Section /Question

RESPONSE BY GUATEMALA

INSTRUCTIONS

It would be advisable to add instructions such as: Tick to activate boxes, and to state what is the character limit for free form text.

INSTRUCTIONS

We suggest to add an instruction requesting to validate that submissions contain no errors, and to generate automatically an e-mail notifying that it has not been answered in full, and that it could not be accepted as valid.

INSTRUCTIONS

It would be advisable to mark which fields are limited to a date or numeric value answer, since this has caused errors in uploading and validating previous ECBs.

INSTRUCTIONS

SHARING CODE: We suggest to add the sharing code after each question for easy reference.

9

TELEPHONE NUMBER: We suggest to allow to enter several phone numbers, and to add a box/field to list the PBX phone extensions or mobile. E-MAIL ADDRESS: We suggest to add a box/field to allow to enter more than one e-mail address.

15.2

Answers for 15.2 and 15.3 are the same, they could be in a table where column A is to answer 15.2 and column B for 15.3. 

16

Define: Custodian wallet providers and Bookmakers. Also, answers to Questions 16 and 17 are the same, they could be comprised in a table, where column A answers Q16, and column B answers Q17.

16.1

Question 16.1 should be in two parts: 1) For a Yes or No answer, and 2) Consider that if thresholds are in place, they may vary among reporting entities; therefore, the box/field should be open for alphanumeric (free form text) answers, and not be limited for a numeric response only.

17

Define: "Custodian wallet providers" and "Bookmakers". Also, answers to Questions 16 and 17 are the same, they could be comprised in a table, where column A answers Q16 and column B answers Q17.

17.1

If thresholds vary between reporting entities, field could be open for free form text and not restrained to a numeric response.

23

In Question 23, add a text field to detail Other types of information.

24

In subsection J.1 add what BNIs stand for. Also, Q24 could be related with Q32. If possible, a box/field could be added to: 1) state if information is available to other FIUs; and 2) record an estimate on days to expect information obtained upon request, as in a previous LWG questionnaire.

32

We agree with Q32, and suggest to comprise it with Q24. If possible, a box/field could be added to: 1) state if information is available to other FIUs; and 2) record an estimate on days to expect information obtained upon request, as in a previous LWG questionnaire.

38

In the previous Census, Section 3 -OPERATIONAL started before question 38. Will this be still the case?  Also, as per R29, Section 3 could be named "OPERATIONAL AND STRATEGIC".

39.4

Answers do not fully correspond to the question. We suggest to eliminate parenthesis or rephrase the question to avoid misinterpretation. Also, it would be useful to add a box to insert links to documents, both of the original language and the English version, if available.

41

For subsection 5.c of the table, please consider adding a field to input jurisdictions who refused (formally or silently) to answer information request(s).

42

For Question 42 (44 in 2017) average from all cases may not reflect the reality of level of overall satisfaction, since it could be negatively influenced by several silent refusals from just one jurisdiction. It would be advisable to have separate questions of level of satisfaction to distinguish answers from those members who did answer and have a separate question for silent or formalistic refusals, as well as a list of members that answered and those who did not answer. It would also be useful to keep the "Note: FIUs are invited to use the following space to comment on specific cases (if applicable)" as in ECB 2017.

45

Question 45 is related with IT section, it could be swapped with question 50 and 50.1 or moved before question 66.

46

Specify period requested (start to end date) if it is for the last two years or since the FIU started to operate.

47

Could you add questions regarding Big Data and Cloud computing?

50

Questions 50 and 50.1 are operational, they could be swapped with Q45 or placed at the start of Section 3 Operational.

51

Questions 51 and 52 could be moved to the Operational section as part of or after questions 41 and 43, respectively.

52

Questions 51 and 52 could be moved to the Operational section as part of or after questions 41 and 43, respectively.

54

The "Person-years metric" is not widely used in Latin America, please add a definition, formula or an example, to standardize responses.

70

Questions 70 and 81 are similar, please clarify difference.

73

Questions 73, 82, and 83, are similar, please define "technical assistance and training", "secondees" and "mentors and coaches" to avoid misinterpretation.

74

Please consider adding "regional groups" to question 74 .

81

Questions 70 and 81 are similar, please clarify difference.

82

Please define "secondees" to avoid misinterpretation with question 83 on "mentors or coaches" and 73 about "technical assistance". 

83

Please define "mentors or coaches" to avoid misinterpretation with questions 82 "secondees" and 73 "technical assistance". 

85

To answer question 85, ECB 2017 reports should be available at the same time when the ECB 2019 is being uploaded. It would be useful to add the link to consult previous ECBs.  Also, Q85 seems to correspond to a closing section, not only to Section 6 - Technical Assistance and Capacity Building.

CLOSING SECTION

Finally, it would be advisable to have a message thanking FIUs for answering the Census and to remind users to review that all responses have been duly validated after uploading their Census, since it could trigger a Support and Compliance process.