GAFI - Second Enhanced Follow Up Report and Second Technical Compliance Re-Rating Report of Bolivia de 2025

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Second Enhanced Follow Up Report and Second Technical Compliance Re-Rating Report of Bolivia

August 20252

This Report was adopted by the LI GAFILAT Plenary Meeting, held in San Salvador, El Salvador, con July 31st, 2025.

Citing reference:

GAFILAT (2025) – Second Enhanced Follow Up Report and First Technical Compliance ReRating Report of Bolivia.

© 2025 GAFILAT. All rights reserved. No reproduction or translation of this publication may be made without prior written permission. Applications for such permission, for all or part of this publication, should be made to the GAFILAT Secretariat at the following address: Avenida del Libertador 218, 10th floor - - C1001ABP - Buenos Aires – Telephone (+54-11) 5252-9292; e-mail: contacto@gafilat.org.

Cover photo: Salar de UyuniFirst Enhanced Follow Up Report and First Technical Compliance Re-Rating Report of Bolivia

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BOLIVIA: ENHANCED FOLLOW UP REPORT – RE-RATING REPORT

I. INTRODUCTION

1. In accordance with GAFILAT’s Fourth Round procedures, Bolivia’s Mutual Evaluation Report (MER) was adopted in December 2023. Bolivia also submitted a first enhanced follow -up and technical compliance re-rating report in December 2024, in which Recommendati ons 6, 13, 22, 23, and 28 were re -rated. This follow-up report analyses Bolivia’s progress in addressing the technical compliance deficiencies identified in its MER, as well as any new deficiencies since the first technical compliance re -rating report in D ecember 2024. New ratings are granted when sufficient progress is observed. Overall, the expectation is that countries have addressed most, if

technical compliance deficiencies identified in its MER, as well as any new deficiencies since the first technical compliance re -rating report in D ecember 2024. New ratings are granted when sufficient progress is observed. Overall, the expectation is that countries have addressed most, if not all, technical compliance deficiencies before the end of the third year since the adoption of their MER. This report does not address Bolivia’s progress in improving its effectiveness.

II. FINDINGS OF THE MUTUAL EVALUATION REPORT

2. In relation to Technical Compliance, the MER and subsequent re -qualifications indicate

that Bolivia was rated as follows:

Table 1. Technical Compliance Ratings, December 2024

R.1 R.2 R.3 R.4 R.5 R.6 R.7 R.8 R.9 R.10

LC C LC C LC LC PC PC C LC

R.11 R.12 R.13 R.14 R.15 R.16 R.17 R.18 R.19 R.20

C C LC C PC LC C LC LC LC

R.21 R.22 R.23 R.24 R.25 R.26 R.27 R.28 R.29 R.30

PC C LC PC C LC C C C C

R.31 R.32 R.33 R.34 R.35 R.36 R.37 R.38 R.39 R.40

PC LC C LC PC LC LC LC LC LC

Note: There are four possible levels of technical compliance: Compliant (C), Largely Compliant (LC), Partially Compliant (PC) and Non-Compliant (NC).

Sources: i) Mutual Evaluation Report of Bolivia: https://biblioteca.gafilat.org/wpcontent/uploads/2024/07/IEM-Bolivia.pdf

3. Considering the results reflected in the MER, GAFILAT placed Bolivia under the enhanced follow-up process. 1 The GAFILAT Plenary of Representatives previously approved this second request for re-rating based on the initial re-rating submission and the country’s reported progress.

3. Considering the results reflected in the MER, GAFILAT placed Bolivia under the enhanced follow-up process. 1 The GAFILAT Plenary of Representatives previously approved this second request for re-rating based on the initial re-rating submission and the country’s reported progress.

The formal request was submitted with the necessary supporting documentation within the set deadline.

4. Based on the above, and in accordance with current GAFILAT procedures, a group of evaluators from the GAFILAT Expert Group (GEG) pool was appointed to carry out the analysis and prepare this report. María Paz Arriagada Ramírez (Head of Dissemination and St udies, Financial Analysis Unit, Chile) and Enzo Paolo Paredes Castañeda (Liaison and Cooperation

1 The regular follow-up is the default monitoring mechanism for all countries. The enhanced follow-up process is based on the FATF traditional policy that approaches members with significant (technical compliance or effectiveness) deficiencies in their AML/CFT systems, and it involves a more intensive monitoring process.First Enhanced Follow Up Report and First Technical Compliance Re-Rating Report of Bolivia

2 Coordinator, Prevention, Liaison, and Cooperation Department, Financial Intelligence Unit, Superintendence of Banking, Insurance, and Pension Fund Administrators, Peru) carried out the assessment. Juan Cruz Ponce, Deputy Executive Secretary of GAFILAT; Diana Lucía Yon Véliz and Guillermo Alejandro Hernández, Technical Experts of the GAFILAT Secretariat; and Mónica Ayala de Paz, an Expert attached to the Executive Secretariat of GAFILAT for El Salvador, coordinated and supported the process.

5. Section III of this report summarises the progress made by Bolivia in improving technical compliance with Recommendations 7, 24 and 35, which are the subject of this re -rating report.

Section IV presents the conclusion and a table showing which Recommendations were re-rated.

III. OVERVIEW OF THE PROGRESS MADE TO IMPROVE TECHNICAL COMPLIANCE

compliance with Recommendations 7, 24 and 35, which are the subject of this re -rating report. Section IV presents the conclusion and a table showing which Recommendations were re-rated.

III. OVERVIEW OF THE PROGRESS MADE TO IMPROVE TECHNICAL COMPLIANCE

6. This section summarises Bolivia’s progress in improving its technical compliance by addressing the technical compliance deficiencies identified in the MER.

3.1. Progress in addressing technical compliance deficiencies identified in the MER

7. Bolivia has made progress in addressing its technical compliance deficiencies identified in the MER in relation to the following Recommendations: • Recommendation 7, currently rated PC; upgraded to C; • Recommendation 24, currently rated PC; upgraded to LC, and; • Recommendation 35, currently rated PC, upgraded to LC.

Recommendation 7 – Targeted financial sanctions related to proliferation (rated PCUpgraded to C)

Criterion 7.1

1. Analysis:

8. The 2023 MER identified a deficiency in this criterion: the regulatory framework does not directly correspond to it because it does not refer to any of the UNSCRs related to suppressing and disrupting the proliferation of weapons of mass destruction and th eir financing. It was also noted that the relevant instruction was not enforceable against all REs due to scope deficiencies relating to DNFBPs. Some sectors applied only to large taxpayers, and the precious metals and stones trading sector was excluded.

9. Based on the legal grounds that empower the Financial Intelligence Unit (FIU), the unit approved the Regulations on Supplementary Procedures for the Implementation of Measures Derived from UNSC Resolutions Related to the Financing of the Proliferation of Weapons of Mass Destruction (FPWMD) through an Administrative Resolution dated January 24th, 2025

(UIF/7/2025). According to article 3 of the AR, any existing, successor, or future UNSCR that calls for the implementation of targeted financial sanctions related to PF falls within its scope. Since no reference is made to specific resolutions, the provision is considered broad enough to cover

(UIF/7/2025). According to article 3 of the AR, any existing, successor, or future UNSCR that calls for the implementation of targeted financial sanctions related to PF falls within its scope. Since no reference is made to specific resolutions, the provision is considered broad enough to cover potential changes to the sanctions regimes, including the addition of new individuals, entities, or countries. Similarly , article 6 refers directly to the regime established based on UNSCR 1718 (2006) and its successors. This makes it clear that the regime covered by the FATF standards — which includes the Democratic People’s Republic of Korea’s (North Korea’s) weapons of mas s destruction (WMD) development program—falls within the scope of the Regulation’s provisions.First Enhanced Follow Up Report and First Technical Compliance Re-Rating Report of Bolivia

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10. Regarding the scope deficiencies indicated for non -financial reporting entities, Administrative Resolution UIF/78/2023 dated December 6th, 2023, has already remedied them by eliminating the restriction on large taxpayers for sectors that have already been incorporated.

Administrative Resolution UIF/29/2024 incorporates the precious metals and stones trading sector as a reporting entity and appoints SENARECOM as the supervisor for this purpose. For more information, please see the analysis of Recommendations 22, 23, and 28 in the First Technical Compliance Re -Rating Report of the Plurinational State of Bolivia. The analysis considers the deficiencies addressed and re-rates the aforementioned Recommendations as C, LC, and C, respectively.

1. Conclusion:

11. Bolivia has made significant progress by establishing specific supplementary regulations on targeted financial sanctions related to PF. These regulations are general in scope. Similarly, addressing the scope deficiency, eliminating restrictions on “large t axpayers,” and including the precious metals and stones sector effectively makes these provisions applicable to all reporting entities required by criterion 7.1.

12. On the basis of the above, criterion 7.1 is met.

Criterion 7.2

precious metals and stones sector effectively makes these provisions applicable to all reporting entities required by criterion 7.1.

12. On the basis of the above, criterion 7.1 is met.

Criterion 7.2

13. The 2023 MER determined that the obligation referenced in criterion 7.2 did not apply to all entities designated by the standard as reporting entities.

1. Analysis:

a)

14. According to the FIU Regulations relating to PF, approved by the AR (UIF/7/2025), all natural or legal persons are required to apply TFSs relating to PF, regardless of their status as REs.

This is outlined in subsection A of article 5, which states that the FIU has the authority to require all citizens, natural persons, and legal entities to freeze funds or other assets without delay or notification to natural persons or legal entities designated by the UNSC.

15. Furthermore, to ensure the entire population is aware of this obligation, article 15 stipulates updates to the lists be disseminated through a national media outlet 2. The outlet must provide hyperlinks to the lists and reiterate the prohibition of providing funds or other assets to or for the benefit of designated persons or entities. Based on the above, as well as the expanded scope of the REs analysed, it can be concluded that the prohibition applies to all natural and legal persons in the country.

16. Therefore, these measures are considered to meet the sub -criterion requirement. Thus, the requirement is met.

2 The FIU Regulations and the notices updating the consolidated lists are published on the FIU website. As of July 2025, the FIU website contained the Regulations at the link https://www.uif.gob.bo/otros -relacionados/; with regard to the communications through which the FIU transmits the freezing obligation, these can be found in the “Communications” section, available at the following link: https://www.uif.gob.bo/comunicados-8797/. The Guide can be found at the link

communications through which the FIU transmits the freezing obligation, these can be found in the “Communications” section, available at the following link: https://www.uif.gob.bo/comunicados-8797/. The Guide can be found at the link https://www.uif.gob.bo/guias-1/.First Enhanced Follow Up Report and First Technical Compliance Re-Rating Report of Bolivia

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17. Considering the analysis of the MER and the definition of the term “funds or other assets” in article 4 of the aforementioned FIU Regulation, as well as the scope of application of article 5 of the Regulation, the sub-criterion requirements are met.

c)

18. As analysed in criterion 7.1, the obligation not to make funds or other assets available to designated persons or entities applies to all citizens, natural persons and legal entities within the country, as set out in paragraph c) of article 5. Similarly, s ubsection C) of article 5 of the FIU Regulation on TFSs related to PF contains a provision with wording that is practically identical to that of the standard. In accordance with the above, the sub-criterion is met.

d)

19. Based on the analysis conducted in the MER, it can be concluded that this sub -criterion’s requirements are met.

e)

20. All entities are informed in paragraph 3 of the notices announcing updates to the sanctions regimes and changes to the United Nations’ consolidated list that ‘if it is identified that a natural or legal person or entity designated on the lists attempts to carry out any act, operation or service, the described prohibition must be applied without delay and this fact must be reported to the Financial Investigation Unit’. In accordance with paragraph 4 of the aforementioned notices, failure to comply with these provisions may result in punishment in accordance with current regulations.

21. To promote compliance with these provisions, Administrative Resolution UIF/5/2025, approved on 21 January 2025, established a Guidance for the Implementation of Targeted

failure to comply with these provisions may result in punishment in accordance with current regulations.

21. To promote compliance with these provisions, Administrative Resolution UIF/5/2025, approved on 21 January 2025, established a Guidance for the Implementation of Targeted Financial Sanctions under United Nations Security Council Resolutions. This Guidance outlines the legal basis, obligations, and procedures to be followed. With regards to UNSCR related to TF and PF. Furthermore, Chapter II, Section B, Paragraph 5 of the Guide sets out the obligation to report any freezing carried out using the designated fo rm and email address, as well as any attempted transactions. Based on the above, the requirements have been fulfilled, and the sub-criterion has been met.

f)

22. Under the terms of the Regulations for the Implementation of the UNSCRs on PF, article 5, paragraph f, the country shall implement measures to protect the rights of third parties acting in good faith when complying with the regulations’ provisions. In this sense, the sub-criterion is met.

1. Conclusion:

23. Analysis of the sub-criteria that make up criterion 7.2 shows that most of the deficiencies listed in the MER have been fully addressed. It is therefore concluded that criterion 7.2 has been met.

Criterion 7.3

24. The 2023 MER identified that the country does not include the purchase and sale of precious metals and stones in its AML/CTF/CPF system. It also highlighted the limitations referredFirst Enhanced Follow Up Report and First Technical Compliance Re-Rating Report of Bolivia

5 to in R.15 and R.22 concerning VASPs, lawyers, accountants, and real estate agents, respectively. The country was also advised to strengthen its legal framework in line with Criterion 7.1 (paragraph III of article 495 of Law 393; paragraph I of articles 24 and 25 of Supreme Decree 4904; and paragraph II of article 12 of FIU Instruction 26/2023).

1. Analysis:

(paragraph III of article 495 of Law 393; paragraph I of articles 24 and 25 of Supreme Decree 4904; and paragraph II of article 12 of FIU Instruction 26/2023).

1. Analysis:

25. As mentioned above, in response to the scope deficiency relating to the REs, which only covered ‘large taxpayers’ and excluded traders in precious stones and metals, the restriction on large taxpayers has been removed for the already incorporated sectors, and the precious metals and stones trading sector has been incorporated as a reporting entity.

26. Similarly, Criterion 7.1, which relates to the effective implementation of TFS linked to PF, the approval and issuance of TFS Regulations and the PF Guide, and the inclusion of provisions related to sanctions applicable under Art. 160 of the Criminal Code “Disobedience to Authority”, consisting of 30 10 100 days in fine.

27. With regard to supervisory actions for all sectors, subsection cc) of Article 25 of Supreme Decree No. 4904 indicates that failure to comply with the measures established by the FIU constitutes an administrative sanction. Likewise, Paragraph II of Article 12 of the “Specific Instructions for Obligated Entities in the Application of United Nations Security Council Resolutions” and Article 10 of the “Regulations on Complementary Procedures for the Implementation of Measures Derived from UNSC Resolutions Related to the FPADM of the FIU” establish complementary provisions in this regard.

28. In addition to the above, the various supervisors with jurisdiction over AML/CFT updated their specific guidelines and manuals to incorporate the SFD provisions on PF, as follows:

• On June 27, 2024, the ASFI updated its Risk Supervision Guidelines to establish supervisory tasks in areas including monitoring to verify that clients and/or users of the OSs under its supervision have registered in the UNSC listing system, as well as the implementation of procedures for the application of SFDs for registered entities. • On November 5, 2024, the APS approved the update of its Supervision Manual for

the OSs under its supervision have registered in the UNSC listing system, as well as the implementation of procedures for the application of SFDs for registered entities. • On November 5, 2024, the APS approved the update of its Supervision Manual for insurance entities, which establishes the procedures for conducting off -site and onsite supervision and monitoring of regulated entities. Likewise, the Insurance Sector Sanctions Regulations, as amended on December 31, 2024, establish that failure to comply with the measures established by the FIU, as set forth in Article 25 of Supreme Decree No. 4904, constitutes an administrative offense punishable under Articles 11 and 12 thereof. • On October 31, 2024, the AJ approved the Procedure Manual for Verifying Compliance with Targeted Financial Sanctions, which states that if conduct is detected that may constitute the offenses established in Article 25 of Supreme Decree No. 4904, the respective sanctioning process will be initiated. • On December 8, 2023, the AEMP approved six technical documents aimed at implementing the EBR in the supervision of APNFDs; likewise, on May 17, 2024, the AEMP prepared the “Informative Guide on the LGI/FT/FPADM Sanctioning Regime.” • The Sole Additional Provision of the Regulations on Preventive Freezing in the Fight Against TF and PF establishes that the DIRNOPLU will supervise compliance with freezing and unfreezing measures, within the framework of current regulations, for the notary public sector.First Enhanced Follow Up Report and First Technical Compliance Re-Rating Report of Bolivia

6 • SENARECOM developed the Regulations on Preventive Freezing and Unfreezing within the framework of ML/TF/PF, which aims to effectively implement legal provisions and strengthen supervision. With regard to the sanctions established for non-compliance, these will be imposed in accordance with the provisions of Law No. 2341 on Administrative Procedure and its regulations, or the SENARECOM Regulations on Infractions and Penalties, approved by Board Resolution No. 001 of

provisions and strengthen supervision. With regard to the sanctions established for non-compliance, these will be imposed in accordance with the provisions of Law No. 2341 on Administrative Procedure and its regulations, or the SENARECOM Regulations on Infractions and Penalties, approved by Board Resolution No. 001 of January 24, 2025.

29. Based on the foregoing, provisions have been issued that allow the various authorities to impose sanctions on SO, as well as on citizens, natural persons, and legal entities that are not SO, for non-compliance with TFS obligations under PF.

1. Conclusion:

30. The criterion is considered to be met by addressing the scope deficiencies regarding DNFBPs and establishing sector-specific provisions.

Criterion 7.4

31. The MER 2023 identified a lack of procedures relating to criterion 7.4 as a shortcoming.

1. Analysis

a)

32. Article 13 of the FIU Regulations on TFS for PF establishes that the criterion for CODELIN to propose the removal of a person or entity listed in the sanctions regime of UNSCR 1718 (2006) and its successor resolutions is that they no longer meet the origin al designation criteria.

Verification of this shall be carried out and, by means of a Technical Report, CODELIN shall propose that the person or entity concerned be removed, either through CODELIN or directly via the United Nations focal point. Similarly, Section II establishes that the requirements and procedures for cases of removal from the lists due to homonymy are indicated on the website. These requirements and procedures have been verified as being disseminated in the same terms as indicated in the regulatory framework. The analysis shows that the sub-criterion is met.

b)

33. In accordance with article 7 of the FIU Regulations for TFS for PF, if it is verified that the designation affects a person or entity other than the one subject to sanctions due to homonymy, CODELIN must analyse the request. If corroborated, CODELIN must t hen recommend the

b)

33. In accordance with article 7 of the FIU Regulations for TFS for PF, if it is verified that the designation affects a person or entity other than the one subject to sanctions due to homonymy, CODELIN must analyse the request. If corroborated, CODELIN must t hen recommend the issuance of an Administrative Resolution for the purposes of unfreezing, which must be ratified by the judicial authority.

34. Similarly, Chapter XI of the FIU Guidance on TFS for PF sets out a procedure for REs to follow, stating that the relevant person or entity may communicate with the FIU via the form provided on its website. Once contact has been established, the FIU will li aise with the relevant person or entity to verify the homonym case. Once the measure has been confirmed, the authority that determined the freezing measure shall order its lifting. The FIU shall then notify the REs, public entities and public registries of this. The REs must inform the FIU of the lifting of measures via the communication channel designated for this purpose. As this meets the requirements, the sub-criterion is also met.First Enhanced Follow Up Report and First Technical Compliance Re-Rating Report of Bolivia

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35. In accordance with the MER, judges determining the measure may grant access to funds and other assets to cover basic or extraordinary expenses. In this sense, the sub-criterion is met.

d)

36. In accordance with the MER, Inst. UIF/26/2023 establishes that the FIU shall notify the SO of the RA ordering the unfreezing of funds or other assets through the established mechanisms, when a person or entity has been removed from the UNSC lists. The esta blished procedure indicates that the notification shall be made expeditiously and that regulated SO shall implement it immediately. In this regard, the subcriterion is met.

1. Conclusion:

37. The country has made significant progress in addressing the remaining deficiencies identified in the MER relating to the homonym procedure, as well as cases where the criteria for

implement it immediately. In this regard, the subcriterion is met.

1. Conclusion:

37. The country has made significant progress in addressing the remaining deficiencies identified in the MER relating to the homonym procedure, as well as cases where the criteria for designating a person or entity are no longer met. The FIU Regulations set out the procedures for analysing cases of homonymy and other situations in which sanctions should be lifted. Considering the above criterion 7.4. is met.

Criterion 7.5

38. According to the analysis carried out in the 2023 MER, the provisions relating to TFS for PF are unclear as to whether they cover all types of pre-existing obligations or only those arising from the conclusion of a contract. They also make no specific mention of interest or other earnings due in respect of accounts frozen pursuant to UNSCR 1718 or 2231.

1. Analysis:

a)

39. According to the Compilation of Rules for Financial Services, issued by the Financial System Supervisory Authority, any funds withheld by order of a competent administrative authority, such as the Financial Investigation Unit (FIU) will affect the balance on the date and time at which the supervised entity receives the instruction, as well as any subsequent deposits.

In this regard, the provision covers the requirement for interests or other benefits to be included, which will remain frozen. In this sense, the sub-criterion is met.

b)

40. As identified in the 2023 MER and based on article 9, which was incorporated into Supreme Decree 1553 via Supreme Decree 4906, the sub -criteria requirements have been met.

Therefore, the sub-criterion is met.

1. Conclusion:

41. The Expert Team considers that the information provided by Bolivia regarding criterion 7.5a addresses the remaining concerns about including interest income from frozen bank accounts in accordance with the standard. This improves the weighting of criterion 7.5. Therefore, criterion

1. Conclusion:

41. The Expert Team considers that the information provided by Bolivia regarding criterion 7.5a addresses the remaining concerns about including interest income from frozen bank accounts in accordance with the standard. This improves the weighting of criterion 7.5. Therefore, criterion 7.5 is deemed to have been met.First Enhanced Follow Up Report and First Technical Compliance Re-Rating Report of Bolivia

8 General conclusion on Recommendation 7

42. Since adopting the MER, Bolivia has made significant progress. The FIU approved the Regulations on Supplementary Procedures for the Implementation of Measures Derived from UNSC Resolutions Related to the Financing of the Proliferation of Weapons of Mass Destruction

(FPWMD) through an Administrative Resolution dated January 2025 (UIF/7/2025). This resolution indicates that any existing, successor, or future UNSCR that calls for the implementation of targeted financial sanctions related to PF falls within its scope. In these terms, Bolivia has the legal framework that allows it to implement SFD to comply with the UNSCR, which is reinforced by updates to the various provisions, manuals, and instructions of the supervisory bodies, including SENARECOM, for the recently incorporated precious stones and metals sector, which include provisions related to monitoring and sanctions for non -compliance with TFS obligations. This represents significant progress in addressing the deficiencies identified in the MER.

43. The country also provided information on the provision that allows deposits to be made to accounts held by administrative authorities that will remain frozen. Therefore, re -rating Recommendation 7 as Compliant is proposed.

Recommendation 24 – Transparency and beneficial ownership of legal persons (rated PC – Upgraded to LC)

Criterion 24.1

1. Analysis:

44. The 2023 MER noted that the term “legal persons” was not covered in accordance with the international legal standard and its glossary. However, by stating in the MER that it does not consider sole proprietorships to be covered by the term “legal person” in the international

1. Analysis:

44. The 2023 MER noted that the term “legal persons” was not covered in accordance with the international legal standard and its glossary. However, by stating in the MER that it does not consider sole proprietorships to be covered by the term “legal person” in the international standard on the subject and its glossary, the AT is not identifying a deficiency, but rather clarifying that these companies are not to be considered as legal persons, as they are natural persons with a business. It should also be noted that Step 46 ‘Operational changes’ of the Business Register Procedures Guidance clearly sets out how beneficial ownership information is to be obtained.

45. The First Follow -up Report with Technical Compliance Re -rating (TCR) concluded that there were no remaining deficiencies. No changes have been identified since the previous report.

1. Conclusion:

46. Accordingly, criterion 24.1 is deemed to have been met.

Criterion 24.2

1. Analysis:

47. In both the 2023 MER and the TCR report, the criterion was considered to have been mostly met. However, the deficiencies identified in the criterion linked to risk analysis wereFirst Enhanced Follow Up Report and First Technical Compliance Re-Rating Report of Bolivia

9 maintained. This is because the risks associated with corporations and limited partnerships by shares are not fully considered, even when they are of lesser materiality.

48. In January 2025, the FIU issued Technical Report INFORME/UIF/DAES/UAEC/7/2025.

This report approved the Sectoral Risk Study on Legal Structures, which covered trusts. This addressed one of the deficiencies identified in the MER.

49. By contrast, the update to the Terrorist Financing SRA considered corporations and limited partnerships that issue bearer shares for analysis. To identify the associated risks of corporations and limited partnerships that issue bearer shares, the national -level participation percentage of both companies was considered, which in the case of SAs represented 1.1% and in the case of

partnerships that issue bearer shares for analysis. To identify the associated risks of corporations and limited partnerships that issue bearer shares, the national -level participation percentage of both companies was considered, which in the case of SAs represented 1.1% and in the case of SCAs represented 0.001%, figures that indicate low participation with respect to the b