Paraguay ECT Final Report i

Program 

Evaluation 

Report, 

Paraguay: 

Economic 

Crimes 

Final Report Submission

June 6, 2023
Paraguay ECT Final Report i

Program Evaluation Report, Paraguay: Economic Crimes

Contents

PROGRAM EVALUATION REPORT,PARAGUAY: ECONOMIC CRIMES................................................................................ I

ACRONYMS ..................................................................................................................................................................... II

I. EXECUTIVE SUMMARY .................................................................................................. 1

BACKGROUND................................................................................................................................................................. 1

EVALUATION QUESTIONS ............................................................................................................................................... 1

SUMMARY OF FINDINGS AND CONCLUSIONS .................................................................................................................. 2

SUMMARY OF RECOMMENDATIONS ................................................................................................................................ 4

II. OTA/PARAGUAY ECONOMIC CRIMES PROGRAM SUMMARY........................... 5

OVERVIEW...................................................................................................................................................................... 5

PROJECT OBJECTIVES...................................................................................................................................................... 7

III. EVALUATION FINDINGS AND CONCLUSIONS......................................................... 9

EQ1: TO WHAT EXTENT HAS THE ECT ACHIEVED THE FOUR PROJECT OBJECTIVES AS DEFINED IN THE PARAGUAY 

YEARLY WORKPLANS? IN WHICH AREAS WAS THE ECT THE MOST SUCCESSFUL? ....................................................... 10

EQ2: WHICH OF THE ECT’S PROJECT OBJECTIVES IN PARAGUAY HAVE BEEN SUSTAINED OVER TIME AND WHY?....... 27

EQ3: WHICH OF THE ECT’S PROJECT OBJECTIVES WERE NOT ACHIEVED AND WHY? ................................................... 34

IV. RECOMMENDATIONS.................................................................................................... 40

V. SUGGESTED NEXT STEPS............................................................................................. 45

VI. ANNEXES ........................................................................................................................... 46

ANNEX A: METHODOLOGY AND DATA SOURCES ......................................................................................................... 47

ANNEX B: LIMITATIONS ............................................................................................................................................... 52

ANNEX C: EVALUATION DATA SOURCE MATRIX ......................................................................................................... 55

ANNEX D: CONNECTING ECT ACTIVITIES TO GAFILAT DETERMINATIONS ............................................................... 58

ANNEX E: KEY INFORMANT INTERVIEW INSTRUMENTS ............................................................................................... 60

ANNEX F: GAFILAT EVALUATION.............................................................................................................................. 80

ANNEX G: RESPONDENT LIST....................................................................................................................................... 82
Paraguay ECT Final Report ii

Acronyms

AML/CFT Anti-Money Laundering and Countering the Financing of Terrorism

CBP Central Bank of Paraguay

DNFBP Designated Non-Financial Businesses and Professions

ECT Economic Crimes Team

EQ Evaluation Question

FATAA Foreign Aid Transparency and Accountability Act

FATF Financial Action Task Force

FCWG Financial Crimes Working Group

FinCEN Financial Crimes Enforcement Network

FIU Financial Intelligence Unit

FSRB FATF-style regional body

GAFILAT Latin American Financial Action Task Force

IMF International Monetary Fund

INL Bureau of International Narcotics and Law Enforcement Affairs 

KII Key Informant Interview

M&E Monitoring and Evaluation

MER Mutual Evaluation Report

OTA Office of Technical Assistance

PM Public Ministry (prosecutor’s office)

RA Resident Advisor

SENABICO National Secretariat for the Administration of Seized and Forfeited Assets

SENAD National Anti-Narcotics Secretariat

SEPRELAD Secretariat for the Prevention of Money or Property Laundering

SET Undersecretary of State for Taxation

STR Suspicious Transaction Report

TA Technical Assistance

USAID United States Agency for International Development
1 Paraguay ECT Final Report

I. Executive Summary

Background

The Department of the Treasury’s Office of Technical Assistance (OTA) provided technical 

assistance in anti-money laundering and countering the financing of terrorism (AML/CFT) to 

Paraguay between 2015–2019. In this initiative, OTA has engaged Resident and Intermittent 

Advisors who have worked closely with counterparts in the Secretariat for the Prevention of 

Money or Property Laundering (SEPRELAD), the Central Bank of Paraguay (CBP), and the 

Public Ministry (PM). For four years, OTA’s Economic Crimes Team (ECT) assistance focused 

on improving the effectiveness of the Financial Intelligence Unit (FIU), money-laundering case 

development, asset recovery and management, and AML/CFT supervision. ECT assistance 

aimed to give counterparts a better understanding of the role of the FIU in Paraguay’s AML/CFT 

system and the importance of interagency collaboration. In accordance with Foreign Aid 

Transparency and Accountability Act (FATAA) requirements, Bixal implemented a summative 

evaluation of OTA’s Paraguay Economic Crimes program based on the evaluation questions 

(EQs) listed below.

The evaluation of OTA/Paraguay’s Economic Crimes Programs serves two purposes: 1) ensure 

compliance with the Foreign Aid Transparency and Accountability Act of 2016,1 which includes 

requirements to evaluate the outcomes and impacts of OTA’s programs, and 2) provide OTA 

with in-depth, third-party, retrospective insights of its Economic Crimes program activities in 

Paraguay and lessons learned for future programming. 

The qualitative evaluation methods include a desk review of OTA’s Paraguay project documents, 

key informant interviews (KIIs) with, among others, OTA Advisors, OTA’s counterparts from 

SEPRELAD and CBP, and other constituents. KIIs were conducted on-site in Asunción and 

virtually. 

Evaluation Questions

Bixal’s evaluation team collaborated with OTA’s Monitoring and Evaluation (M&E) and ECTs

to develop the following evaluation questions (EQs) to better understand OTA’s work in 

Paraguay. 

1 Foreign Aid Transparency and Accountability Act of 2016, Public Law 114–191.

https://www.congress.gov/114/plaws/publ191/PLAW-114publ191.pdf
2 Paraguay ECT Final Report

EQ1: To what extent has the ECT achieved the four project objectives as defined in the Paraguay 

yearly workplans? In which areas was the ECT the most successful:

2

• Increasing the effectiveness of Paraguay’s FIU analysis and reporting 

• Strengthening the AML/CFT supervision of financial and non-financial sectors

• Improving AML/CFT case development and creating a financial crimes task force

• Developing an asset forfeiture and recovery program

EQ2: Which of the ECT’s project objectives in Paraguay have been sustained over time and 

why?

EQ3: Which of the ECT’s program objectives were not achieved and why?

Summary of Findings and Conclusions

EQ1: To what extent has the ECT achieved the four project objectives as defined in 

the Paraguay yearly workplans? In which areas was the ECT the most successful?

The ECT helped to improve the FIU’s analysis and reporting functions. Prior to the outset of the 

Project, SEPRELAD viewed its primary function as passing on to the PM suspicious transactions 

reports (STRs) submitted to SEPRELAD by obliged entities. SEPRELAD provided sparse 

analysis or inquiry regarding suspicious patterns of activity that would guide the prosecutors in 

building cases. ECT provided training in targeted areas, such as indicators used for detecting 

and investigating suspicious activity, remittances, and offshore transactions, and worked with 

SEPRELAD analysts to help them develop their analytical skills. While there is still work to be 

done, interviewees and ECT Advisors agreed that the SEPRELAD reports had improved. This 

was the project objective in which, in the evaluation team’s judgment, ECT achieved the most 

success. While SEPRELAD’s capacity for reporting improved, its effectiveness in its role as 

Paraguay’s FIU within the overall AML/CFT system is still limited. This is due to a 

disagreement with the PM (i.e., prosecutors) about SEPRELAD’s reports. Respondents from the

PM claimed that SEPRELAD’s reports remain insufficient for their needs but did not offer 

specifics or examples.

The ECT also facilitated the creation of a financial crimes working group (FCWG) that convened 

regularly when OTA was present in the country. However, the overall effectiveness of the 

FCWG on AML/CFT case development is not clear; meetings have been irregular since the end 

of the project due, in part, to a change in the government and the departure of several 

2 OTA Economic Crimes Team internal document, 2018 Workplan: Paraguay 2019 Work Plan
3 Paraguay ECT Final Report

prosecutors. As a result, the group’s current and future impact on AML/CFT case development 

and the system overall remains to be seen.

The ECT was instrumental in helping Paraguay’s asset management agency, the National 

Secretariat for the Administration of Seized and Forfeited Assets, manage seized assets. 

However, the existing legal framework did not permit the asset forfeiture function that had been 

contemplated at the Project’s outset.

EQ2: Which of the ECT’s project objectives in Paraguay have been sustained over time 

and why?

Two factors are particularly important for sustainability of the project objectives: 1) a solid legal 

foundation to support AML/CFT actions; and 2) cooperation between the various component

agencies within Paraguay’s AML/CFT system.

While the ECT’s support for improving the AML/CFT legal and regulatory foundation was not a 

formal part of the project objectives, this assistance was necessary in the early stages of OTA’s 

project for the AML/CFT system to function legally and effectively, as a base-level prerequisite 

for the advancement of the project objectives. ECT Advisors provided input into the legislative 

changes that were under consideration during the term of the project. While ECT Advisors did 

not draft laws or regulations, they raised awareness of the need for legislation that provides the

legal authority for the kinds of powers Paraguay’s AML/CFT needs to have to implement 

international AML/CFT standards, as recommended by the FATF. The package of 10 new laws 

passed in 2020 considerably improved Paraguay’s AML/CFT legal framework and is 

fundamental to the sustainability of all four project objectives. 

However, the AML/CFT system’s future sustainability will also depend on its regulated entities’ 

understanding of the law as well as the political will to enforce it. 

The ECT recognized effective cooperation between AML/CFT agencies as another critical 

underlying condition to the overall development and sustainability of Paraguay’s AML/CFT 

success. To address the limitations posed by interagency cooperation, the ECT established the 

FCWG and fostered relationships between SEPRELAD and other agencies. The ECT’s success 

in addressing this fundamental limitation, which is instrumental to OTA’s project objectives, is 

reflected in Paraguay’s improved standing and removal from FATF’s “grey list”. The 

foundation for sustainability exists, but real sustainability will depend on the willingness of the 

Paraguayan counterparts to maintain the momentum now that the ECT Advisors have left.

EQ3: Which of the ECT’s project objectives were not achieved and why?

OTA’s objective of strengthening the AML/CFT supervision of financial and non-financial 

sectors was partially achieved. The CBP believes that it has a risk-based supervision framework 

in place and has declined technical assistance (TA) from OTA for reasons that were not shared 
4 Paraguay ECT Final Report

by respondents from the CBP when asked by the evaluation team. However, OTA Advisors

participated in bank examinations and provided mentoring to CBP examiners. 

OTA’s objective to improve AML/CFT case development and create a financial crimes task 

force was partially achieved.

3 The ECT established the FCWG, which met regularly during the 

project and still meets occasionally. Interagency relationships, however, continue to be an issue 

for Paraguay’s overall efficacy since OTA’s program ended and a new government has replaced 

key individuals, particularly within the PM’s office.

Developing an asset forfeiture and recovery program has been partially achieved. While the ECT 

assisted with asset management policies and practices, Paraguay’s legal framework in place 

during OTA’s project did not include provisions for the effective implementation of the asset 

forfeiture objective. 

Summary of Recommendations

Based on the evaluation findings, the evaluation team suggests that OTA consider the following 

recommendations that can apply to continued assistance in Paraguay and/or similar ECT 

programs in other countries:

• Engage with the leadership of other AML/CFT system constituents in formal agreements 

with specific expectations, (e.g., the PM and the CBP) in addition to the primary focus on 

the FIU in program planning and technical assistance implementation. This includes 

looking for opportunities to assist supervisory authorities in other financial and nonfinancial sectors and identifying objectives that focus on establishing formal memoranda 

of understanding and relationships between agencies that are independent of individuals 

who come and go with government transitions.

• Include opportunities to review program strategies and make mid-course corrections in 

response to changing circumstances. While this is ostensibly done periodically through 

meetings (three times annually), documenting the changes would be helpful to document 

decisions made and preserve project knowledge and context when OTA staff changes

over the life of the project.

3 Originally called the financial crimes task force, the name was changed in 2016 to emphasize that the group would 

take on issues that could be solved by TA, and not be operationally focused.
5 Paraguay ECT Final Report

II. OTA/Paraguay Economic Crimes Program Summary

Overview

The Economic Crimes Team (ECT) project in Paraguay began with a technical assistance (TA)

request to the Office of Technical Assistance (OTA) in the fall of 2013 by the Government of 

Paraguay for an anti-money laundering and countering the financing of terrorism (AML/CFT) 

TA project. ECT conducted an assessment of the project that included the key constituent 

agencies and highlighted concerns about political-level support for AML/CFT reforms, noting 

Paraguay’s “dismal” enforcement record. OTA proposed a plan to provide TA to Paraguay’s

Secretariat for the Prevention of Money or Property Laundering (SEPRELAD), a core agency 

within Paraguay’s AML/CFT system, as the ECT’s principal counterpart agency. 

Concurrent with OTA’s assessment, the U.S. Department of State (State) offered to fund two 

years of ECT programmatic activities in Paraguay through a combination of several unspent 

accounts that consisted of funds administered by Paraguay’s International Narcotics and Law 

(INL) Enforcement Section, which at the time was ending. Following discussions with the 

SEPRELAD’s (now former) Minister, the ECT opted to commence the engagement on an 

intermittent basis with the possibility of expanding the project later to a resident engagement. 

Following the signing of an interagency agreement between State and Paraguay’s INL in 

October 2014, the ECT conducted a candidate mission for the then-Team Lead Advisor in March 

2015. ECT’s Lead Advisor led the project until April 2016, taking three-week trips to Paraguay 

approximately once per quarter.4

The ECT began providing AML/CFT assistance to Paraguay through Intermittent, Non-Resident 

Advisors (RAs) in March 2015, and by May 2017 transitioned to an RA-based engagement

model. From 2015 to 2019, OTA’s project objectives improved the effectiveness of 

SEPRELAD, Paraguay’s FIU; money laundering case development; asset and management; and 

AML/CFT supervision. However, by mid-2018, OTA was concerned that SEPRELAD, as an 

agency, was still not able to assume its central role within Paraguay’s AML/CFT system and 

considered suspending or closing OTA’s engagement because of a lack of traction or impact. 

Inadequate coordination and collaboration between SEPERLAD and its constituent agencies

remained critical constraints to implementing an effective AML/CFT system.

4 The delay between the signing of the interagency agreement in October 2014 and the project launch in March 2015

was due to two reasons. OTA takes approximately two months to internally process incoming funding to make 

available for travel by Advisors (this process was completed by December 2015), and the U.S. Embassy Asunción 

and SEPRELAD requested that the project commence following the Paraguayan summer holidays, which typically 

conclude by mid-February. 
6 Paraguay ECT Final Report

In June 2018, in advance of his inauguration, the then-President Elect Benitez appointed a 

Central Banker to take over leadership of SEPRELAD once his new administration took office 

on August 15, 2018. The new Minister-Elect immediately began working with OTA’s ECT RA 

to gain a better understanding of her new role and planned assistance activities. ECT became 

increasingly optimistic that the new administration represented an opportunity to gain better 

traction with counterparts. A program review in August 2018 just prior to the inauguration 

confirmed the ECT’s optimism.5

SEPRELAD’s new Minister demonstrated an eagerness for and ability to make good use of ECT 

assistance and established frequent standing meetings with key counterparts to discuss 

coordination issues, which the ECT’s RA helped facilitate. SEPRELAD also entered into an 

updated memorandum of understanding (MOU) with other constituent agencies which, among 

other improvements, allowed SEPRELAD to share information more proactively. SEPRELAD’s

Minister also empowered staff to reach out to constituent partner agencies, and with guidance 

from the ECT, incorporated their feedback to improve the FIU’s business processes. 

SEPRELAD added new analytical staff that were trained and mentored by the ECT.

The ECT also engaged with the newly appointed Chief Money Laundering Prosecutor at the 

Public Ministry (PM) to assist new personnel with financial crimes prosecutions. PM staff

working in money laundering began to participate regularly with an interagency financial crimes 

working group (FCWG) that had been earlier proposed by the ECT and eventually formed in 

2018.6

In contrast, the ECT struggled to gain traction with the Central Bank of Paraguay (CBP) to 

support its supervisory role within the AML/CFT system. While coordination with SEPRELAD

was improved during the program, OTA’s August 2018 program review reported that ECT 

discussed its concerns with CBP officials that CBP had not adequately adopted a risk-based 

approach to AML/CFT supervision that met international standards. However, CBP did not 

agree with OTA’s assessment and declined to engage formally with ECT or accept any TA from 

OTA.

7

5 OTA Economic Crimes Team internal document, 2018 Advisor Monthly Report: 

201808_paraguay_ect_mr_rhoades

6 OTA Economic Crimes Team internal document, 2018 Advisor Monthly Report: 

201803_paraguay_ect_mr_rhoades

7 OTA Economic Crimes Team internal document, 2018 Program Review: 

201906_paraguay_ect_pr_schenck_youngblood
7 Paraguay ECT Final Report

Project Objectives

OTA identified four project objectives for the ECT program in Paraguay.

Project objective 1: Increasing the effectiveness of SEPRELAD’s analysis and reporting

The purpose of this project objective was to foster a better understanding between SEPRELAD 

and the PM regarding the content and quality of SEPRELAD’s investigative research reports. 

The ECT learned from discussions with senior Paraguayan officials from several constituent 

agencies that prosecutors were trying to use SEPRELAD’s background and intelligence reports

as complete evidence for their cases, rather than as a starting point for collecting evidence for 

their own investigations. Several counterparts from different constituent agencies remarked that, 

from their perspective, SEREPLAD’s products were incomplete and insufficient for the PM to 

use to prosecute cases. One interview respondent said that SEPRELAD’s reports needed to at 

least help prosecutors understand a connection between its investigative background research 

and a potential financial crime. A SEPRELAD interview respondent said its analysts were 

intelligent and capable but lacked an “analytical mindset.” The respondent described how the 

analysts had benefited from internal training courses developed by SEPRELAD, but that they 

still struggled to make the leap from the principles learned from training to putting them into

practice.8

Project objective 2: Strengthening the AML/CFT supervision of financial and non-financial 

sectors

In the past, a compliance-based approach that sets specific rules and standards and then analyzes

transactions against them was the most common approach to, and considered sufficient for, 

AML/CFT in most countries, including Paraguay. An obliged transactional entity that was 

compliant with standard specific rules was considered operating safely and managing its risks 

appropriately. However, this traditional rules-based approach is no longer sufficient to combat 

money laundering and terrorist financing in the modern financial environment. Increasingly, 

countries around the world have adopted a risk-based approach to AML/CFT supervision, which 

requires more sophisticated investigative research to identify money laundering and finance of 

terrorism risks and updated policies and procedures that obliged transactional entities needed to

mitigate risks.

Project objective 2 intended to help bring Paraguay into harmony with the international standards 

established by Financial Action Task Force (FATF) recommendations regarding supervision of 

obliged entities. Since 2012, FATF has considered a traditional risk-based approach as the 

8 OTA Economic Crimes Team internal document, 2015 Advisor Trip Report:

201503_paraguay_ect_tr_hayden_irmen
8 Paraguay ECT Final Report

“essential foundation” for compliance with international standards established by FATF,

9

as part 

of the analysis of institutions’ AML/CFT framework in their overall supervisory programs.10

Paraguay had been rated non-compliant with (former) FATF Recommendation 23 (Regulation 

and supervision of financial institutions) in its third-round (2008) Mutual Evaluation Report

(MER) by the Latin American Financial Action Task Force (GAFILAT), which assessed 

Paraguay’s AML/CFT system and practices against international minimal performance 

standards.

11

 Paraguay also had been rated non-compliant with former FATF Recommendation 

24 (Regulation and supervision of designated non-financial businesses and professions or

[DNFBPs]) in its third-round MER.12

Project objective 3: Improving AML/CFT case development and creating a financial

crimes working group

The premise of project objective 3 was that Paraguay lacked adequate capacity to investigate and 

prosecute money-laundering crimes. Historically, the number of investigations, prosecutions,

and convictions in Paraguay has been low. As the U.S. Bureau of International Narcotics and 

Law Enforcement Affairs (INL) noted in 2016:

“Although the Government of Paraguay is making progress in improving its AML/CFT 

system, concerns remain regarding the country’s ability to identify, investigate, and 

prosecute money laundering and related crimes effectively.”13

The INL also noted Paraguayan prosecutors’ limited resources for investigating and prosecuting 

financial crimes cases, and the lack of a formal system for tracking money-laundering 

cases. The aim of this project objective was to create a financial crimes task force (or working 

group) that would meet regularly and develop a case-tracking mechanism and operations manual.

9 FATF. 2012 (updated 2019). International Standards on Combating Money Laundering and the Financing of 

Terrorism & Proliferation – The FATF Recommendations, Recommendation 1 (Assessing risks and applying a riskbased approach).

10 Basel Committee on Banking Supervision. 2012. Core Principles for Effective Banking Supervision (Principle 29, 

Abuse of Financial Services); International Association of Insurance Supervisors. 2018. Insurance Core Principles

(ICP 22, Anti-Money Laundering and Combatting the Financing of Terrorism); International Organization of 

Securities Commissions (IOSCO). 2005. Anti-Money Laundering Guidance for Collective Investment Schemes.

11 2021. MER, p. 284. See Annex F for a description of the GAFILAT evaluation and FATF.

12 2022. MER, p. 292.

13 Bureau of International Narcotics and Law Enforcement Affairs. 2016 International Narcotics Control Strategy 

Report (INCSR) – Countries/Jurisdictions of Primary Concern – Paraguay.
9 Paraguay ECT Final Report

Project objective 4: Developing an asset forfeiture and recovery program

At OTA’s program inception, Paraguay had not enacted an asset forfeiture law, although the 

need for Paraguayan authorities to be able to seize, manage, and forfeit assets was well 

recognized, particularly among investigators and prosecutors. A bill had been introduced to 

Paraguay’s Congress and approved by the House but had not been approved by the Senate. 

SEPRELAD and other constituent agencies, including the National Anti-Narcotics Secretariat 

(SENAD), had been working with the Organization of American States’ Inter-American Drug 

Abuse Control Commission’s Seized and Forfeited Asset Management Project on drafting the 

law and standing up a corresponding asset management agency. The aim of this project 

objective was to develop an asset recovery manual that would identify remedies to existing 

impediments.

The workplan described the key challenges facing Paraguay in its effort to build an effective 

AML/CFT system. It also proposed capacity building activities designed to support the 

government of Paraguay to address these challenges and bring Paraguay into greater compliance 

with the FATF recommendations. For each project objective, the workplan set out the specific 

challenges, objectives, and activities, with target dates and deliverables.14

III. Evaluation Findings and Conclusions

Discussion of the evaluation’s findings and conclusions in this section follow each of OTA’s 

three evaluation questions:

EQ1: To what extent has the ECT achieved the four project objectives as defined in the Paraguay 

yearly workplans? In which areas was the ECT the most successful?

15

EQ2: Which of the ECT’s project objectives in Paraguay have been sustained over time and 

why?

EQ3: Which of the ECT’s program objectives were not achieved and why?

Following the discussion of the evaluation team’s findings, this section will also provide a brief 

discussion of the recent GAFILAT Mutual Evaluation Report (MER) of Paraguay’s AML/CFT 

system which further supports aspects of the evaluation’s findings and represents a milestone 

achievement for the country. 

14 OTA Economic Crimes Team internal document, 2015 Trip Report: 201503_paraguay_ect_tr_hayden_irmen

15 OTA Economic Crimes Team internal document, 2018 Workplan: Paraguay 2019 Work Plan
10 Paraguay ECT Final Report

EQ1: To what extent has the ECT achieved the four project objectives as defined in 

the Paraguay yearly workplans? In which areas was the ECT the most successful?

This section discusses findings for EQ1, which follow the ECT’s four project objectives as 

defined in the Paraguay workplan.

16

Overall, the ECT achieved the greatest degree of success with project objective 1 (increasing the 

effectiveness of SEPRELAD’s analysis and reporting), based on a consensus view among the 

counterparts, further supported by Advisors’ own assessments, that SEPRELAD’s analytical and 

reporting capacity significantly improved because of the ECT’s TA. The ECT Advisors

provided valuable training and mentoring to the SEPRELAD staff to enable a transformation 

from merely passing along STRs to providing insights and perspectives to aid the PM in 

developing cases. 

However, this success in capacity building is tempered by an ongoing issue with the PM’s 

limited use of SEPRELAD’s reports to develop and prosecute increased numbers of cases. 

Project objective 1 is discussed in more detail below.

Project objective 1: Increasing the effectiveness of SEPRELAD’s analysis and reporting

Finding: The ECT helped to improve the FIU’s capacity for analysis and reporting.

OTA’s TA improved SEPRELAD’s capacity for analysis and reporting by:

• Expanding SEPRELAD’s analytical and reporting capacity from providing STRs to the 

PM to more extensive intelligence analysis

• Creating a strategic analysis unit within SEPRELAD

• Providing training in targeted areas such as indicators used for detecting and investigating 

suspicious activity, remittances, and offshore transactions

SEPRELAD improved the quality of its financial analysis during the ECT’s program by 

increasing its access to AML/CFT information and improving its use of open-source data to 

develop financial intelligence. The evaluation team spoke with former prosecutors who now 

work in other agencies in the AML/CFT system, and they confirmed that they collaborated with 

SEPRELAD in their past PM role, and that they noticed an improvement in the quality of 

SEPRELAD’s reporting during the ECT’s tenure in Paraguay. This was corroborated by OTA’s

16 OTA Economic Crimes Team internal document, 2018 Work Plan: Paraguay 2019 Work Plan
11 Paraguay ECT Final Report

2017 program review, which noted that SEPRELAD’s role was initially limited to disseminating

STRs then later expanded to producing more comprehensive financial intelligence reports.

17

Improved Analytical Capacity 

In 2017, as OTA transitioned from using Intermittent Advisors to an RA, the ECT’s primary TA 

approach shifted from knowledge-sharing best practices to a more consultative role in helping

analyze the information that SEPRELAD was collecting and providing expert insights on how 

that information could be used.18 The ECT’s SEPRELAD counterparts were effusive in their 

praise of the OTA’s RA and his role in SEPRELAD’s transformation to an enhanced,

intelligence-focused FIU. The GAFILAT 2021 MER found that Paraguay's AML/CFT system 

had improved significantly since its last evaluation. Its discussion noted that SEPRELAD’s

financial intelligence reports add value through its use of a wide range of sources of information 

and contributes to the working groups established for the investigation of emblematic cases by 

the Attorney General’s Office. A former senior SEPRELAD official noted that without the OTA 

RA’s assistance, Paraguay would not have passed the 2021 GAFILAT MER, which indicated an 

overall score of “moderate” level. 

Creating a Strategic Analysis Unit Within SEPRELAD

At the program’s inception, SEPRELAD’s analysis was limited and was a key focus area for the 

ECT. Typically, in most countries, the role of an FIU is to develop financial intelligence, which 

has two components:

• Operational intelligence analyzes specific suspicious transactions and identifies people, 

cross-border transactions, and other information to identify whether there is an ML and 

financing of terrorism or predicate offense case to be presented to the Prosecutors.

• Strategic analysis helps to identify general patterns, typologies, risks, and other more 

structural elements that can lead to strategic planning, or even policy decisions. 

OTA’s Advisors were instrumental in promoting the creation of a strategic analysis unit within 

SEPRELAD. The 2018 Resolution 14/18 of the Criminal Code, among other actions, created 

this unit as a structural reform. The unit is now in charge of developing typologies, identifying 

red flags, and providing feedback and training to reporting entities. OTA Advisors helped the 

newly developed unit to understand and develop its new role. Multiple interview respondents

17 OTA Economic Crimes Team internal document, 2017 Program Review:

201707_paraguay_ect_pr_schenck_youngblood

18 OTA Economic Crimes Team internal document, 2017 Advisor Monthly Report: 

201705_paraguay_ect_mr_rhoades
12 Paraguay ECT Final Report

confirmed the importance of OTA’s advice for creating SEPRELAD’s active strategic analysis 

unit.

Targeted Training

In addition to the ECT’s contributions to SEPRELAD’s improved reports and analysis 

capabilities previously described, Advisors also provided other training to SEPRELAD targeted 

to address the key skill areas listed below. However, the details including the quality of the

ECT’s trainings, while generally referred to in positive terms by the counterparts, are unknown. 

The evaluation findings related to the ECT’s training activities are based on brief descriptions in 

the project documents provided by OTA as well as interviews with Advisors and their 

counterparts. However, documentation or training materials were not available to the evaluation 

team, such as curricula, training designs or objectives with topic details, participant lists, posttraining feedback, or any training follow-up. As a result, there are no findings related to quality, 

utility, or participation regarding the ECT’s training activities.

Financial intelligence reports: The ECT organized a series of weekly training events on 

financial intelligence reports that included the entire SEPRELAD team. The ECT trained 

SEPRELAD in important tools to research and analyze information, including information from 

external sources such as Google Maps, the U.S. Financial Crimes Enforcement Network, and 

other agencies within and outside of Paraguay. The training focused on establishing links among 

sources, focusing on relevant conclusions, completing reports, and closing cases. Other training 

subjects included coordination with other constituent agencies. A former senior SEPRELAD 

official told the evaluation team that the reports were strengthened tremendously due to the OTA 

Advisor’s training. Another senior SEPRERLAD official noted that the ECT Advisor had a 

greater perspective on how to analyze cases to generate better reports, and that the PM also 

received guidance from the ECT Advisor regarding how to approach the reports received from 

SEPRELAD.

Suspicious activity indicators: OTA Advisors also provided training on common indicators 

used by counterpart AML/CFT practitioners outside Paraguay to detect, analyze, investigate, and 

prosecute suspicious activity that could be included in SEPRELAD’s Suspicious Transaction 

Report (STR) Quality Assessment Matrix.19 Prior to the training, the SEPRELAD matrix did not 

include any indicators concerning the financial or economic behavior of the individuals

conducting suspicious transactions, which is a major component in evaluating suspicious 

19 The STR Quality Assessment Matrix was introduced in 2017 by Resolution 232/17. According to this instrument, 

the quality level of STRs is determined by weighting factors such as coherence, clarity, completeness, and 

relevance; origin and destination of funds; typologies; and due diligence. GAFILAT. 2022. Mutual Evaluation 

Report of the Republic of Paraguay, p. 62.
13 Paraguay ECT Final Report

activity.20 SEPRELAD’s use of the matrix was one factor in GAFILAT’s determination that 

Paraguay is compliant with FATF Recommendation 34 (Guidance and Feedback).

21

Remittances risks: In addition to training on financial intelligence reports, OTA Advisors also 

provided training on risks relating to remittances. A SEPRELAD interview respondent noted 

that the Advisor’s experience helped SEPRELAD understand other types of obligated transaction 

entities beyond the formal financial sector. The training extended SEPRELAD’s awareness of 

the need to research information from online and other public sources, such as information from

foreign counterpart; FIUs, such as the Financial Crimes Enforcement Network (FinCEN) in the 

United States; and other AML/CFT agencies and private sector sources within Paraguay.

Offshore Transactions: At SEPRELAD’s request, OTA Advisors also provided training on 

risks and suspicious transactions inherent with offshore transactions. SEPRELAD analysts 

frequently confront offshore entities during the analysis of STRs related to money laundering 

and terrorist financing.

International Cross-Training Opportunities 

The ECT arranged visits to other countries for SEPRELAD analysts to be trained in research, 

analysis, reporting, and financial supervision. Almost 90% of the key AML/CFT officials

participated in these opportunities, according to a counterpart official. Opportunities included

training for prosecutors at Paraguay’s borders. A former SEPRELAD official noted that this was 

a valuable training opportunity for judges and prosecutors in the border regions. 

Finding: OTA helped enhance SEPRELAD’s prominence and stature in the AML/CFT 

system.

Many counterpart respondents said OTA’s assistance helped improve SEPRELAD’s prominence 

and stature within the AML/CFT community. One respondent said, from his perspective at the 

Customs Authority, that he has a better understanding of SEPRELAD’s central role within the 

AML/CFT system because of the Advisor’s influence. A senior CBP official also said that the 

work of the OTA Advisor was a very important link in fostering relationships among

SEPRELAD, the PM, the Supreme Court of Justice, and others such as the Supervisor of 

Cooperatives. The CBP official described past friction between SEPRELAD and some other 

agencies, such as the PM and the Judiciary, and that the OTA RA “smoothed out those rough 

edges.”

20 OTA Economic Crimes Team internal document, 2015 Advisor Trip Report:

201508_paraguay_ect_tr_hayden_neau

21 GAFILAT. 2022. Mutual Evaluation Report of the Republic of Paraguay, p. 311.
14 Paraguay ECT Final Report

Finding: SEPRELAD’s effectiveness is constrained by the limited use of its reports by the 

PM for case development.

Despite the significant improvements in SEPRELAD’s capacity for analysis and reporting, the 

FIU’s overall effectiveness is constrained by the PM’s limited use of its reports for case 

development and prosecution. SEPRELAD’s counterparts discussed an ongoing dispute between 

SEPRELAD and the PM’s office regarding the utility of its reports. The evaluation team did not 

have access to the SEPRELAD’s confidential reports; therefore, it is not possible to form a 

definitive conclusion about the prosecutor’s concerns. However, some insights about this core 

issue emerged during the evaluation process.

For example, the PM disparaged SEPRELAD’s work as insufficient for the prosecutors to 

develop cases. While the source of the tension between the agencies was not fully understood by 

the evaluation team, the political context in Paraguay, as discussed by several counterparts, has a 

large impact on the relationships, such as those between SEPRELAD and the PM. Both PM 

officials with whom the evaluation team met were high-level officials and not “hands-on” 

prosecutors. The evaluation team was unable to speak to active prosecutors with whom 

SEPRELAD might have developed cases in the past, and who might have been able to provide 

greater first-hand knowledge about the day-to-day interaction between SEPRELAD and the PM. 

The high-level officials who were interviewed either could not, or chose not to, provide any 

further details of how SEPRELAD’s reports are insufficient from their perspectives. According 

to project documents, at the outset of the TA project, SEPRELAD was uncertain as to what 

prosecutors needed or otherwise expected as well as what type of information SEPRELAD could

provide. For example, SEPRELAD noted that it would send analytic products to the prosecutors 

and then nothing further would happen.22 One OTA Advisor noted that during his visits to the 

Prosecutor’s office, the prosecutors would tell him the SEPRELAD reports were useless because 

of missing information or inadequate analysis. 

However, the evaluation team also learned that many prosecutors who had collaborated 

frequently with SEPRELAD during the ECT project had left the PM, leading to a loss of 

institutional and technical knowledge as attrition occurs in the institution. The loss of 

experienced prosecutors willing to work with SEPRELAD to improve reports may have 

contributed to a reduced capacity at the PM to use SEPRELAD’s reports. As one respondent 

from the PM shared, good reports from SEPRELAD are useless if the prosecturs do not know 

how to use them. 

In the Paraguayan system, all prosecutors are appointed by, and can be dissmissed by, a highly 

politicized committee. As a result, reliance on personal relationships between agencies has led to 

22 OTA Economic Crimes Team internal document, 2015 Trip Report: 201503_paraguay_ect_tr_hayden_irmen
15 Paraguay ECT Final Report

a vulnerable AML/CFT system that is heavily affected by prosecutor turnover, which could be a 

factor in the disagreement about SEPRELAD’s reports and their utility to the PM.

23

According to SEPRELAD, the legal framework does not make a clear distinction between 

intelligence and evidence, and as a result, prosecutors interpreted SEPRELAD’s role as 

conducting investigations. This gap in interpretation of the legal framework between 

SEPRELAD and the PM results in a constrained ability to collaborate effectively. While the 

evaluation team does not have direct evidence of this from interviews with the counterparts, this 

may have manifested in SEPRELAD’s disagreement with the prosecutor’s office regarding 

quality expectations and depth of analysis of SEPRELAD’s reports as reported by an ECT 

Program Review.24 The document noted that while the PM needed a clearer understanding as to 

how to use financial intelligence and institutional roles within the system, SEPRELAD also 

needed to enhance its analytical capability.

According to Article 15 of the Criminal Procedural Code, only the PM has the authority to 

conduct criminal investigations. Article 58 of the same Code dictates that the Police, acting on 

the guidance of the PM, conduct investigative activities. SEPRELAD’s role is described by 

Article 28 of Law No. 1015 of 1997 (modified by Law No. 3783/2009), which states that 

SEPRELAD will send cases to the PM that have clear indications of money laundering, 

predicate offenses, terrorist financing, or related assets, for the prosecution to initiate a criminal 

investigation.25 This approach is consistent with the role of FIUs in other countries, which 

typically receive, analyze, and transmit financial intelligence reports, including STRs, from the 

private sector. An FIU adds value through analyzing a broad range of financial and other 

information at its disposal where it is uniquely positioned to assess the risk of suspicious 

activities.26

In their technical approach to working with SEPRELAD, the ECT Advisors emphasized that 

SEPRELAD’s analytical products are just the beginning of the anti-money laundering process. 

The 2017 OTA program review noted that Paraguay’s enabling legislation called upon 

SEPRELAD to serve as an administrative rather than investigative FIU. Investigative bodies 

(whether FIUs or other law enforcement agencies) typically have broad authority to require 

testimony and physical evidence, and to enlist the assistance of courts in the event of 

23 OTA Economic Crimes Team internal document, 2018 Program Review: 

201906_paraguay_ect_pr_schenck_youngblood

24 OTA Economic Crimes Team internal document, 2017 Program Review:

201707_paraguay_ect_pr_schenck_youngblood

25 SEPRELAD. “Sistema Nacional ALA/CFT.” https://www.seprelad.gov.py/sistema-nacional-ala-cft-i58

26 Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism. 

Financial Intelligence Units. https://www.coe.int/en/web/moneyval/implementation/fiu
16 Paraguay ECT Final Report

noncompliance. Administrative FIUs, by contrast, do not have these legal powers but specialize 

in collecting and analyzing information. Prosecutors then use this detailed analysis to develop 

sufficient facts to support filing criminal charges and ultimately gaining convictions. 

At times, SEPRELAD attempted to accommodate the PM’s desire for more complete 

information packages by collecting evidence to support the information transmitted in STRs. 

One OTA Advisor recounted a visit to Paraguay during which he found that a SEPRELAD 

analyst was collecting external evidence to be furnished to the PM. Because, as explained above, 

conducting criminal investigations is outside SEPRELAD’s remit, the OTA Advisor dissuaded 

the analyst from gathering evidence and recommended focusing instead on developing 

hypotheses, identifying red flags, and observing suspicious fact patterns with a view toward 

using these items to help the prosecutors develop cases. The ECT worked with SEPRELAD to 

view its role as neither merely transmitting STRs to the PM nor compiling evidence for the 

prosecutors, but rather using its skills and techniques to analyze information to help the 

prosecutors develop cases. 

The 2021 GAFILAT MER provides some valuable insights that confirms the ECT’s guidance to 

SEPRELAD, noting that “The FIU-SEPRELAD produces financial intelligence reports that are 

the product of the analysis of the information it receives from reporting entities and of the value 

added provided by its access to a wide range of sources of information.”27

Further, “The FIU-SEPRELAD has developed its capacity to collect and analyze financial 

intelligence information in response to the requests from criminal investigation and prosecution 

agencies. The statistics show a low number of this type of requests indicating a low use of this 

resource.”28

Taken together, the above passages from the MER strongly suggest that the problem of the 

quality of SEPRELAD reports is something that is not entirely within the control of 

SEPRELAD. It is true that SEPRELAD’s ability to produce analytical reports is much greater 

than was previously the case. It is also true, however, that SEPRELAD can only deal with the 

information that it has. While SEPRELAD has many of the tools that it needs to produce highquality reports for the PM (such as external sources of information and the ability to recognize 

red flags and suspicious patterns), much information needs to come from the reporting entities 

themselves via STRs. 

The MER supports this view, stating that “...while [SEPRELAD’s] information is received and 

used by the Attorney General’s Office, the number of [money laundering] investigations that 

27 GAFILAT. 2021. MER, p. 9.

28 GAFILAT. 2021. MER, p. 44.
17 Paraguay ECT Final Report

derive from financial intelligence reports is not consistent in magnitude with the level of risk to 

which Paraguay is exposed, as well as the amount of information it receives from some reporting 

entities, and the information to which it has access.”

29

Conclusion: While SEPRELAD’s reports to the PM have improved, further work is still 

necessary.

Interviews with the Paraguayan counterparts outside SEPRELAD indicated that the SEPRELAD 

analysts have a better understanding of SEPRELAD’s role and function within the AML/CFT 

system because of the ECT’s assistance, and that the quality of SEPRELAD’s reports to the PM

has improved. However, the improvements to SEPRELAD’s analysis and reporting, at least from 

the PM’s and other constituent agencies’ perspectives, are still insufficient for making significant 

progress with more prosecutions. While some of the reasons are clearly outside SEPRELAD’s 

role and influence within the AML/CFT system, the evaluation team considers SEPRELAD’s 

transformation to a fully functional and effective FIU as defined by Paraguay’s legal framework 

incomplete.

The factors that contribute to this conclusion — differing opinions of the quality of 

SEPRELAD’s reports to the PM, the quality of STRs (which affects the quality of SEPRELAD 

reports), and differing perceptions about SEPRELAD’s proper role (providing analysis and 

insights versus providing evidence that can be presented in court) — have been discussed above. 

However, it is important to recognize that the tension between SEPRELAD and the PM is only 

one piece of a much bigger puzzle: such tension between the Presidential Administration and the 

PM exists on many levels, and that tension will inevitably be present in AML/CFT matters. In 

addition, a number of senior PM officials have been in their positions for many years and are 

reluctant to change. The ability of an outside organization such as OTA to bring about change in 

the system is necessarily limited. This is not a criticism of OTA or its efforts, merely a 

recognition of the fact that real change will take time and will not always follow a logical 

progression. 

Project objective 2: Supervising financial and non-financial sectors

The ECT decreased its engagement with project objective 2 (strengthening the AML/CFT 

supervision of financial and non-financial sectors) because the International Monetary Fund 

(IMF) was already providing the CBP with technical assistance in this area. 

29

 GAFILAT. 2022. Mutual Evaluation Report of the Republic of Paraguay, p. 9. 
18 Paraguay ECT Final Report

Finding: The ECT’s assistance to AML/CFT supervision was limited due to the 

involvement of other TA providers.

This project objective, according to OTA’s workplan, was to develop AML/CFT examination 

manuals in high-risk sectors, train examiners in their use, and assist CBP in conducting

examinations that would ensure compliance with international standards.

However, because the IMF was already engaged with CBP on transitioning from a rules-based 

approach to a risk-based approach (including development of a supervisory manual), CBP

declined OTA’s assistance in this area. In addition, CBP believed that it already had a risk-based 

supervision framework in place (although this only applied to banks; CBP was not interested in 

broadening the scope of the risk-based supervision to include other financial institutions). 

However, an OTA Advisor accompanied inspectors from the CBP AML/CFT Risk Supervision 

Department during an entire on-site examination of a commercial bank and assisted with the 

drafting of the report of examination. They concluded that CBP was using a traditional, rulesbased approach to AML/CFT compliance, including the supervision of STR filings by banks and 

other obligated entities. CBP does not currently communicate with SEPRELAD about 

individual obligated entities. 

No other supervisors (other financial or non-financial sectors) requested or received support from 

OTA to implement a risk-based system of AML/CFT supervision.

Conclusion: OTA may have missed an opportunity to refocus its project objectives.

The ECT recognized that the IMF was adequately improving the supervision of financial and 

non-financial sectors in Paraguay. This recognition presented an opportunity for OTA to 

reconsider its project objectives, adjust its overall strategy for Paraguay, and shift resources to 

other gaps in SEPRELAD or other AML/CFT constituents. This shift could have included, for 

example, aiding other financial and/or non-financial authorities, which could benefit from such 

assistance.

Conclusion: OTA provided limited support for risk-based supervision to CBP and 

provided training, but further work could be done in other financial and non-financial

sectors. 

While Paraguay’s government agencies have made progress with AML/CFT supervision, other

entities, such as private sector banks, have not kept pace. According to one respondent, the 

contrast in supervision between financial sector supervisors and CBP’s supervisors is a serious 

drawback. This official noted that supervisors of securities, cooperatives, and gambling 

establishments need to operate at the level of CBP and recommended that that there be close 

support from more knowledgeable supervisors from more advanced sectors.
19 Paraguay ECT Final Report

Project objective 3: Improving AML/CFT case development and creating a financial 

crimes working group

For project objective 3, the ECT facilitated the creation of the FCWG, which brought together 

critical AML/CFT agencies to share information and best practices, a key component in a 

functioning AML/CFT regime. However, it is difficult to measure the FCWG’s impact on 

AML/CFT case development because the group is currently meeting only sporadically, so as a 

result, project objective 3 has been partially achieved. 

Finding: The FCWG was created and continues to convene but it is unclear whether OTA’s 

assistance resulted in increased case development. 

OTA’s project objective was to create an FCWG that would meet regularly and develop a casetracking mechanism and an operations manual.30 At the outset of the ECT’s engagement in 

2015, the ECT introduced the idea of the FCWG to promote interagency collaboration on 

financial investigations. The group would include high-level AML/CFT decision makers to 

coordinate and facilitate investigations. Numerous interview respondents described how 

Advisors acted as intermediaries between AML/CFT constituents who did not have working 

relationships or who did not share information. The ECT was the key contributor to founding 

the FCWG. Three years after forming and after dozens of meetings, the FCWG continues to 

meet, though there is not a formal schedule and meetings are organized on an ad hoc basis. 

The ECT was central to facilitating meetings with agencies to discuss the working group. To 

illustrate the ECT’s role in the development of the FCWG over time, Figures 1 and 2 represent

every meeting related to the FCWG (as reported in project documents) from program inception 

in 2015 through April 2018. Each meeting is represented by a connected line between 

participant agencies. The connections are color-coded according to the year they occurred. 

OTA’s central role in the FCWG’s development can be seen by the number of connections 

between the ECT and the various constituent agencies, and the activity and growth of the FCWG 

can be seen by comparing Figure 1 (2015) with Figure 2 (2016–2018). 

Each institution’s node is sized by the number of connections it has to other institutions, and the 

members of the FCWG have an opaque maroon border. 

The network maps represent three time periods during the formation of the FCWG: 

Figure 1: 2015; the year the project had an Intermittent Advisor. 

30 Originally called the financial crimes task force, the name was changed in 2016 to emphasize that the group 

would take on issues that could be solved by TA, and not be operationally focused.
20 Paraguay ECT Final Report

Figure 2: July 2016–April 2018; the period during which a second Advisor would transition to 

the project until the FCWG was created and meeting regularly in April 2018.

Figure 3: August 2018–May 2019; the period after the creation of the FCWG in April to the last 

mention of the FCWG in the trip reports in May 2019. This map is discussed in the EQ2

findings.
21 Paraguay ECT Final Report

Figure 1: Meetings on the Formation of the FCWG, 2015

Figure 1 shows each meeting that occurred on the formation of the FCWG in 2015, the year the project had its first Intermittent 

Advisor. Meetings are represented by a green line between agencies. In the early stages of the project, the ECT worked with 

counterparts to develop the concept of the FCWG with a small number of agencies. The ECT’s central role in the FCWG’s development 

can be seen by the number of connections from the ECT to constituent agencies. 
22 Paraguay ECT Final Report

At the outset of the ECT’s engagement in 2015, the Intermittent Advisor found counterparts to 

be receptive to the idea of forming an FCWG to promote interagency collaboration on financial 

investigations. According to trip reports, counterparts envisioned a group comprised of many 

high-level stakeholders empowered to make decisions as they relate to the AML/CFT system and 

financial investigations in Paraguay. The ECT was central to facilitating meetings with agencies 

to discuss the formation of a working group, with many connections originating with the ECT as 

seen in Figure 1. The first Intermittent Advisor left the project in early 2016 after having last 

met about the FCWG in 2015. 
23 Paraguay ECT Final Report

Figure 2: Meetings on the Formation of the Financial Crime Working Group and Financial 

Crimes Working Group Meetings, July 2016–April 2018

Figure 2 maps each meeting that occurred from July 2016–April 2018, the period during which a second Advisor would transition on 

the project until the FCWG was created and meeting regularly in April 2018. Meetings are represented by a color-coded line between 

agencies based on the year they took place. The FCWG meetings and discussions involve many more agencies, and they are much 

more frequent thanks in part to the Advisor’s resident status. The ECT still plays a central role in the FCWG’s development, but more 

meetings are happening between agencies without direct ECT involvement.
24 Paraguay ECT Final Report

Throughout 2016, a new Intermittent Advisor frequently met with counterparts in the AML/CFT 

system to discuss the idea of an FCWG. Counterpart agencies mentioned the need for access to 

better financial intelligence and a collaborative approach to following the money.31 The ECT 

encouraged the PM to lead the group. While the PM was receptive to the idea, it did not take a

proactive role organizing future meetings and developing a clear workplan. 

In December 2016, at the Advisor’s urging, the PM convened the first FCWG meeting with 11 

other constituent agencies. While this was an important milestone, the group failed to develop a 

workplan or set a date for the next FCWG meeting.

32 Participants initially agreed to continue 

meeting on a bimonthly basis; however, the group went months without reconvening for reasons 

that were unclear to the ECT, according to trip reports.

33 In May 2017, the Intermittent Advisor 

transitioned to an RA and was able to meet more frequently with agencies to advance the 

FCWG. To further increase support from counterpart agencies, the ECT collaborated with other

U.S. government agencies, including the U.S. Embassy, which helped convene initial meetings 

to kickstart the group in 2016 and 2017.

34

The FCWG group was reinitiated in April 2018 and continued meeting regularly without direct 

involvement from the Advisor, according to trip reports, though with fewer participating 

agencies.35 The FCWG stills meets as confirmed by the evaluation team in the interviews with

different agencies. 

At the outset of the project, each agency had a unique perspective on the challenges of bringing 

investigations to successful prosecution and conviction. Many blamed the problems on the 

judiciary and prosecution services, and all shared the opinion that many constituents did not 

understand or appreciate the roles and responsibilities of other colleagues. Helping counterparts 

understand their unique roles and authorities within the AML/CFT system in Paraguay was a 

central theme of the RA’s TA with both member agencies and agencies that participated in 

meetings to discuss the FCWG. After the establishment of the FCWG, one of ECT’s priorities

was to assist counterparts in developing the capacity to transfer information seamlessly between 

31 OTA Economic Crimes Team internal document, 2016 Advisor Trip Report:

201607_paraguay_ect_tr_irmen_rhoades

32 OTA Economic Crimes Team internal document, 2016 Advisor Trip Report:

201612_paraguay_ect_tr_rhoades

33 OTA Economic Crimes Team internal document, 2017 Advisor Monthly Report:

201706_paraguay_ect_mr_rhoades_blagg

34 OTA Economic Crimes Team internal document, 2017 Advisor Monthly Report:

201707_paraguay_ect_mr_rhoades

35 OTA Economic Crimes Team internal document, 2018 Advisor Monthly Report:

201804_paraguay_ect_mr_rhoades
25 Paraguay ECT Final Report

relevant constituents and transform the information into evidence and eventually develop a 

successful case. Even though successful AML/CFT cases are limited, according to the GAFILAT 

MER, “cooperation and exchange of information between the FIU and competent authorities was 

demonstrated [during the GAFILAT review].”36

Conclusion: The ECT facilitated the creation of a FCWG, which continues to meet. 

However, the group’s effectiveness is unclear.

The establishment of the FCWG was a significant milestone for the AML/CFT system. 

Although the FCWG meets less frequently than when the ECT was active in Paraguay, the group 

continues to exchange information among different agencies. As described elsewhere in this 

report, the ECT worked with investigative, prosecutorial, and judicial authorities to increase the 

number of AML/CFT cases. However, it is unclear whether that TA resulted in increased case 

development. While evidence of any ongoing activity of the FCWG indicates potential progress,

the FCWG by itself may not have the ability or political influence to resolve Paraguay’s inertia, 

particularly now that the modestly positive GAFILAT results do not present an apparent, urgent 

need for change. The change in the government, the departure of several prosecutors from the 

PM, lack of sufficient resources of the PM, inadequate investigative tools, and problems with the 

judicial system all contribute to limiting the effectiveness of the TA. 

Project objective 4: Developing an asset forfeiture and recovery program

For project objective 4, limitations in the legal framework that existed during the time of the 

ECT’s assistance did not allow for legal asset forfeiture. However, ECT Advisors helped to get 

the National Secretariat for the Administration of Seized and Forfeited Assets (SENABICO) “up 

and running” and provided advice on the management of assets already under SENABICO’s 

control. OTA’s assistance on legal reform helped lay the foundation for the current, more robust 

legal framework in this area. The evaluation team, therefore, found that project objective 4 was 

partially met.

Finding: The ECT was instrumental in helping Paraguay’s asset management agency, 

(SENABICO) manage seized assets, but an asset forfeiture program remains unaddressed.

The ECT could not provide TA on asset forfeiture and recovery beyond a few trainings during 

the program cycle because the legal framework that was in place for most of OTA’s tenure was 

not compatible with the relevant international standards. Following the enactment of the law 

(Ley 5.876 2017) in September 2017 related to asset management, which was spearheaded 

largely by the Organization for American States / Inter-American Drug Abuse Control 

Commission, the ECT provided guidance resulting in SENABICO’s establishment, including 

working with the Paraguayan government to deploy resources to help SENABICO establish a 

36 GAFILAT. 2021. MER, p. 28.
26 Paraguay ECT Final Report

physical office. Beyond the initial start-up activities, the OTA Advisor also provided high-level 

expertise that included providing examples of comparative legal provisions and AML/CFT

practices from other countries. In addition, the Advisor facilitated a visit by a U.S. Marshal to 

share his investigative expertise. 

ECT primarily advised SENABICO on managing assets that were already under the control of 

the institution. SENABICO interview respondents noted that the OTA RA visited the 

SENABICO office two or three times a week, reviewing protocols and advising on procedures

for receiving goods. The Advisor also helped SENABICO develop relationships with other 

institutions, such as the PM and the Judiciary. 

The ECT has stressed, in formal and informal communications with various counterparts, the 

importance of drafting asset forfeiture legislation; Paraguay’s asset forfeiture program is on hold 

pending the passage of such legislation.

Conclusion: OTA may have missed an opportunity for reconsideration and regrouping.

During the project, the ECT realized that certain project objectives related to asset forfeiture 

could not be satisfied for reasons beyond OTA’s control. This was the case regarding assistance 

on asset forfeiture, where the lack of a comprehensive legal framework prompted OTA to focus 

instead on asset management. While the shift is understandable, the project objective and 

workplans, as reflected in OTA’s project documents, was not updated to reflect the situation. It 

may have been more beneficial for OTA to have recognized that this project objective was not 

feasible as written. Potential alternative courses of action could have included revising that 

project objective to specifically emphasize asset management rather than asset forfeiture, or 

shifting resources to other aspects of the project where additional assistance was (and still is) 

needed.

Finding: While not part of the formal project objectives, the ECT contributed to 

SEPRELAD’s data and facilities security.

While improving SEPRELAD’s security (both in terms of data and physical office space) was 

not formally part of the project objectives, the evaluation team considers it appropriate to 

comment on the contribution of the ECT Advisor in this area. 

Prompted by the leak of a SEPRELAD report to the press (which resulted in FinCEN cutting off 

information to SEPRELAD), the ECT Advisor helped SEPRELAD institute procedures to 

prevent a reoccurrence. Responses included training SEPRELAD personnel on procedures 

recommended by an assessment by the Egmont Group, an international group of FIUs, on the 

steps necessary to ensure data security. OTA Advisors also promoted the use of technology 

among SEPRELAD staff to share and analyze data and strengthen security.
27 Paraguay ECT Final Report

The ECT Advisor assisted SEPRELAD by making connections and enhancing SEPRELAD’s 

profile among other AML/CFT constituent agencies resulting in more secure, enhanced office 

facilities. SEPRELAD now has a new outside entrance with security guards and controlled card 

access. It also has adequate space with new computer software that enables financial intelligence 

reports to be coded. The OTA Advisor’s contribution to the improved security situation was 

specifically acknowledged by a former senior SEPRELAD official and a senior CBP official as a 

critical component to safeguarding SEPRELAD’s sensitive data and documents.

Security at all levels (e.g., staff, building, and data) is a key element of an FIU and its 

effectiveness. The ability of an FIU to perform its functions effectively depends on its ability to 

obtain complete and reliable information, which in turn depends on trust: unless the FIU can 

provide assurance that the information it receives will be secure, reporting entities and other 

sources (including other authorities) will be reluctant to provide that information or to 

collaborate with the FIU. This could potentially create a domino effect with the entire 

AML/CFT system. 

The Egmont Group (of FIUs) noted that “The ability of an FIU to protect the information that it 

receives and analyzes affects the integrity of the FIU and its effectiveness in its efforts to combat 

money laundering, associated predicate offenses and terrorism financing. To ensure the security 

of information, Egmont Members must institute measures related to physical security, personnel 

security and information security, including IT security. The FIU security measures adopted 

should be on a risk basis. A Member must be able to protect the confidentiality of information 

that it receives, including information from other FIUs.”37

EQ2: Which of the ECT’s project objectives in Paraguay have been sustained over time 

and why?

Discussion of the EQ1 findings regarding achieved project objectives (see EQ1 above) and EQ3 

findings regarding project objectives that were not achieved (see EQ3 below) integrates insights 

related to sustainability at the detailed, component level; they are summarized here for clarity to 

address EQ2. In addition to the objectives-level summary, discussion of EQ2 will also include 

insights related to OTA’s intangible, but important, contributions to Paraguay’s higher, 

AML/CFT system-level sustainability, specifically with fostering interagency relationships and 

support for the development of Paraguay’s AML/CFT legal framework. 

37 Egmont Group of Financial Intelligence Units. Support and Compliance Process. 2014. pp. 7–8 (footnote omitted, 

emphasis added). The Egmont Group also has a more detailed publication, Securing an FIU, which proposes 

minimum standards/guidance on physical, personnel, and document security. 
28 Paraguay ECT Final Report

Sustained project objectives

There were overarching activities that had an impact on all four project objectives that have been 

sustained over time. These were implemented mostly during the phase of the project involving 

an RA because it gave him the opportunity to identify and promote initiatives with a wide impact 

on the entire AML/CFT system. For example, ECT contributed to overall AML/CFT

sustainability through its assistance with the legal/regulatory framework and through fostering 

the improvement of SEPRELAD’s relationships with other agencies. These contributions can be 

sustained into the future provided certain conditions (such as effective implementation of the 

legal reforms, retention of institutional knowledge, and cooperation between SEPRELAD and 

personnel at other agencies) are satisfied. 

Two project objectives have been partially sustained:

• Project objective 1: Increasing the effectiveness of the SEPRELAD’s analysis and 

reporting

• Project objective 3: Improving AML/CFT case development and creating a financial 

crimes working group

Increasing the effectiveness of the SEPRELAD’s analysis and reporting

As noted in the discussion above regarding EQ1, OTA Advisors assisted SEPRELAD in all 

aspects of the creation of financial intelligence reports, including strategic and operational 

analysis; how to access and use open-source information; and how to increase SEPRELAD’s

analytical capacity through the use of technology. 

SEPRELAD has become more proactive in the reports that it sends to the PM, including sharing 

media and open-source information about suspected corruption on the part of public officials. 

The ECT provided guidance for analyzing information received from reporting entities and 

developing hypotheses to give prosecutors leads to pursue useful evidence and decision criteria 

for what should be pursued. 

Establishing the FCWG

The following discussion describes ECT’s assistance with the creation of the FCWG.

To better understand how the ECT interacted with the AML/CFT agencies either during the 

formation of the FCWG or official FCWG meetings, the evaluation team produced network 

maps that display every meeting ECT Advisors attended and some that only Paraguayan 

agencies attended as captured in trip reports during the formation of the FCWG from 2015 to 

2019. 
29 Paraguay ECT Final Report

Figure 3: Meetings on the Formation of the FCWG: August 2018–May 2019

Figure 3 maps each meeting that occurred from August 2018–May 2019, the period after the creation of the FCWG in April 

2018 to May 2019. Meetings are represented by a color-coded line between agencies for each year they took place. After 

the reestablishment of the FCWG in April 2018, the FCWG meetings continued with less direct involvement of the ECT as 

member agencies continued to meet on their own as shown above by fewer connections going through the ECT. The ECT 

continued to advocate for the FCWG as a mechanism for information sharing by turning to U.S. government agencies such as

the U.S. Embassy to bolster the FCWG to exchange knowledge among AML/CFT agencies. 
30 Paraguay ECT Final Report

Overall contributions to AML/CFT system-level sustainability

In addition to the ECT’s sustained project objectives achieved because of engagement with 

specific activities, OTA also contributed indirectly to sustainable aspects of Paraguay’s 

AML/CFT system. To be clear, we cannot make a conclusive, direct attribution of the ECT’s 

project activities to system-level changes. However, the evaluation findings provide evidence 

that OTA’s TA has contributed to two system-level developments: 1) Paraguay’s AML/CFT 

legal framework; and 2) establishment and fostering of interagency relationships within the 

AML/CFT system beyond the development of the FCWG. 

An understanding of sustainability — what remains after OTA’s ECT engagement — also 

considers how the ECT also contributed to changes in the AML/CFT system through leveraged,

indirect assistance. 

Legal Framework

As reported in project documents and discussed by interview respondents, the ECT provided 

advice supporting the development of Paraguay’s legal AMF/CFT framework and its compliance 

with international standards. While this was not a formal part of the project objectives, it is also 

true that a solid legal foundation is necessary in order for any AML/CFT program to function 

effectively (i.e., to be sustainable over time). ECT Advisors provided input into the legislative 

changes that were under consideration during the term of the Project. While they did not draft 

laws or regulations, they raised awareness of the need for legislative upgrading and provided

guidance as to the kinds of powers that an AML/CFT authority needs to have in order to be able 

to implement international AML/CFT standards as recommended by the FATF. 

In one year, SEPRELAD drafted 12 bills, 10 of which were approved. These provisions include:

• Inclusion of tax evasion as a predicate offense for money laundering

• Provision for SEPRELAD to impose sanctions

• Changes in how forfeited funds are distributed to SENABICO, SEPRELAD, SENAD, 

and the National Police

• Provision for specialized courts for money laundering, narcotics trafficking, terrorism, 

corruption, and organized crime

• Authorization for the government to make terrorism designations under United Nations 

definitions

• Sanctions for international bribery

• Allowance for freezing and seizing of funds in terrorism and terrorism-financing cases

• Strengthening of the autonomous criminal forfeiture law and changes to legal code to 

allow autonomous criminal forfeitures

• Strengthening the bearer stock law, establishing a new date of October 1, 2019, to 

convert the bearer stocks; any stocks not converted after that date become worthless
31 Paraguay ECT Final Report

• Requirement that final beneficiaries be disclosed

• Enabling the use of specialized investigative techniques in corruption cases38

According to counterpart interview respondents, the legal framework included the overall 

approach and key provisions recommended by the ECT. ECT also helped facilitate visits by 

SEPRELAD to the prosecutor’s office and meetings with police working groups. 

The package of 10 new laws passed in 2020 improved Paraguay’s AML/CFT legal framework 

considerably and should facilitate the sustainability of all four project objectives. 

Finding: OTA Advisors raised awareness of the need for a regulatory framework for the 

AML/CFT system.

Interview respondents described the ECT’s support for the idea and development of Paraguay’s 

current AML/CFT regulatory framework. A counterpart noted that an OTA Advisor worked 

with several Ministers to introduce and develop the idea. On July 10, 2018, the PM, working 

with the Advisor, convened an interagency meeting with SEPRELAD’s Minister-elect, the PM

Legal Advisor, the SENABICO Minister, the SENABICO Legal Advisor, and OTA Advisors to 

discuss the status of the then-current Money Laundering Law (from 1996) and asset forfeiture 

framework (from 2010). The discussion focused on the need to update the laws to comply with 

international standards as Paraguay prepared for its next GAFILAT mutual evaluation. The 

group also discussed the need to give Paraguayan law enforcement authorities the ability to 

immediately freeze assets identified as being used to finance or promote terrorism, as well as the 

need to draft non-conviction asset forfeiture law. 

One respondent described the OTA Advisor as a “fundamental influence” in encouraging and 

advising the process that resulted in Paraguay’s current legal framework (which may have been a 

significant factor in Paraguay’s removal from the FATF grey list). Specifically, the OTA 

Advisor helped SEPRELAD to determine the key constituents who needed to be involved in the 

legal reform process, such as with which judges and ministers SEPRELAD should engage, so 

that the project would be presented as not just as something that SEPRELAD needed, but 

something the judges and other agencies needed. OTA Advisors also helped SEPRELAD to 

organize a “you must know SEPRELAD” week, which entailed inviting journalists each 

afternoon for a week to explain the draft laws and the importance of strengthening the AML/CFT 

system. The respondent expressed the view that through these sessions, people began to 

understand what the AML/CFT system means and why it is important. A critical outcome of this 

38 Of the 12 draft laws on this list, one was not enacted and two were combined into one law, resulting in the 

adoption of 10 new laws.
32 Paraguay ECT Final Report

process was that the laws were not only launched by the executive (SEPRELAD), but by all 

three branches of the government. 

Finding: ECT Advisors provided assistance on key legal reforms.

Former and current SEPRELAD Ministers noted that OTA Advisors provided guidance 

regarding the key legal concepts and components for a package of 10 laws that upgraded the 

legal framework for Paraguay’s AML/CFT system, policies, and operations. While ECT

Advisors did not draft laws, they did provide advice on content regarding the kinds of legal 

powers that law enforcement agencies, FIUs, and supervisors need to have to combat and prevent 

money laundering and terrorist financing. 

Another SEPRELAD interview respondent characterized the OTA Advisor’s role as “pivotal” in 

making the AML/CFT constituents aware of the critical need for legal reforms and ensuring that 

SEPRELAD had the best possible guidance for the proposed laws from multiple sources. For 

example, the respondent noted that the OTA Advisor helped SEPRELAD to get in touch with an 

international expert to look at other countries’ experiences. A CBP official noted that the OTA 

Advisor had a lot of involvement in the modification of the confiscated property law and

suggested some laws that served as comparative legislation. A SENABICO official echoed the 

contribution of the OTA Advisor in providing examples of comparative legislation from other 

countries. 

However, the effectiveness of legislative changes is uncertain because they have only been in 

effect since 2019–2020. One respondent noted that it will likely take at least five years to 

evaluate the impact of the legal reforms. 

Interagency Relationships

Finding: OTA Advisors facilitated relationships between SEPRELAD and other agencies, 

and coordination between SEPRELAD and other agencies is ongoing. 

The finding related to the development of the FCWG is an example of the ECT’s contributions to 

fostering interagency relationships (see Figure 3) that are part of an explicit project objective.

Beyond that, the ECT also engaged in other project activities that contributed to the overall 

growth in SEPRELAD’s connections within the AML/CFT system. For example, one 

respondent noted that cooperation and coordination between SEPRELAD and the public 

prosecutor’s office improved greatly due to the assistance of the OTA RA. The same was true 

regarding SEPRELAD and CBP. 

One respondent noted that the OTA RA helped SEPRELAD to understand the fundamental 

importance of meetings with CBP supervisors. The ECT Advisors helped to establish a formal 

working group between supervisors to facilitate the risk-based approach to AML/CFT 

supervision and provided SEPRELAD with two experts to guide this process. While the bulk of 
33 Paraguay ECT Final Report

the assistance in this area was provided by the IMF, CBP appreciated OTA’s mentorship. A 

former financial supervisor also noted that the OTA RA “generated the link that [previously] did 

not exist.”

As noted above, OTA Advisors facilitated communications between SEPRELAD and the PM

and the judiciary regarding improvements in the legal and regulatory framework. As a result, the 

new legislation was viewed as the product of a cooperative effort between SEPRELAD and the 

other branches of government, rather than through SEPRELAD’s initiative alone.

A national Customs Authority official expressed the opinion that OTA’s assistance helped 

SEPRELAD lead, which in turn helped to improve the relationship between the Customs 

Authority and SEPRELAD. As an example, the official noted that SEPRELAD’s web access 

allows it to make more accurate and refined analysis, which helps the Customs Authority to

analyze importing or exporting entities. 

Counterpart interviews revealed that many individuals who worked with OTA Advisors remain 

in the AML/CFT system in other roles and constituencies, and relationships between individuals 

have continued despite their transitions. Some respondents noted a better understanding of the 

needs and processes of other agencies within the system as a result (but see discussion in the next 

section regarding turnover in agencies). 

The ECT’s Advisors’ contributions to milestone outcomes that resulted from SEPRELAD’s 

strengthened relationships included:

Facilitating agreements and memoranda of understanding39

• Memoranda of understanding have been executed between SENABICO and the 

Undersecretary of State for Taxation (SET), the Customs Authority, and the PM.

• A signed agreement has been executed between SENABICO and the Dirección Nacional 

de Aeronáutica Civil (equivalent to the Federal Aviation Administration in the United 

States), securing the use of a warehouse in which to store seized assets.

Facilitating relationships between individuals that have transcended to interagency 

relationships

• SEPRELAD, SET, and the Customs Authority continue to meet on a regular basis with 

the PM. They have generated very important reports of information that are sent to the 

39 OTA Economic Crimes Team internal document, 2018 Advisor Monthly Report:

201803_paraguay_ect_mr_rhaodes
34 Paraguay ECT Final Report

PM. This sharing of information was unprecedented in Paraguay prior to the ECT 

assistance. 

Facilitating creation of the National Council of AML/CFT Supervisors

• Decree No. 1528 signed by Paraguayan President on April 2, 2019, created a National 

Council of AML/CFT Supervisors. The Council includes Superintendents from CBP, the 

Insurance Supervisor, the Securities Commission, the Gaming Commission, the Credit 

Union Commission, and SEPRELAD. The group is tasked with meeting monthly to share 

information and coordinate activities within the AML/CFT legal framework. 

Conclusion: While the foundation for sustainability exists, some cautionary notes are 

necessary.

Appropriate materials (regulations, policies, and manuals, etc.) enable new personnel coming in 

to SEPRELAD as a result of political transitions to have access to the tools and institutional 

knowledge necessary to minimize disruption. An OTA Advisor as well as Paraguayan 

counterparts noted that a troublesome feature of the Paraguayan system is that when a new 

administration comes in, many agency personnel are replaced throughout the agency, not just the 

top officials. Key manuals, documented procedures, and other resources may be insufficient to 

support smooth transitions.

A related issue is that while collaboration between SEPRELAD and other agencies has 

improved, it is built on personal trust and relationships; without key personnel remaining in their 

positions, this cooperation may not last.40

Additionally, while the legal/regulatory system has improved, even the most well-crafted law 

will not be effective (i.e., it will not contribute to sustainability) if it is not implemented properly. 

Implementation requires an understanding of the legal requirements, political will to enforce 

them, and sufficient resources (human, material, and financial) to carry out the functions set out 

in the legislation.

EQ3: Which of the ECT’s project objectives were not achieved and why?

While there are no project objectives that were not achieved at all, the following three objectives 

were only partially achieved:

40 OTA Economic Crimes Team internal document, 2018 Program Review:

201906_paraguay_ect_pr_schenck_youngblood
35 Paraguay ECT Final Report

• Project objective 2—strengthening the AML/CFT supervision of financial and nonfinancial sector 

• Project objective 3—improving AML/CFT case development and creating a financial 

crimes task force

• Project objective 4—developing an asset forfeiture and recovery program

Finding: Project objective 2 was partially achieved. The CBP believes that it has a riskbased supervision framework in place and has declined TA from OTA. 

As discussed in EQ1, the CBP has been working with the IMF to implement its risk-based 

supervision framework in the financial sector and had already developed a supervision manual 

with IMF assistance. While the ECT assisted CBP with its supervision manual, CBP was not 

interested in receiving additional TA from the ECT beyond informal exchange of best practices. 

In the first quarter of 2019, an Advisor accompanied CBP examiners to provide on-the-job 

mentoring, embedded as a team member to assist with AML/CFT issues including drafting 

reports.

41

 According to one respondent, this “took the assistance to the next level.” 

As described by an Advisor, CBP has its own anti-money laundering unit, but that unit really 

does not have effective two-way communication with other areas of CBP. According to the 

Advisor, CBP did not appear to be very interested in STRs or in sharing information. However, 

the GAFILAT MER rated Paraguay “largely compliant” with FATF Recommendation 26 

(Regulation and Supervision of Financial Institutions), “compliant” with FATF Recommendation 

27 (Powers of Supervisors) and “largely compliant” with FATF Recommendation 28 

(Regulation and Supervision of DNFBPs).42

Conclusion: More work is needed in non-bank financial and non-financial sectors in riskbased supervision. 

While the Government of Paraguay has made good progress in AML/CFT supervision relative to 

financial sector entities (particularly banks), there has been less progress in other areas. 

According to one respondent, the contrast in capacity between financial sector supervisors and

CBP supervisors needs to be addressed. This official noted that the level of performance of

supervisors of securities, cooperatives, and gambling establishments needs to rise to that of 

CBP’s. The official recommended that that there be close support from supervisors who are well 

prepared to help others. A CBP official expressed the view that CBP’s participation in the 

committee of supervisors revealed that there is still a path of maturation of other institutions and 

41 OTA Economic Crimes Team internal document, 2019 Advisor Monthly Report:

201913_paraguay_ect_mr_rhoades

42 GAFILAT. 2022. Mutual Evaluation Report of the Republic of Paraguay, pp. 289–294.
36 Paraguay ECT Final Report

other financial and non-financial supervisors, which should be given attention. The CBP official 

noted that many other reporting entities and supervisory authorities are not as sophisticated as 

CBP and are less committed to AML/CFT compliance. CBP has tried assisting other supervisors 

to address these issues, through human resources advice and characteristics of effective 

AML/CFT procedures, for example.

Finding: Project objective 3 was partially achieved. The FCWG was established and 

continues to meet, but it is unclear whether AML/CFT case development has improved.

As discussed above, structural constraints in the AML/CFT system prevented ECT from having a 

greater impact on AML/CFT case development after the FCWG was established:

• There are no specialized courts. Local judges have jurisdiction over many types of

crimes, including these very complex crimes. ECT Advisors traveled outside of 

Asunción to work with regional judges and prosecutors to improve their understanding of 

the system and capacity,43 but regional authorities have limited experience and 

specialized legal knowledge. 

• High levels of corruption in Paraguay have a negative impact. Local judges, 

investigators, or prosecutors could be influenced by corrupt practices. 

• The designation of all the prosecutors’ staff is not impartial and highly politized. 

• Organized crime could threaten local judges, investigators, or prosecutors if they opened 

or continued with case development. In 2022, a prosecutor was assassinated allegedly for 

his work prosecuting drug trafficking gangs.44

On a positive note, one provision in the package of 10 new laws created specialized courts at a 

national level to address some of these obstacles. 

Finding: Project objective 4 was partially achieved. The ECT did not provide technical 

assistance on asset forfeiture and recovery because the legal framework was insufficient.

As explained above, ECT activities focused mostly on the administration of assets. As in the 

case of project objective 3, the following structural elements in the Paraguayan system prevented 

the ECT from having a greater impact in this project objective:

43 OTA Economic Crimes Team internal document, 2016 Advisor Trip Report: 201605_paraguay_ect_eot_hayden

44 Robbins, Seth. 2022. “Connections to Paraguay Prosecutor’s Murder Stretch from Colombia to Brazil.” InSight 

Crime. June 8, 2022. https://insightcrime.org/news/paraguay-prosecutors-murder-plot-hatched-in-colombia/
37 Paraguay ECT Final Report

• ECT raised awareness and provided training on asset forfeiture at the beginning of the 

project but the low levels of case development (see project objective 3) directly impacted

asset forfeiture that can only be implemented through criminal cases.

• The legal procedure for seizing and confiscation was only clear for assets related to 

narcotics trafficking. One of the laws, in the package of 10 new laws, created the 

procedure to seize and confiscate all crime-related assets. 

• Non-conviction-based confiscation is allowed for certain situations, but there is no clear 

procedure on how to implement it. The law in the package of 10 laws on asset forfeiture 

created this procedure only recently. 

• The ECT’s TA did not include recovery and repatriation of assets situated abroad or help 

with international cooperation agreements involved in transnational cases. 

Conclusion: Because of the wide scope of the ECT’s project objectives, OTA may have 

missed opportunities for reconsideration and regrouping. 

According to project documents, the ECT became aware during the program that project 

components related to AML/CFT supervision and asset forfeiture could not be implemented for 

reasons beyond OTA’s control. 

Project objective 2 aimed to provide TA for risk-based supervision to the financial and the nonfinancial sectors as well as Government of Paraguay agencies. Paraguay has a wide variety of 

supervisors, but the ECT focused on providing TA only to CBP and SEPRELAD (and ECT’s 

assistance to CBP was quite limited due to CBP’s engagement with IMF assistance). The ECT 

did not provide additional TA to other financial or non-financial supervisors. This was a missed 

opportunity to provide TA to other agencies that may have been interested in and benefited from

receiving it, including opportunities to further objectives 1, 3, and 4 by engaging the agencies 

below:

• Instituto Nacional de Cooperativismo—cooperatives supervisor

• Superintendencia de Seguros—insurance sector supervisor

• Comisión Nacional de Valores—securities supervisor

• Supreme Court—supervisor of notaries

• Comisión Nacional de Juegos de Azar—casinos supervisor

SEPRELAD is also responsible for supervising financial and non-financial entities, including 

remittance organizations, real estate agents, accountants, and lawyers. SEPRELAD received 

training on AML/CFT supervision from ECT, but further TA was not given to develop a 

supervisory methodology that is risk-based for the entire universe of supervised entities. 
38 Paraguay ECT Final Report

Project objective 4 was not achieved because the legal framework in effect at the time of the 

project did not include provisions for asset forfeiture, which prompted OTA to focus instead on 

asset management. OTA recognized that this project objective was not feasible until very late in 

OTA’s project cycle—when Paraguay’s new legal framework was put in place with little time 

remaining to achieve the objective. Potential alternative courses of action could have included 

revising that project objective to specifically emphasize asset management rather than asset 

forfeiture, or shifting resources to other areas where additional assistance was (and still is) 

needed. These actions could include introducing the concepts of non-conviction-based 

confiscation, recovery, and repatriation of assets situated abroad, and international cooperation 

agreements to identify, divide, and repatriate assets involved in transnational cases.

Finding: It is unclear whether the number of cases increased due to the ETC’s TA, but 

according to the GAFILAT MER, the number of convictions compared to the level of risk 

in Paraguay is still low.

Advisor and counterpart interview respondents provided some possible explanations for this, 

including: 

• SEPRELAD and the PM differ in their expectations regarding the purpose and content of 

SEPRELAD’s reports. As discussed in the findings for EQ1 (above), the PM often 

considers the reports submitted by SEPRELAD, while improved, to be still insufficient to 

proceed with steps toward case development and eventual prosecution.

• In addition, many respondents identified public corruption as a significant problem in 

Paraguay that enables money laundering. One prosecutor noted that corruption 

permeates the entire system and expressed the view that if Paraguay does not attack 

corruption, bad consequences will follow. Officials from SENABICO described some of 

the problems associated with corruption relative to money laundering. These include: 1) 

lack of money laundering convictions involving corrupt individuals; 2) lack of asset 

recovery in cases where corruption is a factor; 3) inadequate resources and personnel for 

intelligence work and investigations; and 4) SENAD’s rare investigations of non-drugrelated criminality.

• The ECT knew judicial corruption was a problem at the inception of the program. An 

Advisor explained that certain judicial procedures can favor defendants and impede 

investigations, e.g., a provision that allows defense attorneys to demand that a prosecutor 

or judge be recused from a case. According to the Advisor, this is easy to do and 

common practice in Paraguay, and it is a reason why so few cases are ultimately tried in 

the courts. A respondent shared an anecdote of this occurring in February 2019. The 

lead prosecutor in a major case was recused the day before 14 targets were to be placed 

under investigation and arrested. SEPRELAD has led an interagency effort to propose 

new legislation to make it more difficult to remove a prosecutor from a case.
39 Paraguay ECT Final Report

• Non-specialized judges also do not have a sufficient understanding of the applicable 

burden of proof needed to secure a conviction for money-laundering crimes. Counterpart 

interview respondents shared that while specialized judges who have been trained in 

AML/CFT matters generally have a good understanding of these issues, the same is not 

true of judges of general jurisdiction. According to one respondent, a non-specialist

judge will investigate drug trafficking but is unlikely to be interested in following the 

dirty money. A specialized judge will try to separate and identify the dirty money. As 

this official described the situation, “The specialist [judge] will go to pursue the wash—

the ordinary [judge] only the precedent.”

• A respondent noted that special investigative techniques are only allowed in cases 

involving illegal drugs and trafficking, and that Congress has not authorized such special 

techniques for investigating other crimes. 

• Another respondent described the problem of inadequate investigative resources, noting 

that while investigating a money-laundering case is never easy, it is particularly difficult 

in Paraguay, where the prosecutor’s office has minimal data to work with and cases 

stagnate. According to the respondent, the situation has not advanced significantly in a 

long time. This respondent noted that there is no mechanism for the prosecutor to access 

information online, and that SEPRELAD has much more access to quick, online 

information than the public prosecutor’s office. The respondent also said that there has 

not been enough training to teach prosecutors to connect dirty money with predicate 

events.

• The prosecutor’s office also lacks sufficient personnel. A United States Agency for 

International Development interview respondent working in the sector noted that the 

prosecutor’s office has only eight to 10 analysts for the entire country, and very few of 

them have financial intelligence expertise.

Overall Conclusion: The impact of OTA’s assistance is reflected in Paraguay’s improved 

standing per the 2021 GAFILAT Mutual Evaluation Report.

OTA’s overall contribution to Paraguay’s AML/CFT system through TA to SEPRELAD can be 

summarized through GAFILAT’s report. A SEPRELAD interview respondent noted that without 

the help of the OTA RA, Paraguay would never have passed the 2021 GAFILAT mutual 

evaluation. Paraguay’s ratings improved dramatically between the 2008 and 2021 MERs. 

According to GAFILAT, Paraguay is now “compliant” or “largely compliant” with most of the 

FATF recommendations, whereas per the 2008 MER, it was only “compliant” with two, and was 

“non-compliant” with 30. 

Based on the evaluation findings supported by interviews and OTA’s project documents, Table 1 

makes connections between the ECT’s TA contributions and GAFILAT’s determinations.
40 Paraguay ECT Final Report

Additionally, Paraguay was removed from the FATF “grey list” in April 2018, three years 

following the commencement of OTA assistance, after the FATF concluded that Paraguay had 

undertaken measures to correct the deficiencies identified in the core and key recommendations

of the previous (2008) MER. This is an important point because grey listing has significant 

negative consequences, including:

• It discourages foreign investment; a grey-listed country stands to suffer foreign direct 

investment shrinkage as a result. According to the IMF, grey-listed countries typically 

suffer an average net loss of 7.68% of capital flow into their states relative to GDP.45

• Foreign banks and investors may become reluctant to do business in grey-listed countries, 

choosing instead to operate in other jurisdictions that present healthier risk profiles. 

• Grey-listed countries are automatically considered high-risk jurisdictions by the 

European Union and the United Kingdom (in other words, they are considered 

jurisdictions with strategic deficiencies in their AML/CFT regimes that pose significant 

threats to the financial system).

Paraguay would not have achieved either of these things without major improvements in 

SEPRELAD’s capacity, and that the ECT has made a significant contribution to SEPRELAD’s 

effectiveness. 

IV. Recommendations

Based on the evaluation findings, from a third-party perspective, the evaluation team suggests 

that OTA consider the following recommendations that can apply to continued assistance in 

Paraguay and/or similar ECT programs in other countries:

1) Formally engage other constituents in program planning and technical assistance

implementation.

Three of the ECT’s four project objectives—1) strengthening AML/CFT supervision of financial 

and non-financial sector; 2) improving AML/CFT case development and creating a financial 

crimes working group; and 3) developing an asset forfeiture and recovery program—depended 

on input and coordination with agencies other than SEPRELAD. While OTA Advisors worked 

closely with SEPRELAD throughout the project and interacted with other parts of the 

government, the evaluation did not find evidence that OTA formally consulted other agencies

with planning or implementation of project activities. Given the ECT’s broad and ambitious 

45 Mizuho Kida and Simon Paetzold. 2021. The Impact of Gray-Listing on Capital Flows: An Analysis Using 

Machine Learning. IMF Working Paper 2021/153
41 Paraguay ECT Final Report

objectives at the inception, it would have been useful to plan a minimal level of active 

engagement, from the outset, with other agencies within Paraguay’s AML/CFT system that 

interact with SEPRELAD on a regular basis. The ECT never entered into a formal agreement or 

terms of reference with other agencies like the ECT did in its previous engagement in Paraguay 

from 2003 to 2011.46 While the strategy for the ECT’s current program focused almost 

exclusively on TA to SEPRELAD, critical constraints to case development and prosecution with 

other constituent agencies remain outside SEPRELAD’s influence. 

2) Regularly update planning documentation to adjust to changes Advisors are making as 

they address emergent needs and realities on the ground with different activities.

During the project, changes in circumstances necessitated adjustments in Advisors’ plans. For 

example, it was not feasible for OTA Advisors to perform their originally contemplated roles 

regarding AML/CFT supervision because the IMF covered this need. It would have been helpful 

for the ECT to adjust the workplans more frequently than annually to ensure OTA’s activities 

and assistance remained relevant to current needs and opportunities to leverage change.

3) Include opportunities to review program strategies and progress and make mid-course 

corrections in response to changing circumstances.

As noted above, there were aspects of two of the project objectives that could not be achieved for 

reasons beyond OTA’s control. OTA did conduct mid-course program reviews and generally 

adjusted its assistance. However, OTA did not formally update the project objectives to reflect 

the changed circumstances. Doing so may have provided an opportunity to further engage 

Paraguayan counterparts and give increased focus to areas in which assistance was most 

critically needed. For example, OTA’s periodic internal program reviews provided useful 

insights on progress toward objectives, milestone achievements, and barriers.47 It is unclear to 

the evaluation team, based on Advisor interviews and project documents, how the reviews were

or were not used to inform mid-course changes with the ECT’s original project objectives or to 

take advantage of new opportunities for leveraging change. 

For example, the ECT’s recognition of critical constraints to the AML/CFT system outside

SEPRELAD were potential missed opportunities for OTA to change or expand its original scope 

of TA beyond SEPRELAD. Alternatively, OTA could have curtailed further efforts toward 

unachievable objectives (such as those related to asset forfeiture) and either planned an earlier 

46 OTA Economic Crimes Team internal document, 2013 End of Project Report:

201301_paraguay_ect_eop

47 For example, OTA Economic Crimes Team internal document, 2018 Program Review:

201906_paraguay_ect_pr_schenck_youngblood
42 Paraguay ECT Final Report

exit strategy or redeployed time and resources to program objectives that targeted other 

unaddressed TA needs for SEPRELAD.

4) Explore opportunities to continue to support Paraguay to address priority actions of 

GAFILAT’s MER.

While GAFILAT’s assessment of Paraguay’s compliance with FATF recommendations was 

overwhelmingly positive, its assessment of Paraguay’s record on the Immediate Outcomes was 

not as strong. GAFILAT rated Paraguay as “moderate” in ML/TF financial intelligence and 

confiscation (Immediate Outcomes 6 and 8) and “low” in ML investigation and prosecution 

(Immediate Outcome 7). 

OTA’s 2019 final project review concluded that it was appropriate to graduate Paraguay in 2019, 

citing the need for the Paraguayan constituents to fully implement recent reforms to achieve 

sustainability. The review also noted the risk of creating dependency on OTA technical 

assistance in the absence of graduation.48 While this concern is understandable, interviews with 

Paraguayan counterparts as well as some of the findings of the 2021 GAFILAT MER suggest 

that OTA could provide further useful assistance, including working through the issues with the 

PM and SEPRELAD’s reporting, moving forward on asset seizure now that the legal framework 

includes relevant provisions, and reinforcing the efficacy of the FCWG that was active while the 

FCT was involved but has been less so more recently.

5) Explore opportunities to assist SEPRELAD in updating the analysts’ handbook and 

related standard operating procedures (SOPs).

OTA’s 2019 final project review noted that the RA could assist with the deployment and use of 

SOPs and could work with the SEPRELAD analysts to identify which SOPs need revisions and 

make updates with the RA’s guidance. For example, information security SOPs are a priority for 

FATF.

6) Explore opportunities to assist supervisory authorities in other financial and nonfinancial sectors, as well as to the PM.

The 2022 GAFILAT MER rated Paraguay “largely compliant” with FATF Recommendation 26 

(Regulation and Supervision of Financial Institutions), “compliant” with FATF Recommendation 

27 (Powers of Supervisors) and “largely compliant” with FATF Recommendation 28 

(Regulation and Supervision of DNFBPs). However, several counterpart respondents said that 

48 OTA Economic Crimes Team internal document, 2018 Program Review:

201906_paraguay_ect_pr_schenck_youngblood
43 Paraguay ECT Final Report

additional OTA assistance would be helpful with other (non-bank) financial entities and nonfinancial sector entities (DNFBPs).

Another respondent expressed that despite the positive GAFILAT findings, a better 

understanding of the system leads to further incentives to improve. This official noted that 

previous MERs focused only on technical compliance, in contrast to the current emphasis on 

efficient AML/CFT implementation of the current legal framework’s laws and procedures. 

A former SEPRELAD official wished that OTA could provide an Advisor focused on the 

prosecutor’s office, noting that it is useless for SEPRELAD to provide good reports if the 

prosecutor’s office does not know how to use them. As noted above, GAFILAT rated Paraguay 

as “low” in Immediate Outcome 7 (Investigation and Prosecution). Additionally, GAFILAT 

noted a low level of compliance with elements of Paraguay’s Strategic Plan regarding 

“detection-investigation-criminal justice.”49

7) Explore opportunities to further improve cooperation between SEPRELAD and CBP.

SEPRELAD and CBP have worked well together with some past initiatives (e.g., developing 

banking guidelines) as discussed in OTA’s 2018 program review document, but the review 

highlighted some areas where collaboration should be strengthened. The evaluation team

concurs with the following opportunities identified in the program review:

• According to SEPRELAD interview respondents, CBP’s risk-based supervision is weak, 

and they were not optimistic that the AML council could influence CBP to improve its 

supervision.

• The Paraguayan Bankers’ Association discussed poor communication between 

SEPRELAD and CBP, resulting in a lack of clarity regarding supervisory matters. The 

Association noted that the banks needed clear guidelines, but that outreach was limited. 

• While CBP expressed satisfaction and appreciation for OTA’s assistance, CBP did not 

seek additional assistance, because it was working with the IMF to implement a riskbased supervision system. Despite this, OTA’s 2019 program review observed that there 

were plenty of opportunities for additional assistance considering CBP’s work with the 

IMF. 

Four years have passed since the OTA’s final program review in 2019, and the evaluation 

suggests two additional possibilities for targeted TA:

49 GAFILAT. 2021. MER, p. 38.
44 Paraguay ECT Final Report

• Collaboration between SEPRELAD and CBP to reach a consensus view with STR

reports50

• AML/CFT aspects of group (“consolidated”) supervision

The second point is especially pertinent. Paraguay hosts a significant number of international 

banking groups.51 Financial associations of this type pose unique challenges in the AML/CFT 

area due to the necessity of groupwide policies and procedures for effective risk management 

and effective means for regulators to analyze and address the risks associated with its 

relationship with other group entities.52 A Paraguayan financial supervisor identified 

consolidated supervision of financial groups as one of the main challenges in strengthening 

Paraguay’s AML/CFT system going forward. The GAFILAT rated Paraguay as “largely 

compliant” with FATF Recommendation 18, noting that despite some positive aspects, 

there is no obligation to provide for group-wide compliance, audit, and/or AML/CFT functions.53

All of these items suggest that OTA’s support of SEPRELAD’s collaboration with CBP is worth 

consideration.

8) Explore opportunities to provide TA for beneficial ownership of legal entities.

The new legislation requiring registration of beneficial owners is a positive AML measure. The 

effectiveness of the law, however, depends upon compliance by entities and their beneficial 

owners, and upon the ability and willingness of public authorities to detect hidden beneficial 

owners and to impose substantial penalties for noncompliance. Experience in other countries 

suggests that criminals are quite adept at concealing beneficial ownership and true control of 

legal persons and legal arrangements through which they conduct illicit activities. A former 

SEPRELAD official expressed that prosecutors need more knowledge and training on research 

techniques regarding how to trace actual beneficial owners, and that such intervention needs to 

come through an actual program rather than occasional seminars.

50 OTA Economic Crimes Team internal document, 2018 Program Review:

201906_paraguay_ect_pr_schenck_youngblood

51 IMF Country Report No. 22/248: Paraguay Technical Assistance Report––Bank Resolution Framework And The 

Deposit Guarantee Fund. 2022. https://www.imf.org/en/Publications/CR/Issues/2022/07/26/Paraguay-TechnicalAssistance-Report-Bank-Resolution-Framework-and-the-Deposit-Guarantee-521332

52 Gary A. Gegenheimer. 2019. “Consolidated Supervision and Anti-Money Laundering Compliance: The 

Crossroads of Effective Banking Supervision” SEACEN Financial Stability Journal, 

https://www.seacen.org/publications/RePEc/702001-100456-PDF.pdf

53 GAFILAT. 2021. MER, pages 265–66.
45 Paraguay ECT Final Report

V. Suggested Next Steps

Paraguay has made substantial progress in its AML/CFT regime. This is confirmed by 

GAFILAT’s assessment of Paraguay as “compliant” or “largely compliant” with 37 of the FATF 

recommendations in its 2021 MER and Paraguay’s 2018 removal from the FATF grey list. This

is due in large part to OTA’s assistance to SEPRELAD, which has significantly improved its 

capacity for meaningful analysis and has a much clearer understanding of the proper role of an 

administrative FIU. All the counterparts whom the evaluation team interviewed were extremely 

complimentary of the ECT Advisors’ guidance and support.

Other component parts of the AML/CFT establishment could also benefit from OTA assistance. 

While the CBP may have a satisfactory program for risk-based AML/CFT supervision, the nonbank supervisory authorities, as well as public authorities that oversee DNFBPs clearly do not. 

The GAFILAT rated Paraguay only “partially compliant” with FATF recommendation 22 

(customer due diligence relative to DNFBPs) and noted that “it is necessary to continue 

strengthening the supervision and sanction processes in those DNFBPs designated as having a 

higher level of risk.”54 The judiciary and PM could also benefit from assistance. OTA should 

explore opportunities in this area, whether on a solo basis or in collaboration with other 

international development organizations. 

Reporting entities within the AML/CFT system could benefit from assistance. The GAFILAT 

MER commented on both the low number of STRs by some reporting entities and the low 

quality of many STRs.55 This reflects a lack of understanding among some reporting entity 

sectors as to what is required and how to provide information that will be useful to SEPRELAD 

and the PM. OTA should explore means to help reporting entities improve their understanding 

and processes in this area.

Resistance to change will challenge some administrative officials who have been in their 

positions, or similar positions, including impacting the relationship between SEPRELAD and the 

PM. Many interview respondents also acknowledged that corruption is a major problem. 

Despite these challenges, the effort is worth pursuing. OTA should take every opportunity to 

raise awareness among Paraguayan government officials, reporting entities, and members of the 

public of the destructive effects of money laundering, terrorist financing, and financing of 

proliferation of weapons of mass destruction, and to encourage the development of the political 

will — and the commitment of sufficient resources — to combat these undesirable elements. 

The cost of vigorous enforcement is high, but the cost of weak enforcement is much higher.

54 GAFILAT. 2021. MER, p. 175.

55 GAFILAT. 2021. MER, pp. 50; 59–61.
46 Paraguay ECT Final Report

VI. Annexes
47 Paraguay ECT Final Report

Annex A: Methodology and Data Sources

Primary evaluation methods included a desk review of project documents provided by the Office 

of Technical Assistance (OTA) and key informant interviews (KIIs) that provided multiple 

perspectives and sources to support and verify the evaluation findings.

Desk Review

Project documents 

The evaluation team analyzed project documents provided by OTA to gain a basic understanding 

of OTA’s activities and interventions in the ECT program area in Paraguay. 

For EQ1, the desk review focused on OTA’s high-level project objectives that were achieved,56

and details of the ECT’s activities that led to their achievement from OTA’s project documents

as reported by ECT Advisors. Similarly, the team reviewed the project documents for details of 

project objectives that were not achieved and why to support findings for EQ3. The desk review 

process for EQ1 and EQ3 also provided the evaluation team with evidence for sustainability to 

support EQ2’s findings.

OTA shared the following categories of project documents with the evaluation team:

• Briefing materials (4)

• End of project report (2)

• Field trip reports of OTA Advisors (41)

• OTA letters to the Minister (2)

• Paraguay evaluation cover sheet 

• Program review (3)

• Project performance (3)

• Project proposal narratives (4)

• Technical implementation reports (4)

• Terms of reference for work with SEPRELAD 2015

• Project workplans for 2015, 2016, and 2019 (4)

56 OTA Economic Crimes Team: Paraguay 2019 Work plan
48 Paraguay ECT Final Report

Reference documents

In addition to project documents, the evaluation team used the following external documents to 

contextualize and support the findings and conclusions presented above:

• GAFILAT, Mutual Evaluation Report of the Republic of Paraguay, 2022

• Official documents from Paraguay: Laws, regulations, and the AML/CFT National 

Strategic Plan

• Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the 

Financing of Terrorism, Financial Intelligence Units: 

https://www.coe.int/en/web/moneyval/implementation/fiu

• Bureau of International Narcotics and Law Enforcement Affairs 2016 International 

Narcotics Control Strategy Report (INCSR) — Countries/Jurisdictions of Primary 

Concern — Paraguay

Key Informant Interviews

Working from interview guides tailored for each category of respondents, the evaluation team 

conducted KIIs to document a full range of perspectives on OTA’s work, uncover new findings, 

and validate findings from the document analysis. KIIs focused on specific OTA activities and 

technical assistance to address the three evaluation questions (EQs) in greater detail. 

Annex Table A is an inventory of respondents interviewed in-country or virtually. Their names 

have not been included in this report to maintain anonymity.

Mixed-Methods Approach

The evaluation team’s design approach started with the desk review to establish a basic 

understanding of what the ECT did in Paraguay. The KIIs were then used to verify, build on, 

and/or add nuance to what was already known from the documents. The team also analyzed the 

ECT’s contributions to broader outcomes in Paraguay’s AML/CFT system. 

Preliminary findings for the ECT project were verified using multiple data sources and the 

evaluation team developed conclusions regarding OTA’s contributions to project objectives and 

their sustainability.

Data Collection

Document review 

The evaluation team reviewed documents to identify themes and preliminary findings for deeper 

probing and verification. The evaluation team implemented a data coding process using the
49 Paraguay ECT Final Report

ATLAS.ti qualitative analysis application that enables the coding, consolidation, and retrieval of 

data, such as document sources, text excerpts, themes, and key words for further analysis. 

Key Informant Interviews

Between November 2 and November 30, 2022, the Bixal evaluation team conducted 11 KIIs

with 26 respondents. The interviews were conducted in Spanish with counterparts and in 

English with OTA Advisors. Interviews in-country were conducted in person and interviews 

conducted after the evaluation team had left Paraguay were done virtually. All interviewers 

closely followed prepared interview guides and instructions to ensure that interviews were 

unbiased and focused on the EQs. When possible, the Bixal evaluation team recorded the 

interviews to ensure data were captured completely and accurately. The evaluation team 

transcribed audio recordings in Spanish and then translated them to English for analysis. 

Notetakers took notes using a notetaking guide. In advance of the first KII, notetakers were 

trained on the evaluation team’s SOP for notetaking to ensure they captured the highest quality 

data. All interview notes that were taken in Spanish were translated to English. The quality 

assurance section of this report details the evaluation team’s quality assurance process for notes 

and transcription translations.

During November 2–11, 2002, the evaluation team visited Asunción, Paraguay. The evaluation 

team completed 11 total KIIs with 26 respondents. Annex Table A breaks out KII respondents 

by group and by gender. Annex Table B breaks out KII respondents by institution. 
50 Paraguay ECT Final Report

Annex Table A: Number of Interview Respondents

KII Respondent Groups Respondents

Direct Government of Paraguay counterparts 20

Beneficiaries 1

Constituents 3

ECT Advisors 2

KII Respondent Gender

Men 17

Women 9

Total KII Respondents 26

Respondents represented the following institutions (in alphabetical order):

Annex Table B: Interview Respondents by Institution

Institution Respondents

Central Bank of Paraguay 4

OTA 2

Paraguayan Chamber of Deputies 1

Public Ministry (Attorney General's Office) 2

SENABICO 3

SEPRELAD Financial Intelligence Unit 8

Undersecretary of State for Taxation (SET) 3

U.S. Embassy 1

United States Agency for International Development 2

Total KII Respondents 26

Data Analysis Process

The evaluation team conducted qualitative analysis of the KII on an ongoing basis concurrent 

with data collection to identify emerging findings and trends during the evaluation’s data 

collection phase. The evaluation team translated interview notes to English to be coded and 

analyzed with the ATLAS.ti application by grouping similar data under themes or categories so 
51 Paraguay ECT Final Report

the evaluation team can easily locate, retrieve, and combine the textual data that corresponds to 

an EQ, concept, or theme of interest.

When data collection was nearly complete, all evaluation team members convened for an 

analysis workshop to discuss findings and conclusions for EQs one and two. After data 

collection was complete, the evaluation team met to discuss findings for EQ three, as well as 

trends and themes that emerged during data analysis. Insights and ideas from this process were 

developed for presentation as preliminary findings to OTA for vetting and discussion on 

December 19, 2022, before the final evaluation report was drafted. With insights from the 

presentation, the team further analyzed the data for additional verification of findings and 

conducted an additional KII to further probe a subset of questions of interest. 

Quality Assurance

The evaluation team followed standard quality assurance best practices that included the 

following:

• Notetakers uploaded their notes at the end of each day of data collection. The team 

leader and/or Bixal staff reviewed notes for accuracy, completeness, precision, and 

quality.

• Spanish transcripts and notes were translated using an external translation service. A 

bilingual team member reviewed all translated transcripts and notes for completeness and 

accuracy. 

• The evaluation team met at the end of each day of data collection in Asunción to discuss 

what was heard and observed to ensure consistency in collecting and reporting data.

• The ATLAS.ti application enabled the team to check for accuracy and completeness of 

qualitative data as they are entered and coded. Standard cross-checking protocols were

followed to ensure consistency and accuracy.

• The data analysis workshops provided an opportunity for evaluation team members to 

check each other’s assumptions and cross-check data quality.
52 Paraguay ECT Final Report

Annex B: Limitations 

The evaluation team faced several key limitations of time, resources, and data that constrained 

the evaluation’s possible purposes and scope. The OTA and the evaluation team were aware of 

most of these limitations from the beginning, and evaluation design choices were made to 

address these limitations. 

Limited Access to OTA Advisors, Counterparts, and AML/CFT Constituents

The evaluation team initially identified six OTA Advisors for KIIs who had worked on the ECT 

project in Paraguay at different times in the project cycle, providing technical assistance in 

different areas, as Intermittent Advisors and RAs. However, the evaluation team was only able 

to interview two OTA Advisors, one of whom was the only Advisor to live in Paraguay. The 

evaluation team was unable to interview most of the ECT’s Intermittent Advisors, including the 

first Advisor at the inception of the project, and another who focused on financial supervision. 

This limitation was partially mitigated through the evaluation team’s focus on OTA’s project 

documents that included a complete set of trip reports that documented Advisor activities, 

although the pro forma reports do not reflect Advisors’ insights as well as an interview.

The evaluation team was also unable to speak to some former counterparts and their staff who 

have moved on from their previous positions since collaborating with OTA. For example, the 

evaluation team was unable to interview one key counterpart, a former SEPRELAD Minister 

who worked with the first Intermittent OTA Advisor in the project’s beginning. From 

counterpart interviews, the evaluation team learned that AML/CFT agencies have experienced 

significant periodic staff attrition and replacement concurrent with new presidential 

administrations. As a result, the evaluation team interviewed a limited number of counterpart 

staff who had worked directly with OTA Advisors. In addition, some former OTA counterparts 

and staff members declined to be interviewed for reasons that were not articulated, but the 

evaluation team assumes that real or perceived job security, political, personal safety, or legal 

risks were among inhibiting factors.

Specifically, despite multiple attempts, the evaluation team was unable to speak to staff from 

SENAD. OTA Advisors worked indirectly with SENAD to establish a financial crimes working 

group with other AML/CFT agencies in Paraguay and to advise on SENAD’s asset forfeiture 

strategy. The evaluation team was unable to interview compliance officers in the banking sector 

to probe whether other private sector constituents in the AML/CFT system observed any indirect 

changes that might be associated with the ECT’s contributions to SEPRELAD.

To address these limitations, the evaluation team reached out beyond the names found in OTA’s 

project documents to additional respondents who were suggested during interviews in snowball 

sampling to broaden the respondent pool. While some of the original intended respondents were 

unavailable, the evaluation team was able to interview alternative subjects who provided a 
53 Paraguay ECT Final Report

diversity of perspectives on the ECT’s activities and contributions as well as verification of the 

evaluation findings from multiple sources.

Evaluation of a Strategic and Sensitive Sector 

Paraguay is a small country and the AML/CFT sector is fraught with security, political, and legal 

risks and sensitivities that manifested challenges to this external evaluation process. The 

evaluation team requested interviews with counterparts who often preferred to be interviewed in 

groups. While potentially being able to include more respondent perspectives, the evaluation 

team did notice some respondents were unable or unwilling to speak freely in group settings with 

their colleagues or supervisors, potentially wary of political or professional consequences. To 

mitigate this limitation, the evaluation team requested individual follow-up meetings with some 

respondents to give them an opportunity for a more discreet, individual interview that resulted in 

alternative perspectives that would not have otherwise been shared. 

Limited Access to Background Statistical Metrics and Contextual Data 

For various legal, security, political, and/or ethical reasons within Paraguay’s AML/CFT context, 

the evaluation team did not have access to statistics, confidential reports, or internal metrics such 

as:

• AML/CFT data or key performance indicators

• SEPRELAD reports

• AML/CFT-related suspicious activity reports, cases, or investigations

The evaluation team is aware of the sensitivities around AML/CFT data and cases in Paraguay. 

However, without access to those data, the evaluation team cannot make any quantitative 

statements on the AML/CFT system in Paraguay, definitive statements on the quality of 

SEPRELAD’s reports, or statements on the quality of AML/CFT cases in Paraguay. The 

evaluation team relied on the qualitative data from interviews that described changes in 

Paraguay’s system over time as narrative observations.

Recall Bias

The evaluation team relied heavily on data generated from qualitative KIIs in which respondents 

were asked to recount facts and details from events that happened three to seven years ago. 

Selective memory can lead to measurement bias. In many cases, the key informants’ 

perspectives of activities that happened years in the past may have changed. A lens of selective 

memory and current circumstances may contribute to a key informant’s overall perspective. 

Recall bias can also lead to respondents forgetting important information such as names or dates, 

and the detailed nuance that is important to understand how and when the ECT’s technical 

assistance was implemented. To account for this, the evaluation team reviewed and coded early 
54 Paraguay ECT Final Report

project documentation such as trip reports to better understand the inception phase of the ECT’s 

project in Paraguay and articulated some interview questions on early activities. While most of 

the interviews and the evaluation team’s questions focused on the later years of the project that 

were most fresh in respondents’ memory, questions about the early period invited responses in 

general terms, with the understanding that details were limited.

Project Documentation Limitations

A key challenge for the evaluation team was gaining an understanding of the ECT’s 

contributions to change at a strategic ECT project or AML/CFT system level. While OTA has 

good activity-level documentation of the ECT’s work, such as trip reports covering short periods 

of time, there are no summative or consolidated annual or final reports for the ECT’s work in 

Paraguay from 2015 to 2019. In contrast, OTA’s previous ECT engagement in Paraguay from 

2003 to 2011 was documented in a five-page end-of-project report produced in 2013,

57 but this 

precedent was not followed with a similar document after the ECT’s engagement ended in 2019. 

OTA’s annual Traction and Impact Assessments,

58 while designed to provide an annual 

performance review against OTA’s Agency-level, cross-program objectives, are limited to 

subjective scores. These scores combine “traction” (i.e., progress) and the impact of multiple 

project objectives in a single Likert scale number using score criteria that were not specified and 

do not include any accompanying narrative of the ECT’s results in Paraguay.

Although OTA has adopted the use of logic frameworks for other, more recent programs, 

ECT/Paraguay lacks a log frame that includes program-level objectives and progress measures 

that would have been a core data source from which the evaluation could have built. 

The evaluation team used all the project documents that OTA provided. While workplans for 

2015, 2016–2017, and 2018–2019 were useful resources for the evaluation team, workplans for 

2017 and 2019 were not included in the documentation provided to the evaluation team. 

Traction and Impact reports for 2016 and 2018 were also not available.

57 OTA Economic Crimes Team internal document, 2013 End of Project Report: 201301_paraguay_ect_eop.

58 For example, OTA Economic Crimes Team internal document, 2019 Technical Implementation Assessment: 

3054 Paraguay 2019 Crimes TI Assessment
55 Paraguay ECT Final Report

Annex C: Evaluation Data Source Matrix

Evaluation 

Question Research Questions (indicative) Sources of Evidence Research Method

1. To what 

extent has 

the ECT 

achieved the 

four project 

objectives as 

defined in 

the Paraguay 

workplans? 

In which 

areas was the 

ECT the 

most 

successful?

Asked for each project objective:

1.1 Increase the efficiency and 

effectiveness of the FIU analytical 

function and the capacity of the FIU to 

deliver improved and sufficient 

analytical products to law enforcement, 

as confirmed by end users, including as 

reflected by an increase in moneylaundering investigations supported by 

FIU referrals.

1.2 AML/CFT supervision of financial 

and/or non-financial sector(s)—mentor 

AML/CFT examinations with the goal 

of creating refined supervisory manuals, 

improved coordination between the 

CBP and FIU, and examination action 

plan and schedule.

1.3 AML/CFT case development, 

including working with investigative, 

prosecutorial, and/or judicial authority. 

The objective is to create a financial 

crimes task force that meets regularly, 

develops a case-tracking mechanism, 

and an operations manual.

1.4 Develop asset forfeiture and 

recovery program that reflects 

international best practices.

OTA documents

OTA Advisors and 

Associate Directors

AML/CFT 

GAFILAT MER

SEPRELAD

CBP

PM

SET

Customs Authority

Congress

U.S. Embassy

USAID, Paraguay

IMF, Paraguay

Document 

review

Results 

mapping

KIIs

Network 

mapping
56 Paraguay ECT Final Report

2. Which of 

the ECT’s 

project 

objectives in 

Paraguay 

have been 

sustained over 

time and 

why?

How did each of the ECT’s program 

objectives and activities 

(influence/guide/shape) the 

development of Paraguay’s overall 

AML/CFT system?

Did staff turnover at SEPRELAD 

impact the sustainability of the ECT’s 

TA outcomes? 

How do the ECT’s counterparts 

describe the future of their (AML/CFT 

system or FIU) (e.g., 1 year/3 years)?

How willing are counterparts to 

implement program objectives/reforms 

suggested by the ECT?

OTA documents

OTA Advisors and 

Associate Directors

AML/CFT 

GAFILAT MER

SEPRELAD

CBP

PM

SET

Customs Authority

Congress

U.S. Embassy in 

Paraguay

USAID, Paraguay

IMF, Paraguay

Document 

review

Results 

mapping

KIIs

Network 

mapping
57 Paraguay ECT Final Report

3. Which of 

the ECT’s 

program 

objectives 

were not 

achieved and 

why?

What gaps in the AML/CFT system

remain unaddressed?

How do counterparts and constituents

understand and describe their role in the 

Paraguayan AML/CFT system? 

How do counterparts describe the 

challenges to improving Paraguay’s 

AML/CFT system?

OTA documents

OTA Advisors and 

Associate Directors

AML/CFT 

GAFILAT Mutual 

Assessment

SEPRELAD

CBP

Public Ministry

SET

Customs Authority

Congress

U.S. Embassy

USAID, Paraguay

IMF, Paraguay

Document 

review

Results 

mapping

KIIs

Network 

mapping

AML/CFT: anti-money laundering and 

countering the financing of terrorism

CBP: Central Bank of Paraguay

ECT: Economic Crimes Team

FIU: Financial Intelligence Unit

GAFILAT: Latin American Financial Action 

Task Force

IMF: International Monetary Fund

KII: key informant interview

OTA: Office of Technical Assistance

SEPRELAD: Secretariat for the Prevention of 

Money or Property Laundering

SET: Undersecretary of State for Taxation

USAID: United States Agency for 

International Development
58 Paraguay ECT Final Report

Annex D: Connecting ECT Activities to GAFILAT Determinations

Project Objective/Evaluation Team 

Findings/Conclusions

GAFILAT Determination

Project objective 1: Increasing the 

effectiveness of SEPRELAD’s analysis 

and reporting 

The ECT provided training in targeted 

areas, such as indicators used for detecting 

and investigating suspicious activity, 

remittances, and offshore transactions, and 

worked with SEPRELAD analysts to help 

them develop their analytical skills. 

SEPRELAD’s reports to the PM have 

improved, although there is room for 

further improvement.

SEPRELAD produces financial intelligence 

reports that are the product of the analysis of the 

information it receives from reporting entities 

and of the value added provided by its access to 

a wide range of sources of information. The 

financial intelligence produced also contributes 

to the working groups established for the 

investigation of emblematic cases by the 

Attorney General’s Office.

(MER, page 9)

Project objective 2: Strengthening the 

AML/CFT supervision of financial and 

non-financial sectors

While OTA’s participation in this area was 

limited due to the involvement of the IMF, 

OTA Advisors did foster improved 

communication between SEPRELAD and 

CBP and provided mentoring to CBP 

examiners.

The GAFILAT MER rated Paraguay “largely 

compliant” with FATF Recommendation 26 

(Regulation and supervision of financial 

institutions), “compliant” with FATF 

Recommendation 27 (Powers of Supervisors) 

and “largely compliant” with FATF 

Recommendation 28 (Regulation and 

supervision of DNFBPs).

(MER, pages 289–94)

Project objective 3: Improving AML/CFT 

case development and create a financial 

crimes task force59

The ECT facilitated the creation of the 

FCWG that convened regularly when OTA 

SEPRELAD prepares the financial intelligence 

reports as a result from the analysis of the 

information received from the reporting entities 

and adds value by having access to a wide range 

of sources of information enables SEPRELAD. 

SEPRELAD’s financial intelligence also 

59 Originally called the financial crimes task force, the name was changed in 2016 to emphasize that the group 

would take on issues that could be solved by TA, and not be operationally focused.
59 Paraguay ECT Final Report

Project Objective/Evaluation Team 

Findings/Conclusions

GAFILAT Determination

was present in the country. However, the 

overall effectiveness of the FCWG on 

AML/CFT case development is not clear. 

Meetings have been irregular since the end 

of the project. 

contributes to the working groups created for the 

investigation of emblematic cases by the 

Attorney General’s Office.

(MER, page 69)

Project objective 4: Developing an asset 

forfeiture and recovery program

While this project objective could not be 

completely fulfilled due to the inadequacy 

of the legal framework during the project, 

OTA Advisors did help to get SENABICO 

“up and running.” OTA’s assistance on 

legal reform helped lay the foundation for 

the current, more robust legal framework 

in this area.

In general, the legal system in place is 

appropriate to combat money laundering. 

(MER, page 6)

Confiscation in Paraguay is pursued as “the 

enactment of the special procedure for 

confiscation, special confiscation, deprivation of 

benefits and profits, and non-conviction-based 

confiscation,” as well as the creation by law of 

the SENABICO and the amendment of the 

criminal code, which readjusts the scope of the 

legal concept of substitute asset confiscation. 

Likewise, it is possible to observe the 

willingness of the authorities to apply 

confiscation measures.

(MER, page 45).

Paraguay has an adequate legal and institutional 

framework to support criminal proceedings to 

seize and confiscate assets and the proceeds of 

crime.

(MER, page 78)

Paraguay has set the prosecution and 

confiscation of the assets derived from criminal 

activities as a priority of its criminal policy, as 

well as proceeds, profits, and property of 

equivalent value. 

(MER, page 78)

Confiscation of the proceeds of crime, proceeds, 

instrumentalities and property of equivalent 

value is pursued as a government objective, 

which can be appreciated by i) a solid legal and 

institutional framework; ii) being set as a 

priority in Paraguay’s Strategic Plan; iii) the 
60 Paraguay ECT Final Report

Project Objective/Evaluation Team 

Findings/Conclusions

GAFILAT Determination

results of confiscations in specific cases; and iv) 

SENABICO’s administration of the seized 

assets, with a view to their eventual confiscation.

(MER, pages 78–79)

Annex E: Key Informant Interview Instruments 

Qualitative Interview Guide—OTA Staff Version 1

Introduction (to be read to interview subject)

The evaluation of OTA/Paraguay’s program will serve two purposes: The first purpose is to 

ensure compliance with the Foreign Aid Transparency and Accountability Act (FATAA) of 

2016, which includes requirements to evaluate the outcomes and impacts of OTA’s programs 

whose dollar value equals or exceeds the median program size and apply the findings and 

conclusions of such evaluations to proposed project and program design. The second purpose is 

to provide OTA with in-depth, third-party, retrospective insights of its economic crimes activities 

in Paraguay. Some aspects of OTA’s experience may be used to inform other current or future 

projects in Paraguay or other countries to inform adaptation, improve projects, discover ways to 

reduce the time to achieve project outcomes, identify new ways to effect positive change, and 

document project achievements and success.

Informed Consent

We anticipate the discussion to take 60–90 minutes. We will be asking you a series of questions 

on your work in Paraguay. Your participation in this discussion is voluntary and you are free to 

not respond to some questions or discontinue with the discussion at any point. We also request 

your consent to record the interview to ensure that our notes and transcripts are complete and 

accurate. At any time, you may request that you not be quoted, or your interview responses be off 

the record and not included in the interview notes or transcripts. The interview recordings, notes,

and transcriptions will not be shared with OTA or others outside the evaluation team and will be 

deleted after the evaluation report is complete. If you have understood these points and consent to 

continue the discussion, can you please state, “Yes, I consent to be interviewed and recorded.” 

Evaluation Questions (for reference use by interviewers during interview)
61 Paraguay ECT Final Report

1) To what extent has the Economic Crimes Team achieved the four project objectives as defined 

in the Paraguay Work Plans? In which areas was the ECT the most successful?

1.1 Increase the efficiency and effectiveness of the FIU’s analytical function and the 

capacity of the FIU to deliver improved and sufficient analytical products to law 

enforcement, as confirmed by end users, including as reflected by an increase in moneylaundering investigations supported by FIU referrals.

1.2 AML/CFT supervision of financial and/or non-financial sector(s)—mentor 

AML/CFT examinations with the goal of creating refined supervisory manuals, improved 

coordination between the Central Bank and FIU, and examination action plan and 

schedule.

1.3 AML/CFT case development, including working with investigative, prosecutorial, 

and/or judicial authority. The objective is to create a financial crimes task force that 

meets regularly, develops a case-tracking mechanism, and an operations manual.

1.4 Develop an asset forfeiture and recovery program that reflects international best 

practices.

2) Which of the ECT’s project objectives in Paraguay have been sustained over time and why?

3) Which of the ECT’s program objectives were not achieved and why?

Interview Questions

Program Role:

1) Can you tell us about your role in Paraguay? 

1)

2) How were the project activities chosen and planned? How did your counterparts participate in the 

decision-making and planning processes?

2)

3) What were your expectations at the beginning of the project? How did they change over time? How do 

you think your expectations and assumptions compare to counterparts' expectations and assumptions?

3)
62 Paraguay ECT Final Report

Results:

4) What were some of the key results and successes from the ECT’s work? 

4)

5) Did you observe improvements in the effectiveness of the FIU and their analytical capacity? 

5)

6) What were your activities with SEPRELAD examiners? What changes did you observe with them over 

time with their knowledge, processes, or behaviors?

6)

7) Which strategies were used to develop the Financial Crimes Task Force (FCTF)? What were the results?

7)

8) What was the effect of the operations manual developed for the FCWG?

8)

9) Do you think the counterparts’ big picture perception of the AML/CFT system has changed since the 

beginning of the program? 

9)

10)In your opinion, did you see an improvement in authorities' understanding of asset forfeiture?

10)

11) Are there other activities or areas that the evaluation team should focus on that we haven’t asked about?

11)

Stakeholder Relationships:

12) How have the roles of the FIU and other AML constituents changed since the beginning of the program? 

12)

13)Can you describe the relationship and communication between SEPRELAD and the CBP? Did it change 

over time? 
63 Paraguay ECT Final Report

13)

Challenges Encountered:

14)What have been some key challenges that you have encountered?

14)

15)Which activities were particularly difficult to implement?

15)

16)What have been the main operational challenges to asset forfeiture or seizure?

16)

17)In your opinions, what are the gaps in the Paraguayan AML/CFT system that remain unaddressed?

17)

18)What are the main impediments for the project objectives to be sustained over time?

18)

19) Do you have anything else that you would like the evaluation team to know?

19)
64 Paraguay ECT Final Report

Qualitative Interview Guide—OTA Staff Version 2

Introduction (to be read to interview subject)

The evaluation of OTA/Paraguay’s program will serve two purposes: The first purpose is to 

ensure compliance with the Foreign Aid Transparency and Accountability Act (FATAA) of 

2016, which includes requirements to evaluate the outcomes and impacts of OTA’s programs 

whose dollar value equals or exceeds the median program size and apply the findings and 

conclusions of such evaluations to proposed project and program design. The second purpose is 

to provide OTA with in-depth, third-party, retrospective insights of its economic crimes activities 

in Paraguay. Some aspects of OTA’s experience may be used to inform other current or future 

projects in Paraguay or other countries to inform adaptation, improve projects, discover ways to 

reduce the time to achieve project outcomes, identify new ways to effect positive change, and 

document project achievements and success.

Informed Consent

We anticipate the discussion to take 60–90 minutes. We will be asking you a series of questions 

on your work in Paraguay. Your participation in this discussion is voluntary and you are free to 

not respond to some questions or discontinue with the discussion at any point. We also request

your consent to record the interview to ensure that our notes and transcripts are complete and 

accurate. At any time, you may request that you not be quoted, or your interview responses be off 

the record and not included in the interview notes or transcripts. The interview recordings, notes 

and transcriptions will not be shared with OTA or others outside the evaluation team and will be 

deleted after the evaluation report is complete. If you have understood these points and consent to 

continue the discussion, can you please state, “Yes, I consent to be interviewed and recorded.” 

Evaluation Questions (for reference use by interviewers during interview)

1. To what extent has OTA's Economic Crimes Team achieved the four project objectives as 

defined in the Paraguay Work Plans? In which areas was the ECT the most successful?

1.1 Increase the efficiency and effectiveness of the FIU’s analytical function and the 

capacity of the FIU to deliver improved and sufficient analytical products to law 

enforcement, as confirmed by end users, including as reflected by an increase in moneylaundering investigations supported by FIU referrals.

1.2 AML/CFT supervision of financial and/or non-financial sector(s)—mentor 

AML/CFT examinations with the goal of creating refined supervisory manuals, improved 

coordination between the Central Bank and FIU, and examination action plan and 

schedule.
65 Paraguay ECT Final Report

1.3 AML/CFT case development, including working with investigative, prosecutorial, 

and/or judicial authority. The objective is to create a financial crimes task force that 

meets regularly, develops a case-tracking mechanism, and an operations manual.

1.4 Develop an asset forfeiture and recovery program that reflects international best 

practices.

2. Which of the ECT’s project objectives in Paraguay have been sustained over time and why?

3. Which of the ECT’s program objectives were not achieved and why?

Interview Questions

Program Role:

1) Can you tell us about your role in Paraguay? 

2) How were the project activities chosen and planned? How did your counterparts participate in the 

decision-making and planning processes?

•

3) What were your expectations at the beginning of the project? How did they change over time? How do 

you think your expectations and assumptions compare to counterparts' expectations and assumptions?

•

Results:

4) What were some of the key results and successes from the ECT’s work? 

•

5) Did you observe improvements in the effectiveness of the FIU and their analytical capacity? 
66 Paraguay ECT Final Report

6) What were your activities with SEPRELAD examiners? What changes did you observe with them over 

time with their knowledge, processes, or behaviors? 

6A) How would you characterize the relationship between SEPRELAD and the Public Prosecutor’s office? 

In your opinion, do SEPRELAD’s reports provide the Public Prosecutors with sufficient information from 

which to build a case? Do you have any insights as to the Public Prosecutors’ views as to the quality of 

SEPRELAD’s reports/the sufficiency of information provided by SEPRELAD? Are you aware of any 

criticisms by the Public Prosecutors of SEPRELAD’s reports? In your opinion, are these criticisms valid? If 

so, how can they be addressed?

7) Which strategies were used to develop the Financial Crimes Task Force (FCTF)? What were the results?

8) What was the effect of the operations manual developed for the FCWG?

9) Do you think the counterparts’ big picture perception of the AML/CFT system has changed since the 

beginning of the program? 

•

10)In your opinion, did you see an improvement in authorities' understanding of asset forfeiture?

10A) One of the Project’s objectives is to “Develop an asset forfeiture and recovery program that reflects 

international best practices.” Through previous interviews, we have been told that most of OTA’s work 

focused on asset management, rather than asset forfeiture. Can you tell us whether that is actually the case, 

and if so, are you aware of the reason for placing more emphasis on asset management rather than asset 

forfeiture?

11) Are there other activities or areas that the evaluation team should focus on that we haven’t asked about?

Stakeholder Relationships:

12) How have the roles of the FIU and other AML constituents changed since the beginning of the program? 
67 Paraguay ECT Final Report

13)Can you describe the relationship and communication between SEPRELAD and the CBP? Did it change 

over time? 

Challenges Encountered:

14)What have been some key challenges that you have encountered?

15)Which activities were particularly difficult to implement?

16)What have been the main operational challenges to asset forfeiture or seizure?

17)In your opinion, what are the gaps in the Paraguayan AML/CFT system that remain unaddressed?

•

18)What are the main impediments for the project objectives to be sustained over time?

18A) Your reports emphasize that corruption is a huge problem, which can impede the effectiveness of 

Paraguay’s AML/CFT system. From a “30,000-foot view,” how can OTA address this problem?

•

19) Do you have anything else that you would like the evaluation team to know?
68 Paraguay ECT Final Report

Qualitative Interview Guide—OTA ECT Counterpart Version 1

Introducción (para ser leída al entrevistado)

El propósito de la evaluación del programa de OTA/Paraguay es proporcionar a OTA información 

retrospectiva, profunda y de terceros sobre sus actividades de delitos económicos en Paraguay. 

Algunos aspectos de la experiencia de OTA en Paraguay pueden usarse para informar otros 

proyectos actuales o futuros en Paraguay u otros países para informar la adaptación, mejorar 

proyectos, descubrir formas de reducir el tiempo para lograr los resultados del proyecto, identificar 

nuevas formas de efectuar cambios positivos y documentar los logros y el éxito del proyecto.

Consentimiento informado

Anticipamos que la discusión tomará entre 60 y 90 minutos. Le estaremos haciendo una serie de 

preguntas sobre su trabajo en [SEPRELAD/SENABICO/SET/CBP]. Su participación en esta 

discusión es voluntaria y es libre de no responder a algunas preguntas o interrumpir la discusión 

en cualquier momento. También solicitamos su consentimiento para grabar la entrevista para 

garantizar que nuestras notas y transcripciones estén completas y precisas. En cualquier momento, 

puede solicitar que no se le mencione, o que sus respuestas a la entrevista sean extraoficiales y no 

se incluyan en las notas o transcripciones de la entrevista. Las grabaciones, notas y transcripciones 

de las entrevistas no se compartirán con la OTA ni con otras personas ajenas al equipo de 

evaluación y se eliminarán una vez que se complete el informe de evaluación. Si ha entendido 

estos puntos y acepta continuar con la discusión, ¿puede decir: “Sí, doy mi consentimiento para 

ser entrevistado y grabado.”

Evaluation Questions (for reference use by interviewers during interview)

1. To what extent has OTA’s Economic Crimes Team achieved the four project objectives as 

defined in the Paraguay Work Plans? In which areas was the ECT the most successful?

1.1 Increase the efficiency and effectiveness of the FIU’s analytical function and the 

capacity of the FIU to deliver improved and sufficient analytical products to law 

enforcement, as confirmed by end users, including as reflected by an increase in moneylaundering investigations supported by FIU referrals.

1.2 AML/CFT supervision of financial and/or non-financial sector(s)—mentor 

AML/CFT examinations with the goal of creating refined supervisory manuals, improved 

coordination between the Central Bank and FIU, and examination action plan and 

schedule.

1.3 AML/CFT case development, including working with investigative, prosecutorial, 

and/or judicial authority. The objective is to create a financial crimes task force that 

meets regularly, develops a case-tracking mechanism, and an operations manual.
69 Paraguay ECT Final Report

1.4 Develop an asset forfeiture and recovery program that reflects international best 

practices.

2. Which of the ECT’s project objectives in Paraguay have been sustained over time and why?

3. Which of the ECT’s program objectives were not achieved and why?

Interview Questions

Program Role:

1)Can you tell us about your role in [SEPRELAD/SENABICO/SET/CBP]? 

1)

2) How were the project activities chosen and planned? How did your institution/group participate in the 

decision-making and planning processes?

2)

3)What were your expectations at the beginning of the project? How did they change over time? How do 

you think your expectations and assumptions compare to OTA’s expectations and assumptions?

3)

Results:

4)In your opinion, what have been some of the key results and successes since the beginning of OTA’s 

assistance? 

4)

5) Did you observe improvements in the operational effectiveness of SEPRELAD? 

5)

6)What were your activities with the ECT? What changes did you observe over time at your institution with 

respect to knowledge, processes, or behaviors?

6)

7) What can you tell me about the FCWG? What was the impact of the FCWG? 

7)
70 Paraguay ECT Final Report

8) How was the operations manual developed for the FCWG? How important was the operations manual for 

your work?

8)

9) Do you think your institution’s big-picture perception of the AML/CFT system has changed since the 

beginning of the project with the ECT? Why or why not?

9)

10)In your opinion, did you see an improvement in your institution as a result of the outcomes of project 

objectives 1.1–1.4?

10)

11) Are there other activities or areas that the evaluation team should focus on that we haven’t asked about?

11)

Stakeholder Relationships:

12) How has the relationship between your institution and SEPRELAD changed since the beginning of the 

ECT project in 2015? Has your role in your institution changed? Has the role of your institution changed? 

12)

Challenges Encountered:

13)What have been some key challenges that you have encountered? Which activities were particularly 

challenging?

13)

14)What was the main operational challenges of implementing project objectives 1.1–1.4?

14)

15)What have been the main (operational, legal, political, other) challenges to improving the AML/CFT 

system in Paraguay?

15)

16)In your opinion, what are the gaps in the Paraguayan AML/CFT system that remain unaddressed? How 

could the AML/CFT system in Paraguay be improved?
71 Paraguay ECT Final Report

16)

17)What are the main impediments for the outcomes of the ECT’s work to be sustained over time? What do 

you think could be the effect of a government change next year?

17)

18) Do you have anything else that you would like the evaluation team to know?

18)
72 Paraguay ECT Final Report

Qualitative Interview Guide—OTA ECT Counterpart Spanish Version 1

Introducción (para ser leída al entrevistado)

El propósito de la evaluación del programa de OTA/Paraguay es proporcionar a OTA información 

retrospectiva, profunda y de terceros sobre sus actividades contra delitos económicos en Paraguay. 

Algunos aspectos de la experiencia de OTA en Paraguay pueden usarse en otros proyectos actuales 

o futuros en Paraguay u otros países para informar la adaptación, mejorar proyectos, descubrir 

formas de reducir el tiempo para lograr los resultados del proyecto, identificar nuevas formas de 

efectuar cambios positivos y documentar los logros y el éxito del proyecto.

Consentimiento informado

Anticipamos que la discusión tomará entre 60 y 90 minutos. Le estaremos haciendo una serie de 

preguntas sobre su trabajo en [SEPRELAD/SENABICO/SET/CBP]. Su participación en esta 

discusión es voluntaria y es libre de no responder a algunas preguntas o interrumpir la discusión 

en cualquier momento. También solicitamos su consentimiento para grabar la entrevista para 

garantizar que nuestras notas y transcripciones estén completas y precisas. En cualquier momento, 

puede solicitar que no se le mencione, o que sus respuestas a la entrevista sean extraoficiales y no 

se incluyan en las notas o transcripciones de la entrevista. Las grabaciones, notas y transcripciones 

de las entrevistas no se compartirán con la OTA ni con otras personas ajenas al equipo de 

evaluación y se eliminarán una vez que se complete el informe de evaluación. Si ha entendido 

estos puntos y acepta continuar con la discusión, ¿puede decir: "Sí, doy mi consentimiento para 

ser entrevistado y grabado."

Evaluation Questions (for reference use by interviewers during interview)

1. To what extent has OTA's Economic Crimes Team achieved the four project objectives as 

defined in the Paraguay Work Plans? In which areas was the ECT the most successful?

1.1 Increase the efficiency and effectiveness of the FIU’s analytical function and the 

capacity of the FIU to deliver improved and sufficient analytical products to law 

enforcement, as confirmed by end users, including as reflected by an increase in moneylaundering investigations supported by FIU referrals.

1.2 AML/CFT supervision of financial and/or non-financial sector(s)—mentor 

AML/CFT examinations with the goal of creating refined supervisory manuals, improved 

coordination between the Central Bank and FIU, and examination action plan and 

schedule.

1.3 AML/CFT case development, including working with investigative, prosecutorial, 

and/or judicial authority. The objective is to create a financial crimes task force that 

meets regularly, develops a case-tracking mechanism, and an operations manual.
73 Paraguay ECT Final Report

1.4 Develop an asset forfeiture and recovery program that reflects international best 

practices.

2. Which of the ECT’s project objectives in Paraguay have been sustained over time and why?

3. Which of the ECT’s program objectives were not achieved and why?

Interview Questions

1. Role: ¿Cuál fue su rol / trabajo entre 2015–2019?

2) Planeación: Hubo un proceso de planeación con la OTA para definir las actividades 

del Proyecto? La entidad para la que trabajaba / trabaja participó en el proceso de 

planeación del proyecto? 

3) Expectativas del proyecto: ¿Cuáles eran sus expectativas al principio del Proyecto? 

Estas expectativas cambiaron con el tiempo?

4) Resultados: ¿Cuáles fueron los principales resultados positivos de la asistencia de 

OTA?

5) Mejoría: ¿Notó que la entidad se fortaleció gracias al apoyo de la OTA? 

6) Actividades: ¿Qué actividades desarrolló con el equipo de la OTA? ¿Qué cambios 

notó dentro de su institución con respecto al conocimiento, procesos e impacto?

7) Grupo de trabajo contra crímenes financieros: ¿Tiene conocimiento de la 

existencia de este grupo de trabajo? Participó en él? Qué nos puede contar al 

respecto? Cuál ha sido su el impacto? 

8) Manual del GTCF: ¿Se desarrolló un manual para el grupo de trabajo? ¿Cuán 

importante ha sido el manual para su trabajo? 
74 Paraguay ECT Final Report

9) Entendimiento general del Sistema ALA/CFT: Considera que el entendimiento de 

su institución del Sistema ALA/CFT como un todo cambió desde el inicio del 

proyecto? Considera que el apoyo de la OTA contribuyó para ese cambio?

10) Mejoría específica: Notó que su institución se fortaleció en: 

1.1 El fortalecimiento de la inteligencia financiera, 

1.2 Regulación y supervisión ALA/CFT, 

1.3 Desarrollo de casos de LA, 

1.4 Proceso para identificar, incautar y comiso de bienes? (Ley 6431)

a.

11) Otras áreas: En su opinión, ¿existen otras áreas donde este equipo de evaluación se 

debe enfocar y que no estamos preguntando? 

12) Stakeholder Relationships:

13) Relación entre entidades: Considera que la relación entre la SEPRELAD y otras 

entidades cambió desde el inicio del proyecto? Algo de este cambio puede ser 

atribuible al proyecto de la OTA?

14) Retos: ¿Cuáles cree que son han sido los retos para la implementación del proyecto? 

Qué áreas o actividades considera que han sido un reto para implementar o trabajar?

15) Retos operativos: ¿Cuáles fueron los retos operativos principales para: 

 1.1 El fortalecimiento de la inteligencia financiera, 

 1.2 Regulación y supervisión ALA/CFT, 

 1.3 Desarrollo de casos de LA, 

 1.4 Proceso para identificar, incautar y comiso de bienes? (Ley 6431)

 
75 Paraguay ECT Final Report

16) Principales retos para el Sistema: ¿Cuáles considera que son los principales retos 

para el fortalecimiento del sistema ALA/CFT de Paraguay? 

a.

17) Debilidades por fortalecer en el Sistema ALA/CFT: ¿Cuáles son las principales 

debilidad que tiene el Sistema ALA/CFT de Paraguay? ¿Cómo se puede fortalecer?

a.

18) Obstáculos para la sostenibilidad: ¿Considera que los resultados del proyecto de la 

OTA siguen vigentes? ¿Cuáles son los principales obstáculos para que los resultados 

del Proyecto de la OTA se mantengan en el tiempo? ¿Cuál podría ser el impacto del 

cambio de gobierno del año que viene? 

a.

19) Hay algo más que le gustaría contarnos? 
76 Paraguay ECT Final Report

Qualitative Interview Guide—OTA ECT Counterpart Spanish Version 2

Introducción (para ser leída al entrevistado)

El propósito de la evaluación del programa de OTA/Paraguay es proporcionar a OTA información 

retrospectiva, profunda y de terceros sobre sus actividades contra delitos económicos en Paraguay. 

Algunos aspectos de la experiencia de OTA en Paraguay pueden usarse en otros proyectos actuales 

o futuros en Paraguay u otros países para informar la adaptación, mejorar proyectos, descubrir 

formas de reducir el tiempo para lograr los resultados del proyecto, identificar nuevas formas de 

efectuar cambios positivos y documentar los logros y el éxito del proyecto.

Consentimiento informado

Anticipamos que la discusión tomará entre 60 y 90 minutos. Le estaremos haciendo una serie de 

preguntas sobre su trabajo en [SEPRELAD/SENABICO/SET/CBP]. Su participación en esta 

discusión es voluntaria y es libre de no responder a algunas preguntas o interrumpir la discusión 

en cualquier momento. También solicitamos su consentimiento para grabar la entrevista para 

garantizar que nuestras notas y transcripciones estén completas y precisas. En cualquier momento, 

puede solicitar que no se le mencione, o que sus respuestas a la entrevista sean extraoficiales y no 

se incluyan en las notas o transcripciones de la entrevista. Las grabaciones, notas y transcripciones 

de las entrevistas no se compartirán con la OTA ni con otras personas ajenas al equipo de 

evaluación y se eliminarán una vez que se complete el informe de evaluación. Si ha entendido 

estos puntos y acepta continuar con la discusión, ¿puede decir: "Sí, doy mi consentimiento para 

ser entrevistado y grabado."

Evaluation Questions (for reference use by interviewers during interview)

1. To what extent has OTA's Economic Crimes Team achieved the four project objectives as 

defined in the Paraguay Work Plans? In which areas was the ECT the most successful?

1.1 Increase the efficiency and effectiveness of the FIU’s analytical function and the 

capacity of the FIU to deliver improved and sufficient analytical products to law 

enforcement, as confirmed by end users, including as reflected by an increase in moneylaundering investigations supported by FIU referrals.

1.2 AML/CFT supervision of financial and/or non-financial sector(s)—mentor 

AML/CFT examinations with the goal of creating refined supervisory manuals, improved 

coordination between the Central Bank and FIU, and examination action plan and 

schedule.

1.3 AML/CFT case development, including working with investigative, prosecutorial, 

and/or judicial authority. The objective is to create a financial crimes task force that 

meets regularly, develops a case-tracking mechanism, and an operations manual.
77 Paraguay ECT Final Report

1.4 Develop an asset forfeiture and recovery program that reflects international best 

practices.

2. Which of the ECT’s project objectives in Paraguay have been sustained over time and why?

3. Which of the ECT’s program objectives were not achieved and why?

Interview Questions

Role: ¿Cuál fue su rol / trabajo entre 2015–2019?

1)

Planeación: Hubo un proceso de planeación con la OTA para definir las actividades del Proyecto? La 

entidad para la que trabajaba / trabaja participó en el proceso de planeación del proyecto? 

2)

Planeación 2: Conoce si hubo un proceso de planeación con otras contrapartes para definir actividades 

relacionadas con el MP o con SENABICO?

3)

Expectativas del proyecto: ¿Cuáles eran sus expectativas al principio del Proyecto? Estas expectativas 

cambiaron con el tiempo?

4)

Resultados: ¿Cuáles fueron los principales resultados positivos de la asistencia de OTA?

5)

Mejoría: ¿Notó que la entidad se fortaleció gracias al apoyo de la OTA? 

6)

Actividades: ¿Qué actividades desarrolló con el equipo de la OTA? ¿Qué cambios notó dentro de su 

institución con respecto al conocimiento, procesos e impacto?

7)

Grupo de trabajo contra crímenes financieros: ¿Tiene conocimiento de la existencia de este grupo de 

trabajo? Participó en él? Qué nos puede contar al respecto? Cuál ha sido su el impacto? 

8)
78 Paraguay ECT Final Report

Manual del GTCF: ¿Se desarrolló un manual para el grupo de trabajo? ¿Cuán importante ha sido el manual 

para su trabajo? 

9)

Entendimiento general del Sistema ALA/CFT: Considera que el entendimiento de su institución del 

Sistema ALA/CFT como un todo cambió desde el inicio del proyecto? Considera que el apoyo de la OTA 

contribuyó para ese cambio?

10)

Mejoría específica: Notó que su institución se fortaleció en: 

1. El fortalecimiento de la inteligencia financiera, 

2. Regulación y supervisión ALA/CFT, 

3. Desarrollo de casos de LA, 

4. Proceso para identificar, incautar y comiso de bienes? (Ley 6431)

11)

Otras áreas: En su opinión, ¿existen otras áreas donde este equipo de evaluación se debe enfocar y que no 

estamos preguntando? 

12)

Stakeholder Relationships:

Relación entre entidades: Considera que la relación entre la SEPRELAD y otras entidades cambió desde el 

inicio del proyecto? Algo de este cambio puede ser atribuible al proyecto de la OTA?

13)

Retos: ¿Cuáles cree que son han sido los retos para la implementación del proyecto? Qué áreas o actividades 

considera que han sido un reto para implementar o trabajar?

Retos operativos: ¿Cuáles fueron los retos operativos principales para: 

1. El fortalecimiento de la inteligencia financiera, 

2. Regulación y supervisión ALA/CFT, 
79 Paraguay ECT Final Report

3. Desarrollo de casos de LA, 

4. Proceso para identificar, incautar y comiso de bienes? (Ley 6431)

Principales retos para el Sistema: ¿Cuáles considera que son los principales retos para el fortalecimiento 

del sistema ALA/CFT de Paraguay? 

14)

Debilidades por fortalecer en el Sistema ALA/CFT: ¿Cuáles son las principales debilidad que tiene el 

Sistema ALA/CFT de Paraguay? ¿Cómo se puede fortalecer?

15)

Obstáculos para la sostenibilidad: ¿Considera que los resultados del proyecto de la OTA siguen vigentes? 

¿Cuáles son los principales obstáculos para que los resultados del Proyecto de la OTA se mantengan en el 

tiempo? ¿Cuál podría ser el impacto del cambio de gobierno del año que viene? 

16)

Hay algo más que le gustaría contarnos? 

17)
80 Paraguay ECT Final Report

Annex F: GAFILAT Evaluation

Post-project development: The 2021 GAFILAT Mutual Evaluation

Paraguay underwent a mutual evaluation by the GAFILAT during 2021, which included an onsite visit from August 23 to September 3, 2021. According to the previous (2008) mutual 

evaluation carried out by the IMF in accordance with the 2004 Financial Action Task Force 

(FATF) methodology, Paraguay had been rated “compliant” in two of the FATF 

recommendations, “largely compliant” in two, “partially compliant” in 14, “non-compliant” in 

30, and one recommendation was classified as “not applicable.” Paraguay was not rated 

“compliant” or “largely compliant” in any of the 16 core and key recommendations. Based on 

the aforementioned mutual evaluation, the FATF placed Paraguay on an enhanced follow-up 

process (the “grey list”). FATF removed this status in April 2018 after it concluded that 

Paraguay had undertaken measures to correct the deficiencies identified in the core and key 

recommendations of the 2008 MER.

In the 2021 Mutual Evaluation Report (MER), GAFILAT rated Paraguay as “compliant” in 18 

FATF recommendations, “largely compliant” in 19, “partially compliant” in two, and one

recommendation was classified as “not applicable.” Paraguay was not found to be “noncompliant” with any of the recommendations.60

The 2021 MER found that Paraguay's anti-money laundering and countering the financing of 

terrorism (AML/CFT) system has improved significantly since its last evaluation. There is a 

more robust legal and institutional framework to fight against ML/TF and proliferation 

financing. In terms of effectiveness, the 2021 MER found Paraguay has reached a “moderate” 

level, although major improvements are still needed in all areas of the AML/CFT system, and 

fundamental improvements are needed regarding money-laundering investigation, prosecution, 

and convictions. With these results, Paraguay did not fall under FATF’s monitoring, and 

therefore has no risk of being included in the “grey list.”

GAFILAT Evaluation

Paraguay is a member of the Financial Action Task Force of Latin-America, better known as 

GAFILAT for its acronym in Spanish. GAFILAT is a regionally based intergovernmental 

organization that brings together 17 countries from South, Central, and North America.

GAFILAT members have endorsed the 40 FATF recommendations aiming to prevent and 

combat money laundering, the financing of terrorism, and the financing of the proliferation of 

weapons of mass destruction, through a commitment to the continuous improvement 

60 GAFILAT. Paraguay ́s Mutual Evaluation Report. https://www.gafilat.org/index.php/es/noticias/180-informe-deevaluacion-mutua-de-la-republica-de-paraguay 
81 Paraguay ECT Final Report

strengthening of the various mechanisms of cooperation among member countries. GAFILAT 

supports its members in the implementation of the 40 recommendations and in the creation of a 

regional system to prevent money laundering and terrorist financing, through the development of 

guides, reports, and supporting documents. GAFILAT mutual evaluations follow the FATF’s 

assessment methodology.61

Along with the FATF, the FATF-style regional bodies (FSRB) — including GAFILAT, the IMF,

and the World Bank — are the entities with the mandate to develop FATF-styled assessments. 

There are nine FSRBs that cover different regions of the world. When a country is found with 

major weaknesses on its AML/CFT system and does not reach a minimum threshold as 

determined by the mutual evaluation, then FATF begins a close monitoring that could lead to a 

public listing. 

61 GAFILAT. What is GAFILAT? https://www.gafilat.org/index.php/es/espanol/18-inicio/gafilat/157-what-is-gafilat3
82 Paraguay ECT Final Report

Annex G: Respondent List

TO BE REDACTED BEFORE PUBLISHING

Meeting Respondent Name

Redacted

Name 

Redacted

Position Institution Date

1 1 Advisor ECT OTA 10/25/22

2 2 Rule of Law 

Advisor

USAID 11/2/22

3 Public 

Administration 

Specialist

USAID 11/2/22

3 4 Former 

Director 

General of 

Rules and 

Supervision

SEPRELAD 

(Financial 

Intelligence 

Unit)

11/2/22

4 5 Intendente CBP 11/3/22

5 6 Minister 

SENABICO

SENABICO 11/3/22

7 Legal Affairs 

General 

Director 

SENABICO

SENABICO 11/3/22

8 General 

Secretary, 

SENABICO

SENABICO 11/3/22

6 9 Political 

Officer

U.S. Embassy 11/3/22

7 10 Chief of Large 

Taxpayers 

Audit 

Department 

Tax Authority

SET 11/4/22

11 Coordinator de 

Tax 

Investigations 

Tax Authority

SET 11/4/22
83 Paraguay ECT Final Report

12 Vice Minister 

SET

SET 11/4/22

8 13 Congress 

Member

Paraguayan 

Chamber of 

Deputies

11/7/22

9 14 International 

Affairs Director

SEPRELAD 

(Financial 

Intelligence 

Unit)

11/8/22

15 Regulations 

Director

SEPRELAD 

(Financial 

Intelligence 

Unit)

11/8/22

16 Viceminister SEPRELAD 

(Financial 

Intelligence 

Unit)

11/8/22

17 Director 

General 

Financial 

Analysis

SEPRELAD 

(Financial 

Intelligence 

Unit)

11/8/22

10 18 Prosecutor 

Economic 

Crimes and 

Corruption

Public 

Ministry 

(Attorney 

General)

11/8/22

11 19 Attorney 

General

Public 

Ministry 

11/8/22

12 20 Former 

Minister

SEPRELAD 

(Financial 

Intelligence 

Unit)

11/10/22

13 21 Customs 

Authority 

Coordinator of 

Administrative 

Investigations

Custom 11/10/22

14 22 Intendente CBP 11/11/22
84 Paraguay ECT Final Report

23 Team Leader CBP 11/11/22

24 Member of the 

Board

CBP 11/11/22

15 25 Advisor ECT OTA 11/11/22

16 26 Former

Interinstitutional 

Relationships 

Director

SEPRELAD 

(Financial 

Intelligence 

Unit)

12/21/22

CBP: Central Bank of Paraguay

ECT: Economic Crimes Team

OTA: Office of Technical Assistance

SENABICO: National Secretariat for the Administration of Seized and Confiscated Assets

SEPRELAD: Secretariat for the Prevention of Money or Property Laundering

SET: Undersecretary of State for Taxation

USAID: United States Agency for International Development