Work Report 2024-2025 of the Superintendency of Banks

Memoria
2024-2025
WORK REPORT of the Superintendency of Banks Solidity and Legacy

2 Superintendency of Banks
SUPERINTENDENCY OF BANKS
Promote stability and confidence in the supervised financial system Julio Alfaro

Work Report of the Superintendency of Banks | 2024-2025 3 Dear readers:
I am pleased to present the Work Report of the Superintendency of Banks (SIB), corresponding to the 2024-2025 period. This report reflects the actions, progress, and results achieved by the Institution, as well as its process of modernization and transformation in the supervision of the national financial system. Since October 2022, the Superintendency of Banks has made significant progress in its digital transformation, particularly with the implementation of digital tools and procedures. Furthermore, the adoption of risk-based supervision supported by advanced technologies has strengthened monitoring capabilities. This transition has optimized supervision, resource allocation, regulation, and adaptation to a constantly evolving financial environment. During this period, improvements were recorded in supervision and regulation methods of the financial system. The implementation of the Integrated Supervision Model (MIS) has allowed for a broader view of the risks and challenges faced by supervised entities. Additionally, the institutional structure was consolidated through the creation of new areas, including the Insurance Superintendency, with the purpose of addressing the particularities of the insurance sector, considering the integration between banking and insurance, as well as the composition of national financial groups. In terms of financial inclusion, the National Financial Inclusion Strategy (ENIF) was updated, financial education programs directed at the public were supported, and internal learning platforms were strengthened. These actions contribute to expanding access to and use of financial services by the population. The evolution of the financial system continues to pose new challenges and opportunities for supervision. The incorporation of emerging technologies, the use of artificial intelligence in banking and financial services, the entry of new actors into the ecosystem, changes in global regulations and international standards, as well as greater attention to aspects such as cyber risk, operational resilience, and the inclusion of geopolitical risks integrated into periodic assessments, require PRESENTATION

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Work Report of the Superintendency of Banks 2024-2025 Superintendency of Banks increasingly broad and adaptable supervision. Added to this is the growing level of interconnectivity between financial markets on a national and international scale, which demands a vision oriented toward continuous improvement. In this context, the SIB maintains the development and implementation of solutions in areas such as cybersecurity, data analysis, and artificial intelligence, with the objective of strengthening stability, transparency, and confidence in the supervised financial system. During this administration, the SIB consolidated strategic advances in financial supervision related to the management of liquidity, credit, and solvency risks, as well as the regulation of payment instruments, digital channels, and credit cards. A relevant milestone was reached in the matter of prevention and combat against Money Laundering and Terrorist Financing (ML/TF), by achieving that Guatemala obtained first place in the contest for best success cases of the Financial Action Task Force of Latin America (GAFILAT) with the "Los Delfines" case, and by assuming the Pro Tempore Presidency of the aforementioned body, leading the regional agenda for ML/TF prevention. In this period, the modernization of the regulatory framework was also promoted through Law Initiative 6593, recently approved by the Congress of the Republic of Guatemala, according to Decree Number 15-2026, Integral Law for the Prevention and Repression of Money Laundering or Other Assets and of Terrorist Financing, reinforcing the country's legal and financial system, aligning it with the international standards required at present. Approaching 80 years of history, the SIB continues to adapt to the transformations of the financial environment. Its human resources, the accumulated technical specialization, and the ability to respond to new dynamics of the market, including emerging financial modalities, constitute elements that support the fulfillment of its functions and contribute to the development of the country. I invite you to explore this SIB Work Report 2024-2025, which presents a comprehensive vision of the work performed, the achievements obtained, the challenges faced, and the strategies for the future. Through modernization and commitment to excellence, the Superintendency of Banks will continue to fulfill its mission of promoting stability and confidence in the supervised financial system, for the benefit of all Guatemalans. Sincerely, Saulo De León Durán SUPERINTENDENT OF BANKS

Work Report of the Superintendency of Banks | 2024-2025 5 INDEX PRESENTATION 3 SUPERINTENDENCY OF BANKS: IDENTITY, DIRECTION AND STRATEGY
1.1 Institutional governance and organizational structure 7
1.2 Institutional role and internal strengthening: advances in the digital transformation of human talent management 9
1.3 New institutional vision and roadmap to the future 9
1.4 Our reason for being: institutional mission 9
1.5 Values guiding supervision and public service 10
1.6 Strategic planning: objectives, priorities, and lines of action 11
OVERVIEW OF THE SUPERVISED FINANCIAL SYSTEM: STABILITY AND PERFORMANCE
2.1 Main milestones and achievements in financial supervision 13
2.2 General context of the financial system 15
2.3 Evolution and behavior of the banking system 16
2.4 Institutional strengthening: creation of the Insurance Superintendency 20
2.5 Performance and financial situation of the insurance market 21
RESULTS OF A MODERN RISK-BASED SUPERVISION
3.1 Risk-Based Supervision, Integrated Supervision Model (MIS) 25
3.2 Macroprudential supervision 30
3.3 Consolidated and cross-border supervision 32
3.4 Compliance with international standards 33
3.5 Strengthening of prudential regulations 35
PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING:
RESULTS AND LEADERSHIP
4.1 Regional leadership: Pro Tempore Presidency of GAFILAT and strategic contributions 39
4.2 Monitoring and analysis of financial transactions 41
4.3 Financial intelligence and strategic analysis of information 42
4.4 National Risk Assessment ML/TF: progress and results 43
4.5 Presidential Commission for the Coordination of Efforts Against Money Laundering or Other Assets, the
Terrorist Financing and the Financing of the Proliferation of Weapons of Mass Destruction in Guatemala (COPRECLAFT) 43
4.6 Regulatory framework for the prevention of ML/TF 44
4.7 Strengthening of capacities and specialized training 45
4.8 Supervision and support to Obligated Persons 45
4.9 Cooperation and international participation in ML/TF matters 47
STRATEGIC COMMUNICATION AND FINANCIAL INCLUSION
5.1 Communication strategy: strengthening the link with society and the media 49
5.2 Advances in the National Financial Inclusion Strategy (ENIF) 58
5.3 Promotion of financial education: strengthening economic culture in citizenship 60
5.4 Institutional relations and international cooperation 61
5.5 Financial user attention: statistics and follow-up 64
DIGITAL TRANSFORMATION AND STRENGTHENING OF INSTITUTIONAL CAPACITY
6.1 Advances in digital transformation: innovation and institutional development 69
6.2 Adoption of advanced technologies in data analysis, AI, and cybersecurity 78
6.3 Supervisory efficiency and regulatory modernization 80
6.4 Contribution of innovative technologies to the supervision process 80
6.5 Human talent: capacities, development, and institutional security 81
ANNEXES
7.1 Supervised institutions 87
7.2 Financial groups 88
7.3 Representation offices of foreign banks 89
SOLIDITY AND LEGACY, 80TH ANNIVERSARY OF THE SUPERINTENDENCY OF BANKS 91 1 2 3 4 5 6 7 8

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Work Report of the Superintendency of Banks 2024-2025 Superintendency of Banks INDEX OF GRAPHS Graph 1 Credit portfolio of the banking system 16 Graph 2 Financing to companies. Main year-on-year growths of credit economic activities 17 Graph 3 Financing to households. Consumer and housing credits at December 2025 17 Graph 4 Deposit liabilities of the banking system 18 Graph 5 Integration of deposit liabilities at December 2025 18 Graph 6 Credits obtained from the banking system 18 Graph 7 Profitability in relation to assets 19 Graph 8 Return on equity 19 Graph 9 Main assets of insurance companies 21 Graph 10 Main liabilities of insurance companies 22 Graph 11 Share capital of insurance companies 22 Graph 12 Composition of net premiums 23 Graph 13 Preventive measures required in 2024 and 2025 26 Graph 14 Recommendations of a prudential nature in matters of security in electronic channels 30 Graph 15 Number of Suspicious Transaction Reports received in the IVE 41 Graph 16 Number of complaints, involved parties, and amount reported by the IVE to the MP 42 Graph 17 Number of national legal requirements received in the IVE 42 Graph 18 Number of people trained in ML/TF prevention 45 Graph 19 Number of supervision activities in ML/TF prevention 2024-2025, by segment of Obligated Persons 46 Graph 20 Number of supervision activities in ML/TF prevention 2024-2025, by type of supervision activity and segment of Obligated Persons 46 Graph 21 Number of support activities to Obligated Persons 47 Graph 22 Requests attended by type of medium 51 Graph 23 Attention to media outlets 51 Graph 24 Community on social networks at December 2025 55 Graph 25 Interactions on social networks at December 2025 55 Graph 26 Annual visits to the institutional website 2024-2025 56 Graph 27 Downloads of the institutional mobile application 2024-2025 56 Graph 28 Number of short SMS messages sent during 2024-2025 57 Graph 29 Increase in subscribers 2024-2025 57 Graph 30 Participations by segment 61 INDEX OF TABLES
Table 1 Results and indicators 23
Table 2 Regulations issued by the Monetary Board at
the proposal of the Superintendency of Banks 35
Table 3 Resolutions, agreements, and circular letters
issued by the Superintendency of Banks 37
Table 4 Meetings with audiences 50
Table 5 Requests and management attended in 2025 65
Table 6 Files and user requests for products
and financial services attended in 2024 and 2025 66 INDEX OF ILLUSTRATIONS Illustration 1 Updated philosophical framework of the Superintendency of Banks 10 Illustration 2 Strategic map of the Superintendency of Banks 12 Illustration 3 Supervised financial system 16 Illustration 4 Main financial indicators 19 Illustration 5 Regional banking groups with presence in Guatemala 33 Illustration 6 Action Plan Pro Tempore Presidency of GAFILAT 39 Illustration 7 Evolution of Law Initiative 6593 (Period 2015-2025) 41 Illustration 8 Institutional external communication strategy 49 Illustration 9 Institutional logo 57 Illustration 10 Phases of the project life cycle 71 Illustration 11 Value increment in the Institution 71 Illustration 12 Feasibility and Authorization Phase 72 Illustration 13 Project Team 73 Illustration 14 Integral SIBienestar Plan 82 Illustration 15 Strategic axes 82 Graph 31 Requests and management by entity from January to December 2025 65 Graph 32 Requests and management by product from January to December 2025 66 Graph 33 Requests for economic-financial information and public information (credit history) 66 Graph 34 Users registered in the User Attention Portal 67 Graph 35 Number of credit history queries in the User Attention Portal from January to December 2025 67 Graph 36 Distribution of positions 83 Graph 37 Areas of professionalization 83 Graph 38 Training events 85 Graph 39 Training modalities 85

Work Report of the Superintendency of Banks | 2024-2025 7 SUPERINTENDENCY OF BANKS: IDENTITY, DIRECTION 1 AND STRATEGY The organizational structure of the SIB reflects an institutional evolution oriented toward functional specialization and the cross-articulation of its competencies. The Institution is organized in superintendencies and technical and support dependencies that, in a coordinated manner, strengthen risk-based supervision, the prevention of money laundering and terrorist financing, the modernization of the regulatory framework, digital transformation, and efficient management of institutional resources.
1.1 Institutional governance and
organizational structure
The institutional governance of the Superintendency of Banks (SIB) is based on the constitutional and legal framework that defines its attributes of surveillance and inspection over the supervised entities. In this scope, the strategic direction of the Institution corresponds to the Superintendent of Banks, who guides decision-making and promotes its execution through the specialized functional structure, designed to ensure a technical, coordinated, and timely performance in the face of the dynamics and challenges of the financial environment. LEVEL STRUCTURE Central Office Lic. Saulo De León Durán Superintendent of Banks Superintendencies Lic. Gustavo Adolfo Zepeda Gaitán Banking Supervision Superintendent
Lic. Héctor Antonio Espina Lima
Insurance Superintendent
Lic. Edgar Josué Cruz Hernández
Superintendent of Studies, Regulations, and Resolution of Financial Entities
Lic. Juan Carlos Monroy Véliz
Special Verification Superintendent
Lic. Julio César Gálvez Díaz
Strategic Administration Superintendent

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Work Report of the Superintendency of Banks 2024-2025 Superintendency of Banks General Legal Advisory Lic. Alejandro Pedro Baldizón Montepeque General Legal Advisor Directors Lic. Manuel Ernesto Rodríguez Tuez Department "A" of Banking Risk Supervision
Lic. Mario Roberto Castañeda Vega
Department "B" of Banking Risk Supervision
Lic. Luis Francisco Vallejo García
Department of Specific Risk Supervision
Lic. Ricardo Alvarado del Valle
Macroprudential Supervision Department
Lic. Ariel Esduardo Méndez Girón
Studies Department
Lic. Gustavo Adolfo Rodas Gómez
Banking Regulations Department
Lic. Carlos Federico Toledo Sebastián
Resolution of Financial Entities and Statistics Department
Lic. Mayra Karina Chojolán Prillwitz
Insurance Risk Supervision Department
Lic. Juan Francisco García Mancilla
Insurance Records, Studies, and Regulations Department
Lic. Juan Fernando Argueta Estrada
Prevention and Compliance Department
Lic. Dayle Josué Pitán Guzmán
Financial Transactions Analysis Department Eng. Oscar Gabriel Calvillo Salguero Technology, Analytics, and International Department
Lic. Otto Marlon Santos Hernández
Financial and Services Department
Lic. Guillermo Carlos René Ralón Corzo
Information Technology Department
Eng. Xiomara Noemí Cabrera Aguirre de Anzueto Human Talent Management Department Eng. Miguel Alberto Arriaga Cruz Institutional Development Department

Work Report of the Superintendency of Banks | 2024-2025 9
1.2 Institutional role and internal
strengthening: advances in the digital transformation of human talent management The Superintendency of Banks is committed to the development and well-being of human talent, adopting best practices and new management models. In line with this vision, during 2024-2025, the human talent management model was strengthened, through the consolidation of the Integral SIBienestar Plan, which considers the collaborator as one of the most valuable assets of the SIB. This plan focuses on creating and promoting conditions that optimize performance and productivity throughout the entire lifecycle within the Institution. Parallel to this, actions were promoted oriented toward the digital transformation of the Department of Human Talent Management, through the modernization and systematization of its internal processes, strengthening operational efficiency, information traceability, and timely access to management tools for institutional decision-making. This approach is aligned with international best practices that position the Department of Human Talent Management as a strategic partner for the fulfillment of the mission and institutional vision.
1.3 New institutional vision and roadmap
to the future
During the strategic planning process, the Superintendency of Banks carried out an integral exercise to update its strategic framework and guarantee its validity in the current environment. As a result of this analysis, the institutional mission was confirmed, values were ratified, and the vision was updated, with the purpose of expressing more clearly and challengingly the future aspiration of the Institution. New vision "To be an entity of recognized credibility and prestige at the international level, with personnel of excellence." The new vision reflects an evolution of the institutional philosophical framework, synthesizes the journey traveled and projects the SIB toward a stage of greater positioning, alignment with international standards, and strengthening of human talent as a strategic asset. In this way, the focus is on three key attributes: credibility, prestige, and personnel excellence. The roadmap to the future is articulated around three axes that guide the effective implementation of the institutional strategy. The first consists of the clear and coherent definition of projects, as a basis for orderly, prioritized management aligned with our institutional philosophical framework. The second is the recognition of the organization, which allows comprehensively understanding its structure, capabilities, challenges, and opportunities for improvement. The third emphasizes the strengthening of soft and technical skills, fundamental for consolidating more prepared, collaborative, and results-oriented teams.
1.4 Our reason for being: institutional
mission
Mission
"Promote stability and confidence in the supervised financial system." The institutional mission expresses directly the reason for being of the Superintendency of Banks and summarizes the public sense of its actions. Promoting stability and confidence in the supervised financial system implies exercising surveillance and inspection with a technical focus, independence of criterion, responsibility

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Work Report of the Superintendency of Banks 2024-2025 Superintendency of Banks Source: SIB Strategic Plan 2026-2028. institutional and capacity to adapt to changes in the economic, regulatory, and technological environment. In the review of the philosophical framework for the strategic cycle 2026-2028, the mission was confirmed without modifications, reaffirming its validity as a permanent foundation of the institutional strategy. This continuity reflects that, even in a context of digital transformation, financial innovation, and greater complexity of risks, the essential purpose remains unaltered. Illustration 1 Updated philosophical framework of the Superintendency of Banks
1.5 Values guiding supervision and
public service
Value Description
Service Attitude
Promptly and respectfully attend the requirements of internal and external users. Responsibility Be aware of my obligations and act accordingly, assuming the consequences thereof. Reliability Inspire credibility, confidence, and prestige. Excellence Demonstrate extraordinary personal and professional qualities that evidence the permanent search for improvement in my conduct and work. Honesty Act with sincerity, decency, integrity, justice, and honesty. Loyalty Act with respect and fidelity toward the Institution. reaffirmed as permanent pillars of the institutional work, by recognizing that technical excellence is only sustainable when based on clear principles of service, integrity, and public commitment. The institutional values constitute the cultural basis that guides the conduct of SIB personnel and grant ethical coherence to their decisions, relationships, and processes. In the new strategic cycle they were Mission Vision Values "Promote stability and confidence in the supervised financial system." "To be an entity of recognized credibility and prestige at the international level, with personnel of excellence."

• Responsibility • Service Attitude • Reliability • Honesty • Excellence • Loyalty

Work Report of the Superintendency of Banks | 2024-2025 11 Together, these values guide the way in which the SIB understands supervision, regulation, public service, and the relationship with its groups of interest. They constitute, therefore, the reference that supports the organizational culture and institutional credibility.
1.6 Strategic planning:
objectives, priorities, and lines of action During the biennium 2024-2025, strategic planning institutional maintained continuity with the strategic map in force and, simultaneously, prepared the transition to a new planning cycle 2026-2028. In its preliminary phase, the process was supported by the review of the philosophical framework and strategic results, complemented by a comprehensive analysis of the environment and the active participation of institutional leaders. This approach allowed aligning the strategy with a realistic agenda based on projects. Component Description Institutional Objectives Promote the stability of the supervised financial system and strengthen the prevention, control, surveillance, and sanction of ML/TF. Cross-cutting Priorities Digital transformation and project-based management. Lines of Action Communications and electronic processes with external stakeholders, transformation of management and operations, and optimization of supervision processes, ML/TF prevention, and information. The institutional strategy is articulated around three strategic lines that remain in force and the projects with the greatest impact for the SIB. These lines allow translating the long-term vision into concrete actions of institutional modernization, internal development, and strengthening of the supervisory function. Strategic Line Purpose 1 Communications and electronic processes with external stakeholders The management of communications and electronic processes with external stakeholders constitutes a fundamental task