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Anti money laundering in Paraguay: obligated subjects, due diligence, suspicious reports, SEPRELAD sanctions and the laundering offence

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

Ley 1015/1997, rewritten in 2019 and 2022, makes banks, exchange houses, insurers, cooperatives, real estate businesses, casinos, dealers in jewels and art, sports clubs, money transfer businesses and virtual asset service providers, among others, obligated subjects supervised by SEPRELAD, Paraguay's financial intelligence unit, and sector regulators. They must run risk based due diligence including beneficial owners, record every operation, keep records for 5 years and report any suspicious operation, completed or attempted, whatever the amount, without tipping off the client. Companies face fines of up to 5,000 monthly minimum wages (about US$2.59 million) or 50 percent of the operation; laundering itself is a crime of up to 5 years, 10 if commercial, and negligent laundering up to 2 years.

USD figures use PYG 5,868.31 per US dollar, the Banco Central del Paraguay reference quotation for 28 October 2026. Amounts set in minimum wages use the monthly minimum wage of PYG 3,044,000 and the daily minimum wage (jornal) of PYG 117,077 in force since 1 July 2026 under Resolución MTESS 670/2026. Conversions are for orientation only and move with each wage adjustment.

Key facts

Financial intelligence unitSEPRELAD (Secretaría de Prevención de Lavado de Dinero o Bienes) Ley 1015/1997 art. 27 as amended by Ley 6497/2019, as of 2026-10-28 · in force
AML record keeping5 yearsLey 1015/1997 art. 18 as amended by Ley 6497/2019, as of 2026-10-28 · in force
Minimum amount for suspicious operation reportsNone (any amount, including attempts) Ley 1015/1997 art. 2 e) and 19, as of 2026-10-28 · in force
Maximum AML fine for companies5,000 monthly minimum wages (PYG 15,220,000,000) or 50% of the operation PYGLey 1015/1997 art. 24 as amended by Ley 6497/2019, as of 2026-10-28 · in force
Maximum AML fine for individuals500 monthly minimum wages (PYG 1,522,000,000) or 1% to 10% of the operation PYGLey 1015/1997 art. 24 as amended by Ley 6497/2019, as of 2026-10-28 · in force
Virtual asset service providers are AML obligated subjectsYes Ley 1015/1997 art. 13 as amended by Ley 6960/2022, as of 2026-10-28 · in force
Prescription of administrative sanction proceedings5 yearsLey 1015/1997 art. 36 as amended by Ley 6497/2019, as of 2026-10-28 · in force
Money laundering, maximum prison (commercial or gang)10 yearsCódigo Penal art. 196 as amended by Ley 6452/2019, as of 2026-10-28 · in force

The rule

1. Who is obligated. The obligated subjects are banks, finance companies, insurers, exchange houses, securities firms and exchanges, investment companies, mandate companies, mutual and pension fund managers, cooperatives, gambling operators, real estate businesses, non profit organisations, pawnshops, government entities, designated non financial activities and professions, tobacco and cigarette producers and distributors, sports clubs and their federations and associations, habitual intermediaries in finance and in sports contracts, dealers in jewels, precious stones and metals, art, antiques, stamps and coins, any business that transfers money or values formally or informally, and virtual asset service providers. The list is not closed and must follow international standards. SEPRELAD itself regulates, supervises and sanctions obligated subjects that lack a natural supervisor.
Cost to do it: Registration and arancel amounts are not set in the law; SEPRELAD may charge fees for its services (art. 28 num. 10).
Example: A real estate agency in Asunción (art. 13 k) and a football club (art. 13 p) are both obligated subjects. / A crypto exchange serving Paraguayan users is an obligated subject as a virtual asset service provider (art. 13 v).Ley Nº 1015/1997, art. 13 and 28 as amended by Ley Nº 6960/2022, Art. 13 and 28 num. 9, 2022-07-15 official text · verified 2026-10-28 · changed: Ley Nº 6797 of 20 August 2021 rewrote art. 13 with virtual asset service providers on the list; Ley Nº 6960 of 15 July 2022 rewrote art. 13 again to add tobacco businesses, sports clubs, sports federations and intermediaries in sports contracts.
2. Customer due diligence and beneficial owners. Obligated subjects must apply due diligence to customers (individuals, companies and legal arrangements) at onboarding, continuously during the relationship and whenever there is suspicion. Measures: identify and verify the customer with reliable independent documents or data; identify the beneficial owner (the individual who ultimately owns or controls the customer or on whose behalf a transaction is made, including those with ultimate effective control of a legal person or arrangement) and take reasonable steps to verify them; understand the purpose of the relationship; and monitor transactions against the customer's profile, including source of funds where relevant. SEPRELAD and supervisors may set simplified, general or enhanced measures by risk. If due diligence cannot be completed, the subject must not open the relationship or carry out the operation, must end the relationship and, where appropriate, file a suspicious report.
Cost to do it: Know your customer systems and staff are an internal cost not priced by law.
Example: A bank opening an account for a Paraguayan S.A. owned through a Panamanian holding must identify the individuals who ultimately own or control the holding. / A US$500,000 land purchase by a foreign trust requires the agency to identify the trust's ultimate beneficial owners before closing.Ley Nº 1015/1997, art. 2, 14 and 15 as amended by Ley Nº 6497/2019, Art. 2 c) and f), 14 and 15, 2019-12-26 official text · verified 2026-10-28
3. Risk systems, records and confidentiality. Obligated subjects must implement risk based identification and management procedures and systems, keep beneficial ownership records of client entities up to date, adopt internal control procedures and require directors, managers and staff to comply. They must record all domestic and international operations with amounts, currencies and details enough to reconstruct them, including due diligence files and analyses whether or not they led to a report, and keep these records for 5 years from the operation or the end of the relationship. They must not reveal to the customer or third parties any action or communication made under the law. Everyone, public or private, must give SEPRELAD the information it requests; bank, tax and other secrecy cannot be opposed.
Cost to do it: Record keeping and system costs are internal.
Example: A file for a customer relationship that ended on 31 December 2026 must be kept until at least 31 December 2031. / A foreign bank's Paraguayan branch cannot refuse a SEPRELAD request by invoking bank secrecy (art. 22).Ley Nº 1015/1997, art. 16, 17, 18 and 22 as amended by Ley Nº 6497/2019; art. 20 and 21 (original), Art. 16 to 18, 20 to 22, 2019-12-26 official text · verified 2026-10-28
4. Suspicious operation reports. Obligated subjects must report to SEPRELAD any operation, completed or attempted, regardless of amount, for which there are reasonable grounds or suspicion of links with money laundering or terrorist financing. The content of reports and the identity of the compliance officer and reporting entity are confidential. SEPRELAD analyses reports and other information and, where indications are established, sends a reserved intelligence report to the Public Prosecutor and other competent bodies.
Cost to do it: No fee for reporting.
Example: A jeweller whose client tries to pay PYG 300,000,000 in cash and abandons the sale when asked for ID must still report the attempted operation. / There is no reporting threshold: a US$1,000 transfer can be reportable if it is suspicious.Ley Nº 1015/1997, art. 2 e) and 19 as amended by Ley Nº 6497/2019, Art. 2 e) and 19, 2019-12-26 official text · verified 2026-10-28
5. Administrative sanctions. Breaches of the law, regulations and SEPRELAD or supervisor rules are administrative faults, including: no written policies, no risk system, deficient due diligence, failure to keep records, no compliance officer, obstructing inspections, late or missing suspicious reports, tipping off, failure to cooperate and failure to carry out required external audits. Companies face a warning, public reprimand, fines of up to 5,000 monthly minimum wages or up to 50 percent of the operation, suspension or closure of the licence for up to 1 year, or revocation. Individuals face a warning, public reprimand, fines of up to 500 monthly minimum wages or 1 to 10 percent of the operation, removal and a 3 to 10 year ban from management posts, cancellation of registration and suspension of dividends for up to 3 years for shareholders in management. Officers and managers of sanctioned companies are sanctioned personally when involved. Sanctions are graded by responsibility, past conduct, gains, self correction, gravity and recidivism, and SEPRELAD keeps a register of sanctioned persons, identifying who made up sanctioned companies at the time.
Cost to do it: Company fine ceiling 5,000 x PYG 3,044,000 = PYG 15,220,000,000 (about US$2,593,592); individuals PYG 1,522,000,000 (about US$259,359).
Example: A real estate agency that closes a PYG 2,000,000,000 sale without identifying the buyer's beneficial owner risks up to PYG 1,000,000,000 (50 percent of the operation) or the fixed ceiling of PYG 15,220,000,000. / On a sale worth about US$340,814, the operation based ceiling is about US$170,407 for the company and US$3,408 to US$34,081 for a responsible manager.Ley Nº 1015/1997, art. 24, 25, 28 and 35 as amended by Ley Nº 6497/2019 and Ley Nº 6960/2022, Art. 24, 25, 28 num. 8, 35, 2022-07-15 official text · verified 2026-10-28
6. Procedure, limitation and appeals. Proceedings to sanction administrative faults prescribe 5 years after the transaction ended or the account was closed. Against a sanction by the supervisor's highest authority, reconsideration can be filed within 10 business days and must be decided within 20 business days (silence means rejection); the contentious administrative action must then be filed within 18 business days. Appeals do not suspend the sanction except for fines, and courts may suspend effects only if financial or economic stability is not affected. Final fine resolutions are enforceable titles in the civil and commercial courts of the capital; fines go 75 percent to the supervisor and 25 percent to SEPRELAD, or entirely to SEPRELAD where there is no natural supervisor.
Cost to do it: Litigation cost of the contentious administrative action; no fee set by the AML law.
Example: A licence suspension takes effect even if the exchange house files reconsideration; a fine does not until the appeal is decided. / A sanctioned money transfer business notified on a Monday has 10 business days to file reconsideration.Ley Nº 1015/1997, art. 36, 37 and 38 as amended by Ley Nº 6497/2019, Art. 36 to 38, 2019-12-26 official text · verified 2026-10-28
7. The money laundering offence. Converting or concealing an object derived from a predicate unlawful act, or disguising its origin or frustrating its discovery, confiscation or seizure, is punished with up to 5 years in prison or a fine, as is acquiring, transferring, keeping or using it knowing its origin; attempt is punishable. Predicates include listed Penal Code offences (fraud, breach of trust, bribery, tax evasion under art. 261 with limits, counterfeiting, market manipulation, private bribery and others), any crime, offences by members of criminal associations, drug trafficking, arms trafficking, customs smuggling (Customs Code art. 336), illicit enrichment and influence peddling, securities law offences and transnational bribery; foreign predicates count if punishable where committed. Acting commercially or as a gang raises the penalty to up to 10 years; gross negligence as to the origin is punished with up to 2 years or a fine. Laundering is autonomous: no conviction for the predicate is needed. Voluntary reporting before discovery can avoid punishment.
Cost to do it: Criminal exposure; no fee.
Example: A car dealer who accepts PYG 900,000,000 in cash for vehicles while grossly negligent about its drug trafficking origin risks up to 2 years in prison (art. 196 num. 5). / Funds from tax fraud or bribery committed abroad are laundering predicates in Paraguay if the act is punishable where committed (art. 196 num. 7).Ley Nº 1160/1997, Código Penal, art. 196 as amended by Ley Nº 6452/2019, Art. 196, 2019-11-29 official text · verified 2026-10-28 · changed: Ley Nº 6452 (promulgated 29 November 2019, published 2 December 2019) replaced art. 196, renaming it lavado de activos, widening predicates, adding conversion and transfer and making the offence autonomous.
WhoFixed fine ceilingPYGUSDOperation based fineOther sanctions
Companies5,000 monthly minimum wages15,220,000,0002,593,592Up to 50% of the operationLicence suspension up to 1 year, revocation
Individuals500 monthly minimum wages1,522,000,000259,3591% to 10% of the operationRemoval and 3 to 10 year ban, dividends suspended up to 3 years

AML administrative sanctions (Ley 1015/1997 art. 24 as amended; amounts at the July 2026 minimum wage, USD at PYG 5,868.31)

Worked example

  • A Paraguayan real estate developer (obligated subject under art. 13 k) sells an apartment for PYG 2,000,000,000 (about US$340,814) to a company registered abroad. It must identify and verify the company, identify the individuals who own or control it, record the operation, keep the file for 5 years and report to SEPRELAD if anything is suspicious, without telling the buyer. If it closes without identifying the beneficial owner, the company risks up to PYG 1,000,000,000 and the responsible manager PYG 20,000,000 to PYG 200,000,000.
  • A virtual asset exchange that has no compliance officer and no written manual commits two administrative faults under art. 35 f) and a); as there is no natural supervisor for the sector, SEPRELAD regulates and sanctions it directly and collects 100 percent of any fine (art. 28 num. 9 and art. 38).

Step by step

  1. Check whether your activity is on the art. 13 list (it is not closed) and identify your supervisor or SEPRELAD.
  2. Appoint a compliance officer and adopt a written risk based AML manual approved by the board.
  3. Build onboarding that identifies and verifies customers and beneficial owners, and refuses or exits relationships when due diligence fails.
  4. Record every operation with amounts and currencies, and keep due diligence and analyses for 5 years after the relationship ends.
  5. Set up an internal escalation route for suspicious or attempted operations of any amount and train staff not to tip off clients.
  6. Commission the external AML audits your supervisor requires and answer SEPRELAD requests promptly, without invoking secrecy.

Common traps

  • There is no de minimis amount for suspicious reports; attempted operations count (art. 2 e and 19).
  • Non profit organisations, tobacco companies and sports clubs are obligated subjects, which surprises many foreign investors (art. 13).
  • Managers and shareholders with management roles are personally exposed: bans of 3 to 10 years and suspension of dividends for up to 3 years (art. 24).
  • Appeals do not suspend licence sanctions, only fines (art. 37).
  • Gross negligence about the origin of funds is itself a crime with up to 2 years in prison (Penal Code art. 196 num. 5).
  • Beneficial ownership must also be declared to the official registry for Paraguayan entities; see the entities section for that separate duty.

Sources

Related pages

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