Misuse of AML/CFT Tools as a Mechanism of Economic Pressure: A Structural Risk Assessment for Latin America

Published
February 20, 2026
Author
Khrabrykh S. A.
Original language
English

This report provides a comprehensive study of the risks arising from the use of Anti-Money Laundering and Counter-Terrorist Financing tools as levers of economic and political pressure. It analyzes the specific context of the Latin American region, where the intersection of global compliance standards and local political factors creates unique vulnerabilities for the financial system.

The study focuses on destructive patterns in the use of compliance procedures. In an era of total banking automation, even unverified risk signals or adverse media mentions can trigger an escalation mechanism leading to account freezes and de-banking. This creates a defensive compliance effect, where financial institutions prefer to terminate client relationships at the slightest suspicion to avoid regulatory penalties.

The report examines in detail the secondary effects of such abuses: the deterioration of the investment climate, restricted access to banking services, and long-term reputational damage. A significant portion of the work is dedicated to safeguards. The author proposes the implementation of structural checklists for verifying risk sources and strengthening regional expertise to distinguish genuine criminal threats from instances of artificial pressure.

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