From the Geopolitics of Compliance to Local Reality.
The recent update issued by the Financial Action Task Force (?FATF?) and the global visualization of jurisdictions under increased monitoring offer far more than a technical snapshot of international compliance. They constitute, in essence, a geopolitical map of risk, credibility, and global financial trust.
An analysis of the global distribution of countries included in the so-called ?grey list? reveals a structural phenomenon: international standards on anti-money laundering, counter-terrorist financing, and counter-proliferation financing have become a common language of the international financial system.
Today, full participation in that system is no longer defined exclusively by macroeconomic indicators, but also by the institutional quality of financial integrity frameworks.
The global picture is revealing. The Americas, Europe, and much of Asia show relatively low concentrations of jurisdictions under enhanced monitoring, reflecting decades of investment in regulation, supervision, and compliance infrastructure.
Yet it also reveals persistent asymmetries, particularly in regions where structural challenges ? institutional, economic, and political ? hinder the effective implementation of complex and evolving standards.
This confirms a central premise: compliance is no longer merely regulatory. It is a structural component of international competitiveness.
The Global Standard as an Economic Determinant.
For years, AML/CFT/CPF compliance was perceived as a technical issue confined to regulatory specialists. That view has been definitively surpassed.
Today, alignment with FATF standards has tangible effects on critical economic variables, including:
- access to financial assistance programs from international institutions such as the IMF and World Bank;
- access to correspondent banking relationships;
- cost of international financing;
- sovereign risk perception;
- foreign investment flows;
- integration into global value chains.
Inclusion in enhanced monitoring lists generates immediate reputational and practical consequences for both the country and its citizens. Even absent such designation, markets continuously assess the robustness of each jurisdiction?s preventive framework.
In this context, financial credibility becomes a strategic asset. And like any asset, it can either be strengthened or eroded.
Argentina in the International Context.
For Argentina, this discussion is particularly significant. Historically, the country has experienced cycles in international compliance, alternating between periods of alignment and phases of scrutiny or reassessment by multilateral bodies.
The current global environment requires moving beyond such pendular dynamics. In a financial system where trust is incremental and cumulative, setbacks in integrity frameworks carry disproportionate costs compared to the short-term benefits that may be sought through regulatory flexibility.
Argentina faces a dual challenge: consolidating institutional progress while demonstrating long-term consistency.
Consistency, ultimately, is the most valuable currency in the marketplace of international credibility.
The Local Debate: Economic Incentives vs. International Standards.
In recent months, Argentina?s public debate has incorporated initiatives aimed at stimulating the economy through financial incentives and mechanisms for asset disclosure or mobilization.
Within this context, concepts such as the so-called ?under-the-mattress dollars? have gained prominence in economic and political discourse.
Beyond their specific design, such instruments reflect a recurring tension in emerging economies: how to generate economic incentives without weakening standards of transparency and financial traceability.
This is no minor challenge. Policies designed to expand monetary liquidity or mobilize undeclared savings may be macroeconomically rational in the short term, but they must be carefully evaluated from the perspective of international compliance.
In a hyper-connected world, regulatory signals transcend borders and are interpreted by correspondent banks, multilateral institutions, and institutional investors.
The key lies in balance: designing economic tools that do not compromise the architecture of integrity.
Decree 93/2026 and Regulatory Signaling.
Within this framework, Decree 93/2026 (Official Gazette, January 9, 2026) introduces elements that warrant strategic analysis. Beyond its technical content, the decree must be interpreted as a regulatory signal.
Signals matter. And in AML/CFT/CPF matters, they matter as much as the rules themselves.
Each regulatory change is assessed by international evaluators through a cumulative lens. FATF and regional bodies do not examine isolated statutes or decrees, but rather the systemic coherence of regulatory frameworks and, above all, their effective implementation.
Accordingly, any reform must be calibrated across three dimensions:
- Technical compatibility with international standards;
- Institutional implementation capacity;
- External reputational impact.
Comparative experience shows that jurisdictions capable of sustaining international credibility are those that internalize this multidimensional logic.
Credibility as a Matter of State Policy.
One of the clearest lessons from the global compliance landscape is that financial credibility cannot be built through isolated measures or political cycles. It requires continuity, interinstitutional coordination, and long-term strategic vision.
Jurisdictions that have positioned themselves as credible share several common traits:
- regulatory stability;
- technical autonomy of supervisory authorities;
- sustained international cooperation;
- professionalization of the compliance ecosystem.
Argentina has made progress across several of these fronts at different points in its recent history. Yet the challenge remains to consolidate these gains into a consistent and predictable trajectory.
In a context where the country seeks full reintegration into international markets, financial integrity must be understood as critical infrastructure ? as essential as physical or energy infrastructure.
Analytical Continuity.
This perspective does not arise in isolation. It forms part of a broader analytical framework developed in recent scholarly work published in leading legal journals such as La Ley, Mercojuris, and Infojus, which argue that the evolution of Argentina?s AML/CFT/CPF system must be understood as part of a broader process of structural alignment with global standards.
Within this line of analysis, the author has argued that Argentina?s preventive regulatory architecture has evolved from a reactive construct into a central pillar of its international integration strategy. The key objective is no longer merely passing technical evaluations, but consolidating systemic credibility.
Prior publications ? including those featured on the CASSAGNE Consultores institutional blog ? have explored this thesis from complementary angles.
Analyses of asset regularization programs have emphasized that such processes must balance economic incentives with international expectations, avoiding contradictory external signals.
Similarly, research on AML/CFT as a state policy has underscored that the primary challenge is not normative but institutional: sustaining consistency over time amid economic pressures.
Finally, studies on the evolution of money laundering offenses following the enactment of Law 27,739 have introduced a criminal law dimension, highlighting how the expansion and conceptual refinement of the offense reflects the gradual internalization of international standards into domestic law.
Taken together, these contributions reveal a clear through-line: the evolution of Argentina?s AML/CFT system cannot be understood as a series of isolated reforms, but rather as a process of institutional maturation.
The Historical Cost of Inconsistency.
To fully appreciate the present moment, it is essential to recognize that Argentina?s path toward international credibility has not been linear. Inclusion in the FATF grey list provided profound lessons, both technically and reputationally.
The effects extended well beyond regulatory circles. They included heightened due diligence requirements from correspondent banks, increased compliance costs for domestic entities, and measurable impacts on country risk perceptions from a financial integrity standpoint.
Perhaps most significant, however, was the intangible effect: erosion of trust.
In the international financial system, trust is built slowly and lost quickly.
Exiting that scenario required substantial effort: legal reforms, institutional strengthening, supervisory professionalization, and a cultural shift within the compliance ecosystem.
That process entailed political, economic, and regulatory costs ? but also generated invaluable institutional learning.
From Recovery to the Challenge of Consistency.
Having undergone that experience places Argentina in a unique position within the global compliance landscape. This is not a jurisdiction beginning its alignment journey, but one that has already experienced the consequences of misalignment.
That experience imposes an additional responsibility: avoiding regression.
The present context demands a shift from recovery logic to consolidation logic ? one of the most complex transitions in public policy.
Consolidation requires resisting the temptation to relativize standards in the face of economic urgency. It also requires understanding that each regulatory signal is interpreted within a historical narrative by international stakeholders.
In other words, the past matters. And it conditions present maneuverability.
The Role of the Private Sector.
Alignment with international standards is not the exclusive responsibility of the State. The private sector plays a decisive role in building systemic credibility.
Financial institutions, law firms, real estate developers, fiduciary entities, and other reporting entities serve as the system?s first line of defense. The quality of their compliance programs directly influences international perceptions of the jurisdiction.
In this regard, the risk-based approach acquires strategic relevance. It is no longer merely about formal compliance, but about developing genuine capabilities to identify, mitigate, and manage risk.
Organizations that internalize this logic not only reduce regulatory exposure but also enhance their competitiveness in increasingly demanding markets.
Looking Ahead: Permanent Alignment.
A comprehensive reading of the global landscape leads to a clear conclusion: in financial integrity matters, alignment with international standards is an ongoing process, not a static achievement.
For Argentina, this means recognizing that every economic decision with financial implications must be assessed through the lens of international credibility.
Policies adopted today will shape perceptions in future FATF evaluation cycles and among key actors in the global financial system.
Credibility functions as an accumulative reputational capital: it takes years to build and can erode rapidly.
Conclusion: Credibility as a Strategic Asset.
The latest FATF grey list update ? formalized at the February 2026 plenary held in Mexico ? offers a lesson that transcends technical analysis.
International compliance is no longer peripheral; it is a central determinant of global economic integration.
A global visualization of the updated list reveals an important insight: commitment to preventive standards appears relatively strong across most continents. The Americas, Europe, and much of Asia exhibit low grey-list concentration, reflecting sustained progress in regulatory and supervisory systems, while a significant share of jurisdictions under enhanced monitoring remains concentrated in Africa.
This reality does not necessarily reflect weaker regulatory intent, but often structural constraints related to institutional capacity, economic development, political stability, and technical resources.
From a strategic perspective, the map reinforces a key conclusion: the international prevention standard is now truly global. Compliance is no longer about meeting domestic requirements alone, but about aligning with increasingly demanding international expectations.
For reporting entities, advisors, and regulators, this implies a growing responsibility: strengthening risk-based compliance programs, continuously monitoring FATF developments, and anticipating regulatory evolution.
Argentina stands at a decisive juncture. The need to stimulate growth and mobilize capital ? including initiatives aimed at attracting so-called ?under-the-mattress dollars? ? coexists with the imperative to consolidate integrity standards aligned with global best practices.
Debates surrounding such initiatives, regulatory measures like Decree 93/2026, and future policy decisions must be evaluated not only for their domestic impact, but also for their effect on international credibility.
In a world where trust is the scarcest and most valuable currency, sustained alignment with international standards is not merely a technical obligation ? it is a development strategy.
Maintaining that alignment will be essential for Argentina to be not only competitive, but also credible. And in the international financial order, credibility remains the most decisive asset of all.