risk - should be used universally, but the specific weight assigned to each of these components when evaluating global aml / cft risk must be based upon the strategy pursued by each country ’ s regulatory authorities, who best know the domestic market. this includes the periodic review of strategy by the regulator and by each financial institution. although standards are important, no less important is the value of the judgment by those responsible for supervision and control. for instance, what magnitudes are we discussing when analyzing fluctuations in the current account balances or the size of certain transactions? what level of volatility is unusual for a certain type of business or customer? the answer is not the same for turkey, russia or argentina. the risk - based approach, like the spirit of our proposal, tells us that these kinds of assessments require acquiring special expertise on the nature of the business that should also include thorough knowledge of standard domestic market practices. this includes not only regulatory and market issues but also elements such as corporate governance, relations with the community, and the economic, historical and cultural context. as a matter of fact, we would like to reiterate our strong support to work together with the us treasury to make the most out of the cartagena meeting as part of the private sector dialogue initiative. we all know that cash - intensive activities by definition carry a greater associated risk. nevertheless, their treatment should take into account whether the economy is in itself highly dependent on the use of cash, given the historically low penetration by financial services. elements such as these are essential when it comes to adequately allocating risk to a customer or a transaction, and will undoubtedly increase the ability to detect criminal operations efficiently. once financial institutions have detected through their risk analysis processes those transactions or customers showing high levels of risk, they must implement the necessary internal control measures. obviously this type of approach should be supplemented by a smooth and constant flow of appropriate information from the various government entities to the financial system ’ s supervisors regarding those actions that could be linked to terrorist activities. in this instance, the timing of the availability of the relevant information will be essential to be able to act upon, particularly in the case of the fight against terrorism, when the funds used do not necessarily derive from illegal or criminal activities. in our opinion, an approach of this nature has a positive effect on financial stability and minimizes the negative externalities associated with specific issues that can become systemic problems. to sum up, we share the goals and we would like to contribute to

develop their own countercyclical policy so as to overcome periods of limited financial market access, preventing domestic variables from being significantly affected. thanks to these policies, the monetary and financial system in latin america as well as in argentina, despite facing a series of turbulences, has managed to operate within the guidelines set. there have been no bank closures, the institutions have kept their robust liquidity and solvency levels, savers have been able to make the portfolio decisions they have deemed fit, credit has kept growing – though at a slower pace. for the first time in several decades, after patiently working for five years, the central bank of argentina has become a true stability anchor, providing three public goods unprecedented in the country : monetary stability, financial stability and foreign exchange predictability. as regards the institutional impact on growth, the literature does seem to have risen to the occasion. the neo - institutionalist school has come to prominence in the past few decades with the spread of its explanatory power. from the very beginning, its founders have sought to answer a fundamental question – why do some nations achieve self - sustained growth, while others remain economically stagnant? neo - institutionalism highlights the role of the historical background. unlike the neoclassical school, it focuses on a dynamic vision. in my opinion, when we talk about economic institutions, the concept of pyramid comes in very handy, and what better place than the mayan and aztec land to make a reference to it. societies build their institutional arrangements in stages, one after the other, one over the other, each on top of the previous one. to keep progressing with this pyramidal arrangement at the regional level, it is essential to develop financial markets in domestic currency. in this sense, there are several important factors, both at the macroeconomic and microeconomic levels. the microeconomic factors include an increasing dedollarization of the economy and reduced vulnerabilities related to potential sudden stops in capital flows. this is particularly important since currency mismatches have been the basis of the major financial crises among emerging economies. a marked reliance on borrowing in strong currencies makes countries more vulnerable to domestic currency depreciation ( which is strongly tightening ). furthermore, the development of finance markets in local currency is usually associated with improved liability management facilitating risk management. among the microeconomic factors, it is key to develop a yield curve in local currency that reflects the opportunity cost of funds for different terms, leading to more efficient resource allocation