FINANCIAL SERVICES ADVISOR a PUBLICATION of the DIALOGUE May 5-18, 2016

LATIN AMERICA ADVISOR FINANCIAL SERVICES ADVISOR A PUBLICATION OF THE DIALOGUE www.thedialogue.org May 5-18, 2016

BOARD OF ADVISORS FEATURED Q&A TOP NEWS Ernesto Armenteros Vice Chairman of the Board, MONEY LAUNDERING Banco de Ahorro y Crédito Unión How Are Stricter Pablo Barahona Authorities COO, Latin America & Continental Target Alleged Europe, Liberty International Rules Affecting Laundering Ring Richard Child CEO, Authorities arrested a prominent Mattrix Group Caribbean Banks? Panamanian businessman and Michael Diaz Jr. dismantled a network of compa- Partner, nies that was allegedly part of a Diaz, Reus & Targ, LLP major money-laundering ring. Ernesto Fernández Holmann Page 2 Chairman of the Board, Ayucus Rich Fogarty INSURANCE Managing Director, Berkeley Research Group Axa Predicting Desiree Green Double-Digit Vice President, Growth in Brazil’s International Government Affairs, Prudential Financial Insurance Sector Earl Jarrett The French insurer expects the General Manager, U.S. policies have led several banks to sever correspondent relationships with banks in the industry to post strong growth Jamaica National Building Society Caribbean, Earl Jarrett says below. // File Photo: TastyCakes via Creative Commons. in the years ahead despite the Thomas J. Mackell, Jr. country’s deep recession. Former Chairman of the Board, Federal Reserve Bank of Richmond Caribbean leaders, including the prime ministers of Trinidad Page 3 Thomas Morante & Tobago and the president of Guyana, met earlier this Partner, month in Washington with U.S. Vice President Joe Biden. FINANCIAL SERVICES Holland & Knight Q Ahead of the meeting, the visitors expressed concerns that David Olivares Itaú’s Goldfajn Senior Credit Offi cer, some U.S. banks were severing ties with banks in the Caribbean due to Tapped to Latin America Banking fears about fi nes and higher costs because of increased U.S. oversight Moody’s Investors Service Head Brazilian of money laundering in the area. What effects are U.S. compliance Manuel Orozco Central Bank Director, regulations having on Caribbean banks? How has the de-risking trend Migration, Remittances & Development, Itaú Unibanco’s chief economist, Inter-American Dialogue affected non-banking fi nancial institutions in the Caribbean basin? Are Ilan Goldfajn, was named head of Adalberto Palma-Gomez the U.S. regulations appropriate, or are they causing an undue burden the country’s central bank. Gold- Senior Partner, on companies and their customers? How will new transparency rules, fajn previously served as central Proxy, Gobernanza Corporativa bank chief under former President announced May 5 by the Obama administration requiring fi nancial insti- Rodolfo Pittaluga Fernando Henrique Cardoso. Retired Principal, tutions to know the true owners of accounts, affect U.S. and Caribbean Page 2 Deloitte Financial banking relationships? Advisory Services, LLC Jan Smith Partner, Earl Jarrett, member of the Financial Services Advisor board KoreFusion and general manager of the Jamaica National Building So- Roberto Teixeira da Costa Board Member, ciety: “The U.S. Treasury’s policies and tactics have had the SulAmérica unintended consequence of banks de-risking their operations Mario Trujillo A CEO, by severing correspondent account relationships with several banks in the DolEx Dollar Express Caribbean region. Many of the region’s banks are fearful that, should the trend continue, Caribbean countries could be locked out of the international payment system, as more than 37 fi nancial institutions have had their accounts restricted or terminated. Remittance companies have also been severely affected, resulting in the closure of businesses or signifi - cant changes in business practices. This includes shipping U.S. currency Goldfajn // File Photo: Brazilian Government. Continued on page 3

REMITTANCES NEWS ANTI-MONEY LAUNDERING NEWS NEWS BRIEFS

Curbing Remittances Authorities Target Goldfajn Tapped to Head Would Harm Anti- Alleged Panama Brazil’s Central Bank Newly appointed Brazilian Finance Minister Laundering Eff orts: Laundering Ring Henrique Meirelles on Tuesday nominated Ilan Goldfajn as the next president of Brazil’s Mexican Offi cial In a coordinated effort between the United central bank, The Wall Street Journal reported. States, Panama and Colombia, authorities have Goldfajn is currently the chief economist for Any attempt by a new U.S. administration to arrested a prominent Panamanian business- Itaú Unibanco, Brazil’s largest private-sector curb the fl ow of remittances from the United man and dismantled a network of companies bank by assets. He was also the director of the States to Mexico would translate into a major that U.S. offi cials allege were part of a major central bank from 2000 to 2003 under Presi- setback in the countries’ joint efforts to stop money laundering ring for drug traffi ckers. In a dent Fernando Henrique Cardoso. The Senate statement May 5, the U.S. Treasury’s Depart- must confi rm Goldfajn’s nomination before he ment of Foreign Assets Control, or OFAC, may take offi ce. announced sanctions against Nidal Waked and his uncle Abdul Waked as well as six other associates of the men and 68 companies tied Caixa Econômica Federal to what OFAC called a “drug money laundering Won’t Need Capital network.” The network “uses trade-based money laundering schemes, such as false commer- Increase: CFO cial invoicing; bulk cash smuggling; and other Aportela // File Photo: Twitter. Brazil’s largest mortgage lender, state-run money laundering methods, to launder drug bank Caixa Econômica Federal, will not need money laundering and other illicit forms proceeds on behalf of multiple international a capital injection, a senior executive told of fi nance, Mexico’s deputy secretary for drug traffi ckers and their organizations,” OFAC Reuters May 9 after the bank reported a 46 per- fi nance said May 12, the Los Angeles Times cent drop in net income as delinquency rates reported. Fernando Aportela also warned increased, Reuters reported. Caixa reported a that any attempt to seize remittances would The Treasury froze quarterly profi t of $235 million, and its delin- force Mexicans to hide and smuggle money, the U.S. assets of 68 quency rose to 3.51 percent from 2.85 percent undermining the strides the two countries have companies involved a year ago. The bank’s return on equity fell to made in making money fl ows more transpar- 10.3 percent from 13.7 percent a year earlier ent. “We will end up getting less information” in the case. as well, causing some analysts to wonder if the to work with instead of more, Aportela said at bank will need fresh capital. Chief Financial Of- the Wilson Center in Washington. “It will create said. As part of the sanctions, the Treasury fi cer Márcio Percival said the 90-day delinquen- [new] challenges.” U.S. presidential candidate froze the U.S. assets of the 68 companies. cy rate could reach 3.8 percent by the end of and presumptive Republican nominee Donald Nidal Waked was arrested May 4 at an airport the year, but added the bank would make up for Trump has vowed that if elected, he would in Bogotá, just after clearing customs follow- losses by implementing higher interest rates on force Mexico to pay for building a wall at the ing his arrival on a Copa Airlines fl ight, the its credit portfolio. border between the two countries and would Associated Press reported. He and his uncle impound remittance payments if the Mexican are accused of being the ringleaders of the government did not comply. Mexican offi cials organization, which is alleged to have used a have repeatedly rejected Trump’s pledge, say- bank—Balboa Bank & Trust—as well as a luxury Costa Rica Planning Tax ing they have no intention of building or paying mall and the duty-free zone at Panama City’s in- on ATM Transactions for a border wall. A Trump administration could ternational airport to launder drug profi ts. The potentially impose regulatory and logistical family also owns the Estrella de Panama, the Costa Rica’s government is planning to impose obstacles to sending remittances to Mexico, Central American country’s largest newspaper. a new tax on ATM transactions of more than much in the way the United States has done The family’s holding company, Grupo Wisa, 100,000 colones ($187), local newspaper El to impede terrorism fi nancing. However, doing issued a statement Thursday calling the allega- Mundo reported May 13. The tax would amount so would likely be met with challenges in the tions “false and unfounded,” the AP reported. to 0.02 percent of the transaction amount, said courts and resistance from banks. The company added that it had instructed its legislator Otto Guevara, who opposes the tax.

lawyers to cooperate fully in an investigation FEATURED Q&A / Continued from page 1 that was announced by Panamanian Attorney General Kenia Porcell Díaz. “We are cooperat- around the region or negotiating non-bank and foreign countries are concerned that ing fully with U.S. authorities in this matter, and settlement options to facilitate remittance the traditional shell company may be that we will ensure justice is served by the people payments. These non-bank alternatives gold that is gone forever. The Panama of Panama. This investigation further strength- expose the region to greater risk of money Papers revealed what many already knew: ens our efforts and resolve to vigorously attack laundering as the transparency offered by that shell companies are used frequently for criminal activity in Panama so that the rule of correspondent banking relationships is both legal and illegal purposes. Recently, law prevails,” Porcell Díaz said in a statement. substituted for less formal payment and the U.S. government set forth new ‘custom- Panamanian offi cials also said they had seized settlement arrangements. Non-bank entities er due diligence’ rules, requiring fi nancial Balboa Bank & Trust and brokerage Balboa are also inclined to conduct transactions in institutions to verify who actually owns and Securities as part of the action. An unnamed U.S. currency rather than domestic currency, profi ts from a shell company when it opens law enforcement offi cial told the AP that the thereby stimulating greater use of cash and an account with a fi nancial institution. But Waked family is accused of laundering money the emergence of black market operations. does this new regulation truly eviscerate on behalf of Mexican and Colombian drug Banks in the United States have expressed the use of shell companies? Maybe not. The cartels as well as independent drug traffi ckers. fear and fatigue in fully understanding the term ‘benefi cial owner’ has traditionally been U.S. offi cials have requested Nidal Waked’s requirements of the law; and in avoidance defi ned in the international fi nance sector extradition, Colombian migration offi cials told of fi nes and custodial sentences, have taken as the actual human being who gains from the AP. He faces charges of money laundering the easiest and simplest route by severing the company’s equity. However, President and bank fraud in Florida, according to the Drug banking relationships. The new customer Obama’s new ‘customer due diligence’ rules Enforcement Administration. The arrest and due diligence rule announced on May 5 redefi ne the meaning of ‘benefi cial owner.’ the investigation was announced just weeks requires banks to identify and verify the Under the new rule, anyone who owns less after the release of the “Panama Papers” in benefi cial owners who own and profi t from than 25 percent of a company does not need which the leak of some 11.5 million documents companies. I anticipate that this rule will to be reported as the benefi cial owner, and, showed how Panamanian law fi rm Mossack exacerbate the problems of correspondent perhaps more interestingly, the appointed Fonseca helped clients conceal wealth. The banks as the cost of compliance and the risk president of a shell company is allowed to leak has led to pressure on Panama to improve of fi nes would increase. In a technologically, be listed as the ‘benefi cial owner.’ The fallout the transparency of its fi nancial system. Soon fi nancially and politically integrated world, from the Panama Papers will continue. It is after the leak, Panamanian President Juan efforts should not be made to unilaterally now more important than ever to proactively Carlos Varela announced he was forming a build ‘fi nancial walls’ and require countries seek to avoid the traps meant to catch illegal commission of international experts in an such as those in Latin America and the Ca- activity. It is crucial in these times to have effort to make the country’s offshore fi nancial ribbean to pay the cost. Instead, we should a trusted team of advisors, including legal industry more transparent. [Editor’s note See utilize the well-established channels of counsel, to give certainty and security to related Q&A in the April 27 issue of the Latin bilateral discussion and cooperation to craft your tomorrow. Maybe nothing gold can stay, America Advisor.] policies that will have the desired effect but it is not yet gone.” of combating money laundering and tax evasion, while pursuing options for countries Matias Mora Simoes, managing INSURANCE NEWS in the region to continue to participate in director for the Central America the international payment system; thereby region at Berkeley Research improving the economic conditions of these A Group: “As a result of stricter Axa Predicting countries and strengthening relations with U.S. compliance regulations, Caribbean Brazilian Insurance the United States and engagements in the banks are re-evaluating their compliance region.” programs and banking practices. They are Sector Growth having to invest heavily in the adoption of Louis V. Martinez and Roland M. best practices as well as the acquisition of French insurer Axa is predicting double-dig- Potts, attorneys at Diaz, Reus & tracking and monitoring tools. Small banks it growth for Brazil’s insurance sector this Targ LLP: “As Robert Frost once that do not have the economies of scale and year despite an ongoing recession, and the A wrote, ‘nothing gold can stay.’ economic strength to face a large penalty company would consider more acquisitions in With the release of the Panama Papers, a will not last long in the market, and only South America’s largest economy, Bloomberg lot of investors, banks, fi nancial institutions Continued on page 6 News reported May 6. A local currency that has

COPYRIGHT © 2016, INTER-AMERICAN DIALOGUE PAGE 3 FINANCIAL SERVICES ADVISOR May 5-18, 2016 fallen 30 percent since Axa entered the market in 2013 has made acquisitions attractive again, ADVISOR Q&A Philippe Jouvelot, president of the company’s Brazilian unit, told the news service. “If we can trust that Brazil’s economy can recover two Will Dilma Survive the Eff ort to

Demographics in Oust Her Permanently? the region provide a Following a marathon session vice president. But this number represents positive outlook....” that lasted more than 20 hours, a snapshot in time and could change with — Philippe Jouvelot Q Brazil’s Senate voted May 12 a lack of public support over the coming to suspend President Dilma months. The new cabinet chosen by the vice Rousseff from offi ce and put her on trial president is a group of white, male, conser- to three years from now, then investing now for allegedly breaking the country’s budget vative, old-style politicians who represent is the best thing you can do,” Jouvelot said. laws, an allegation she denies. What will the traditional way of doing politics—in the Brazil’s insurance market, now valued at about result from the trial? What are the long-term shadows, though back rooms and without $100 billion, has room to grow, he added, with effects of this situation on Brazil’s democ- transparency. It is a team with no diversity— only 25 percent of Brazilians having health racy and economy? What policies must no women, no businesspeople, no blacks, insurance and only 10 percent with homeown- Acting President Michel Temer pursue now no social movement leaders and no minority ers insurance. Other industry executives are in order to stabilize a country that has faced groups represented in the cabinet. It is a similarly bullish on the sector’s outlook. “The economic and political upheaval? How is powerful sign of the regression of democra- regional income per capita is around $10,000, Brazil’s political situation being viewed cy. How will that government deal with the which represents an infl exion point in terms internationally? demands of civil society? Probably by using of insurance growth,” Pablo Barahona, the outdated security measures. In the inter- chief operating offi cer for Latin America and Gilberto M. A. Rodrigues, pro- national arena, multilateral organizations Continental Europe at Liberty International, told fessor of international relations critical of the impeachment, such as the the Advisor in December. “Demographics in at the Federal University of ABC OAS and Unasur, could become obstacles the region provide a positive outlook, as well... A in Brazil and member of the for the new government to burnish its image, in most countries, the percentage of the adult Coordinadora Regional de Investigaciones which will try to strengthen its relationship population is increasing, providing a larger Economicas y Sociales (CRIES): “The Senate with international investors and the private base of potential customers for the insurance session confi rmed the lower chamber’s sector, not only to boost the economy, but sector,” he added. action. For the majority of the parliamentar- also to divert attention from its troublesome ians, the legal aspects of the process were lack of legitimacy.” secondary; the impeachment was clearly an POLITICAL NEWS opportunistic political movement to remove the Workers’ Party from power. The fact that EDITOR’S NOTE: More commentary on this Army Must Choose 55 senators voted to suspend the president, topic appears in the May 13 issue of the one vote more than needed to dismiss in Latin America Advisor. Whether to Follow the trial, is seen as a strong support for the

Constitution or constitution or with Maduro,” Capriles told the Supreme Court may overrule that decision journalists, BBC News reported. “To impose as it has with other actions by the legislature. Maduro: Capriles this, he’d better start preparing to deploy the Opposition leaders are planning nationwide war tanks and military jets.” The 60-day state protests for May 18 to demand that authori- Following a declaration of a state of emergency of emergency that Maduro declared beginning ties accept petitions calling for a referendum by Venezuelan President Nicolás Maduro, the last Monday suspends several constitutional to recall Maduro. The president on Tuesday country’s army must decide whether to adhere protections, paves the way for expropriations said the petitions, which the opposition says to the country’s Constitution or follow Maduro, and also gives the police and military wider contain some 1.8 million signatures in favor of opposition leader Henrique Capriles said May powers to maintain public order. Venezuela’s a referendum, are riddled with fraud. [Editor’s 17. “I tell the armed forces: The hour of truth opposition-controlled National Assembly note: See Q&A about Venezuela in the May 17 is coming, to decide whether you are with the rejected the emergency decree in a vote, but issue of the Latin America Advisor.]

NEWS BRIEFS properly investigated nor prosecuted. The Mexican President AFL-CIO and four Colombian unions said in the Dominican Republic’s Proposes Legalizing complaint that since the U.S.-Colombian trade Medina Claims Victory, deal took effect in 2011, nearly 100 Colombian Same-Sex Marriage workers or their advocates were killed as they Abinader Concedes tried to exercise labor rights. The complaint said the oil and sugar sectors were among the Dominican President Danilo Medina on May Mexican President Enrique Peña Nieto on May businesses where workers remain oppressed. 17 claimed victory in Sunday’s election, as 17 proposed legalizing gay marriage nation- AFL-CIO President Richard Trumka called the partial results showed him winning by a wide wide, the Associated Press reported. The labor provisions for the TPP a “near carbon margin, BBC News reported. Of the 67 percent move would enshrine a ruling last June by the copy” of those in the Colombian trade deal. of all votes counted, Medina had captured 62 country’s Supreme Court that it is unconstitu- Lawmakers will likely vote on the TPP, which percent, well ahead of the second-place fi n- tional for states to bar same-sex couples from was negotiated last year but still requires U.S. isher, Luis Abinader, who captured 35 percent getting married. The ruling did not overturn any congressional approval, after the November of the votes tallied. Abinader conceded but state laws at the time. At an event on the Inter- presidential elections. A study by the Washing- accused the president of misappropriating national Day Against Homophobia, Peña Nieto ton-based Peterson Institute for International state resources in order to win re-election. said he had signed initiatives that would seek Economics estimates the TPP will increase Medina’s Dominican Liberation Party, or PLD, to add provisions to Mexico’s Constitution and annual real incomes in the United States by also appeared to have retained control of the national civil code that would allow for same- $131 billion and boost annual exports by $357 Senate and Chamber of Deputies. sex marriage. The president said he would plan billion by 2030. to reform Article 4 of the Constitution so that it would refl ect the Supreme Court’s opinion Mexican Teachers Call “to recognize as a human right that people can Chile Expects Copper Indefi nite National Strike enter into marriage without any kind of discrim- ination.” Peña Nieto’s Twitter page was turned Prices to Rise Sharply Members of the CNTE teachers union in Mex- rainbow-colored on Tuesday when he made the ico began an indefi nite strike on May 16, de- announcement. Gay marriage is already legal Chilean offi cials expect copper prices to manding that the government of President En- in some parts of Mexico, including the capital, increase by about a third over the long term be- rique Peña Nieto scrap its education reforms, the northern state of Coahuila and Quintana cause of rising demand from China, Bloomberg EFE reported. The reforms include mandatory Roo state. News reported Monday. Copper, the country’s teacher evaluations, which began last year and top export, may average $6,330 per metric ton can lead to the dismissals of teachers who fail them. Teachers in several states were working, ECONOMIC NEWS but there was a “high level” of teachers who We have a high level were observing the strike in states including of confi dence about Michoacán and Guerrero, said Michocán’s Labor Unions File the increasing prices.” CNTE secretary, Salvador Almanza. Complaint Over — Sergio Hernández

Colombia Trade Pact after 2018, Sergio Hernández, executive vice House Misses Deadline president of the Chilean Copper Commission, for Puerto Rico Bill Labor unions from the United States and or Cochilco, told reporters. Some producers, Colombia on May 16 fi led a complaint with the such as Rio Tinto Group and Freeport-McMo- U.S. House republicans on May 13 missed a U.S. Department of Labor, saying the bilateral Ran, have projected the copper market will be self-imposed deadline for a plan to help Puerto trade agreement between the two countries in defi cit within several years, if not next year. Rico dig out from under $70 billion in debt, the has failed to safeguard worker protections in “We have a high level of confi dence about the Associated Press reported. Lawmakers have the Andean nation as promised, Reuters re- increasing prices,” Hernández said. The lull gone through three versions of a bill that would ported. The unions, which have pointed out the in global copper prices in recent years has create a control board to oversee some debt massive 12-nation Trans-Pacifi c Partnership brought labor tension in Chile as companies restructuring, but fi scal conservatives fear it they generally oppose is subject to the same adjust to lower demand. Unionized workers at would set a precedent for fi nancially ailing shortcomings they see in the Colombia-U.S. Freeport-McMoRan’s El Abra mine accepted states, while some Democrats have expressed pact, said threats and acts of violence against a wage contract offered by the company last concern the board would favor creditors. trade unionists in Colombia were neither month after a strike, Reuters reported.

FEATURED Q&A / Continued from page 3 FINANCIAL SERVICES ADVISOR is published biweekly by the Inter-American Dialogue, Copyright © 2016 the big banks that are capable of facing Belize is most affected, with more than this situation will remain. The extreme use half of its banking assets no longer having Erik Brand of de-risking is increasing the closure of a correspondent banking relationship. In Publisher [email protected] correspondent banking relationships in Jamaica, the number of money transfer busi- the region. This directly affects countries’ nesses and foreign exchange traders has Gene Kuleta Editor commercial sectors because companies use declined; Guyana, the Cayman Islands, the [email protected] these correspondent accounts to pay for Nicole Wasson many commercial transactions, transfers, Reporter, Assistant Editor purchases of imports and export sales. The FinCEN’s latest rules [email protected] U.S. regulations are considered strict, but may have gone too far, they are actually appropriate, taking into ac- making it easier count the objectives of the new AML compli- to cease relations ance horizons. However, the extreme use of than to increase Michael Shifter, President de-risking could affect companies and cus- compliance.” Genaro Arriagada, Nonresident Senior Fellow tomers that are eliminated as clients without — Jan Smith Sergio Bitar, Nonresident Senior Fellow a proper investigation, just because they are Joan Caivano, Director, Special Projects perceived as a risk. Banks should generate Kevin Casas-Zamora, Director, and carry out adequate KYC programs that Peter D. Bell Rule of Law Program allow them to accurately determine the true Bahamas and Barbados all have experienced Ramón Espinasa, Nonresident Senior Fellow risk profi les of their clients. New transparen- terminations, and business has slowed. The Ariel Fiszbein, Director, Education Program cy rules demand that clients provide much terminations are not based on any wrong- Alejandro Ganimian, Nonresident Fellow more information about their business and/ doing, but rather a result of constricting Peter Hakim, President Emeritus or assets to justify their banking activity, cost of compliance set by Basel, FATCA and Claudio Loser, Senior Fellow among other requirements. These require- other bodies. Guidelines are often unclear Nora Lustig, Nonresident Senior Fellow ments would be applied differently among or inconsistently applied. Regulators need Margaret Myers, Director, China and Latin America Program the types of clients according to their to be more clear and must limit exposure to Manuel Orozco, Director, Migration, risk profi les—the higher the risk, the more fi nes and penalties when there has been no Remittances & Development information required. If a client can’t provide proven illegal activity. The Caribbean region Jeffrey Puryear, Senior Fellow all the required information on the origin of is vocal in expressing its concerns—most Tamar Solnik, Director, Finance & Administration funds, banks will be obliged to close their recently at the Financial Stability Board’s Lisa Viscidi, Director, Energy Program accounts. If Caribbean banks follow the new meeting in Tokyo—but their plight seems to transparency rules by the book, this can only be falling on deaf ears. FinCEN’s latest rules Financial Services Advisor is published biweekly, strengthen its relationship with their U.S. may have gone too far, making it easier to with the exception of major holidays, from 1211 Connecticut Avenue NW, Suite 510 counterparts.” cease relations than to increase compliance. Washington, DC 20036 The risk is that countries and individuals Phone: 202-822-9002 Jan Smith, partner at KoreFu- who no longer have access to the services Fax: 202-822-9553 sion in Mexico City: “De-risking of international banks will conduct their www.thedialogue.org has a severe impact on the fi nancial and foreign exchange transactions ISSN 2163-7962 Caribbean—a phenomenon also outside of licensed institutions. This is a Subscription Inquiries are welcomed at A [email protected] affecting countries in Asia, Africa and Latin serious concern, because in most countries,

America in a major way. Unfortunately, more more than 60 percent of payments are still The opinions expressed by the members of the Board of terminations of correspondent accounts and made in cash.” Advisors and by guest commentators do not necessarily the loss of banking services will worsen, represent those of the publisher. The analysis is the sole view of each commentator and does not necessarily leaving many businesses and individuals cut The Advisor welcomes comments on its Q&A represent the views of their respective employers or off from their money and making it diffi cult section. Readers can write editor Gene Kuleta fi rms. The information in this report has been obtained from reliable sources, but neither its accuracy and for new businesses to establish operations. at [email protected]. completeness, nor the opinions based thereon, are guaranteed. If you have any questions relating to the contents of this publication, contact the editorial offi ces of the Inter-American Dialogue. Contents of this report may not be reproduced, stored in a retrieval system, or transmitted without prior written permission from the publisher.