Javier Coronado, associate attorney at Diaz, Reus & Targ, LLP: “In 2019, Colombia recorded a higher money laundering (ML) risk rating because the Basel Anti-Money Laundering (AML) Index is now following a methodology that points to longstanding gaps that Colombia has in the effective implementation of an AML framework. Specifically, the Financial Action Task Force (FATF) Mutual Evaluation Reports, a key indicator in the Basel AML Index, now emphasize the effectiveness of AML systems and not only technical compliance with the 40 FATF recommendations.