88 to a fixed 2 per thousand plus a risk based variable component of up to 2 per thousand.

7. Taking money from the public habitually without authorization under the banking law or a special law, by any instrument and however booked, and using it for lending, is the crime of financial intermediation: prison of 5 to 10 years with no substitute measures for the individuals and the administrators, managers, directors and legal representatives of a company, a fine of 10,000 to 100,000 unidades de multa, cancellation of the trading license or liquidation of the company. Banks, financial companies and offshore entities that breach the law face administrative fines of 500 to 40,000 unidades de multa for a first offence, doubled for a second and doubled again for a third of the same kind. Each unidad de multa equals US$1 at the Banco de Guatemala reference rate on the date of the sanction. Cooperatives and other deposit takers governed by a special law are outside this law but must report to the Superintendencia on request.
Cost to do it: Criminal fine of US$10,000 to US$100,000 (Q76,442.70 to Q764,427 at the 28 October 2026 rate); administrative first offence fine of US$500 to US$40,000 (Q3,822.14 to Q305,770.80).
Example: A lending platform funded by retail investors' notes, without a bank license or a registered public offer, risks this crime and the one in the securities law; a lender using only its own and institutional funds does not take money from the public. / Fines are denominated in dollars: 40,000 units is US$40,000.Decreto Nº 19-2002 del Congreso, Ley de Bancos y Grupos Financieros (published 15 May 2002, in force 1 June 2002; reformed by Decretos 26-2012, 28-2016 and 37-2016), Art. 4, 96, 99 and 103, 2002-05-15 official text · verified 2026-10-28

8. The Superintendencia de Bancos is the technical banking supervisor, acting under the general direction of the Junta Monetaria, and supervises the Banco de Guatemala, banks, financial companies, credit institutions, surety and insurance companies, general bonded warehouses, exchange houses, financial groups and their holding companies, and any other entity other laws assign to it, for liquidity, solvency and capital soundness. Its supervision does not make it liable for the supervised entities.
Cost to do it: Banks and financial companies pay the Superintendencia an annual inspection fee based on prior year end assets, capped at 1 per thousand of assets net of cash and reserve deposits held at the Banco de Guatemala (Ley de Bancos art. 111).
Example: A bank with Q10,000 million of assets net of cash and reserve deposits pays at most Q10 million a year in inspection fees. / About US.31 billion of net assets, at most about US$1.31 million a year.Decreto Nº 18-2002 del Congreso, Ley de Supervisión Financiera (published 13 May 2002); Decreto Nº 19-2002, Ley de Bancos y Grupos Financieros (published 15 May 2002), Ley de Supervisión Financiera art. 1 and 2; Ley de Bancos art. 111, 2002-05-13 official text · verified 2026-10-28

9. A public offer of securities (an open invitation to the public, directly or through a third party, via a stock exchange or any mass medium, or the systematic placement of securities by other means) may only be made after the securities are registered in the Registro del Mercado de Valores y Mercancías, a technical body of the Ministry of Economy, and while the registration is in force. An offer is private, and outside the registration rules, when made only to existing shareholders of an issuer whose shares are not registered; to institutional investors (entities supervised by the Superintendencia de Bancos, the social security institute IGSS, public or private pension entities and collective investment vehicles) without intermediaries or mass media; or to no more than 35 named persons in total for all series, per calendar year for debt securities. Above 35 the offer becomes public. Public offers of securities in foreign currency, issued in or outside Guatemala, to be traded in Guatemala must also be registered, except foreign securities listed on an exchange's international quotation system. Offers by the State, Banco de Guatemala, municipalities and Superintendencia supervised institutions follow their own laws.
Cost to do it: Registry fees are set by tariff approved by the President and may never exceed 0.001 percent of the nominal value of the issue (Decreto 34-96 art. 16 literal d); exchange, rating agency and legal costs are additional.
Example: Registering a Q100 million bond issue costs at most Q1,000 in Registry tariff. / About US$13.08 million of bonds, at most about US$131 of Registry tariff.Decreto Nº 34-96 del Congreso, Ley del Mercado de Valores y Mercancías (published in the Diario de Centro América 24 June 1996), as reformed by Decreto Nº 49-2008 (published 25 September 2008, in force eight days later), Art. 3, 4, 8, 27 and 38 (art. 3, 27 and 38 as reformed by Decreto 49-2008 art. 2, 7 and 8), 2008-09-25 official text · verified 2026-10-28 · changed: Decreto 49-2008 redefined public and private offers (35 person limit and institutional investor exemption), required registration of foreign currency offers traded in Guatemala, added the international quotation system and created the crimes of illicit fund raising and illicit securities intermediation.

10. Raising funds from the public habitually, with or without advertising, when obliged to register a public offer and without registering it (or after the registration was suspended, cancelled or expired) is the crime of illicit fund raising (captación ilícita de dinero); acting as a securities intermediary without the required authorization is the crime of illicit securities intermediation. Individuals, and shareholders, directors, managers, representatives and trusted staff of companies involved, face 6 to 10 years in prison with no substitute measures, a fine of 50,000 to 200,000 unidades de multa and a ban from the financial and securities sector at least as long as the prison term; the company is fined 50,000 to 200,000 units and its registration is cancelled. In this law each unidad de multa is valued by the Registry between Q100 and Q1,000, updated every six months. Misusing reserved names such as bolsa de valores, casa de bolsa or agente de valores is fined 5,000 to 50,000 units.
Cost to do it: Penalty exposure, not a fee: the minimum corporate fine of 50,000 units is Q5 million to Q50 million depending on the unit value set by the Registry.
Example: A startup selling profit participation notes to 200 retail buyers through social media without Registry registration falls inside art. 98 bis. / Q5 million is about US$654,000; Q50 million about US$6.54 million.Decreto Nº 34-96, Ley del Mercado de Valores y Mercancías, as reformed by Decreto Nº 49-2008 (published 25 September 2008), Art. 5, 90, 96, 98 bis and 98 ter (as reformed or added by Decreto 49-2008 art. 13, 17, 18 and 19), 2008-09-25 official text · verified 2026-10-28

11. A garantía mobiliaria is a real security right over any movable property, present or future, specific, generic or the whole of the debtor's movables (including inventory, receivables, derived and rotating assets), securing obligations of any kind; it also covers retention of title, security trusts, floating charges over a business, receivables discounting and financial leasing. It becomes enforceable against third parties when publicized, by registration in the electronic Registro de Garantías Mobiliarias or by delivery of possession; priority runs from the time of publicity and a registered security ranks ahead of later or unregistered attachments. Registration lasts five years unless agreed otherwise, renewable for three year periods keeping its rank. No public deed is required to create, assign, amend or cancel the security or register it. On default the creditor registers its decision to enforce, and the parties may agree, even after default, on a private auction, sale or award of the collateral; court help is available to take possession. Since Decreto 4-2018, pledges previously recorded in the property registries had to move to this Registry.
Cost to do it: Registry tariff set by the Registry regulation (art. 48; amount not reachable on an official source in this session); no notary deed is needed (art. 79), which saves notarial fees.
Example: A distributor borrowing Q3 million can grant a single security over its whole present and future inventory and receivables by a private contract and one electronic filing. / About US$392,450 of credit secured without a public deed.Decreto Nº 51-2007 del Congreso, Ley de Garantías Mobiliarias (published 16 November 2007, in force 1 January 2008), reformed by Decreto Nº 46-2008 (published 12 September 2008) and Decreto Nº 4-2018 (published 7 March 2018), Art. 3, 4, 15, 16, 44, 54, 58, 79 and 82; Decreto 4-2018 art. 26, 2018-03-07 official text · verified 2026-10-28 · changed: Decreto 4-2018, published 7 March 2018, centralized pledges in the Registro de Garantías Mobiliarias (transfer of existing pledges free of charge within two months), reworded enforcement (art. 58) and allowed derived, rotating and floating collateral to be identified generically (art. 16).

Activity	Gate	Authority	Sanction without it
Taking deposits or other funds from the public to lend	Bank license (or special law, such as cooperatives)	Junta Monetaria after Superintendencia de Bancos opinion	5 to 10 years prison, 10,000 to 100,000 units, liquidation
Foreign bank lending into Guatemala with local presence	Branch license or representative office registration	Junta Monetaria (branch); Superintendencia de Bancos (office)	Same as above if taking funds from the public
Issuing shares or bonds to the public	Registration of the public offer	Registro del Mercado de Valores y Mercancías	6 to 10 years prison, 50,000 to 200,000 units
Placing securities with up to 35 named persons or institutional investors	None (private offer)	Not applicable	Becomes public above 35 persons
Acting as broker or securities intermediary	Registration as agent	Registro del Mercado de Valores y Mercancías	6 to 10 years prison, 50,000 to 200,000 units
Buying 5 percent or more of a bank	Prior approval	Superintendencia de Bancos	Shares above 5 percent not registered

Who may raise money in Guatemala and the gate to pass. Sources: Decreto 19-2002 art. 3, 4, 6, 7 and 96; Decreto 34-96 art. 3, 4, 27 and 98 bis as reformed by Decreto 49-2008. Fines in unidades de multa; banking law units are US$1, securities law units Q100 to Q1,000.

Worked example

A US company wants to finance its Guatemalan distributor with US$2,000,000 (about Q15.29 million at Q7.64427) and to raise further working capital locally.
1. Intercompany or foreign bank loan. A loan from the parent or a foreign bank to the distributor is not taking money from the public, so no Guatemalan license is needed; it can be written and repaid in dollars (Ley Monetaria art. 6) and moves freely under the FX regime. Withholding tax on the interest is covered on the FX page.
2. Collateral. The distributor grants a garantía mobiliaria over its present and future inventory and receivables by private contract and the lender files it electronically in the Registro de Garantías Mobiliarias, which fixes priority from the filing time (Decreto 51-2007 art. 4, 15, 54 and 79).
3. Local bank line. A Guatemalan bank offers a Q7,644,270 (US$1,000,000) line: the rate is negotiated freely, but the contract must state the effective annual rate (Decreto 19-2002 art. 42).
4. Local bonds. If the distributor later sells notes to 20 named local investors it is a private offer; if it advertises to the public or exceeds 35 named investors it must register the issue first, at a Registry tariff of no more than 0.001 percent: Q100 for a Q10 million issue (about US$13), with exchange, rating and counsel costs on top (Decreto 34-96 art. 3, 16 and 27).

Step by step

1. Classify the activity: lending own funds or a foreign lender's funds needs no Guatemalan banking license; taking money from the public needs one (Decreto 19-2002 art. 3 and 96).
2. For a bank or branch: prepare the feasibility study, capital origin evidence and fit and proper files for founders, directors and managers, file with the Superintendencia de Bancos, publish the application in the official gazette and another newspaper, obtain the Junta Monetaria resolution, register at the Registro Mercantil and start operations within six months (art. 7 to 9).
3. For a stake of 5 percent or more in an existing bank: obtain Superintendencia approval before closing (art. 19).
4. For securities: decide private or public offer under Decreto 34-96 art. 3; for a public offer, register the issue with the Registro del Mercado de Valores y Mercancías before any marketing and list it on an authorized exchange; debt issues traded on an exchange need a risk rating (art. 19 literal d as reformed by Decreto 49-2008).
5. For secured credit: sign the security agreement (no deed needed), file it in the Registro de Garantías Mobiliarias before disbursing, renew before five years, and register any enforcement decision (Decreto 51-2007 art. 44, 58 and 79).
6. Check the FX page for withholding on interest paid abroad and the regulation section for AML duties of financial entities under Decreto 15-2026.

Common traps

Crowd lending or note programs funded by the public without a bank license or a registered offer can fall under two crimes with 5 to 10 and 6 to 10 years of prison that exclude substitute measures (Decreto 19-2002 art. 96; Decreto 34-96 art. 98 bis).
The 35 person private placement count is across all series, and for debt securities it resets each calendar year; using mass media or third party intermediaries makes even a small offer public (Decreto 34-96 art. 3).
Free interest rates are not free fees: charging for services not actually provided is prohibited, and contracts without the effective annual rate breach the law (Decreto 19-2002 art. 42).
Foreign branch capital is locked in: it cannot be withdrawn without Junta Monetaria authorization, and the parent bank answers without limit for the branch (art. 18).
Unregistered movable collateral loses to a registered one even if created earlier, and to a registered attachment (Decreto 51-2007 art. 54).
Deposit cover is only Q20,000 (about US$2,616) per depositor per bank; corporate treasury balances above that are unprotected (art. 87).
The banking law's fine unit is US$1, while the securities law's unit is set by the Registry between Q100 and Q1,000, so the same number of units means very different amounts.

Sources

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