Call for consultants – U4 study on building capacities against illicit financial flows in Peru

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U4 STUDY

Building capacities against illicit financial flows in Peru

The role of legal persons and arrangements

Background

Peru faces an intensifying link between corruption and illicit financial flows (IFFs), fuelled by profitable illegal markets and sophisticated criminal networks that exploit complex legal entities, shell companies, and digital financial technologies. These dynamics undermine state authority, distort governance, weaken domestic revenue collection, and limit investment in health, education, and other social priorities, while also harming the environment and public security.

In response, Peru has developed an anti-money laundering / countering the financing of terrorism (AML/CFT) framework led by the financial intelligence unit (FIU), which coordinates obliged entities, supervisors, law enforcement, and the judiciary. However, there are still gaps in implementation of the framework, particularly regarding the role of the private sector (e.g., compliance officers, customer due diligence, suspicious transaction reports, and internal controls), alongside corporate liability prevention models for offences related to corruption and organised criminal activities.

Internationally, Peru’s commitments under the OECD Anti-Bribery Convention and the Grupo de Acción Financiera de Lantinoamérica (GAFILAT)’s recommendations underscore the need to better understand how legal persons and structures are misused for money laundering. Earlier assessments, including a 2021 money laundering / terrorism financing (ML/TF) risk assessment of legal entities and arrangements, revealed major vulnerabilities. However, recent changes to Financial Action Task Force (FATF) Recommendation 24, particularly the inclusion of foreign legal persons with sufficient links to Peru, mean the risk picture is now outdated.

Therefore, the German development cooperation agency (GIZ) in Peru has partnered with the U4 Anti-Corruption Resource Centre (U4) and the Peruvian FIU to conduct a year-long engagement to support Peru’s preparation for the next GAFILAT cycle of mutual evaluation and contribute to a more transparent and resilient financial system that reduces money laundering, criminality, and insecurity. The engagement involves the development of a background study on the assessment of legal persons and arrangements in Peru, and a workshop to convene relevant national and international stakeholders.

Study aims and objectives

The overall aim of the study is to analyse the status, opportunities, and challenges legal persons and arrangements in Peru, integrating political economy drivers of risk and feasibility for reform, including foreign legal persons with “sufficient links”. Findings will serve to inform AML reforms and actionable entry points in the country (particularly the Plan Nacional Contra el Lavado de Activos (PNCLA) to 2030) as well as at a regional level, serving also as preparation for Peru’s upcoming mutual evaluation by GAFILAT. The main objectives of the study will be to:

1. Map how legal persons and arrangements are misused for licit and illicit purposes (focus on ownership/control patterns, cross‑border structures).
2. Identify new and emerging risks linked to digital economies (e.g. fintech, platform businesses, virtual asset‑related entities) and transnational structures.
3. Analyse interests, incentives, and power relations that shape beneficial ownership (BO) transparency and ML/TF controls in this sector.
4. To map and assess current initiatives and capacities of key actors to address issues relating to the role of legal persons and legal arrangements in illicit financial flows in the country.
5. To provide recommendations to strengthen AML reforms in the country (including actionable entry points for the PNCLA to 2030 and upcoming GAFILAT mutual evaluation) for all relevant stakeholders.

The consultant will work collaboratively with the U4 Senior Adviser leading the IFFs theme for each deliverable.

Methodological approach

The consultant will co-develop the methodology with the concerned U4 thematic adviser. The methods to be used should include:

• Desk review of relevant literature, policy documents, legal frameworks, and existing datasets.
• Key informant interviews and/or focus group discussions with stakeholders such as:
  – Public officials
  – Civil society representatives
  – Development partners and multilateral agencies

The consultant should ensure the inclusion of diverse voices, with attention to gender, ethnicity, region, and other marginalised identities.

Deliverables and timeline

Qualifications of the consultant

• The ideal candidate(s) will have:
• Demonstrated expertise in anti-corruption, illicit financial flows and anti-money laundering systems in Peru and in Latin America.
• Strong understanding of Peru’s political economy and public sector institutional landscape.
• Proven experience in different research methodologies, including desk and field components.
• Excellent writing skills in English and the ability to produce clear, policy-relevant analysis (Applying consultants should submit an approved policy report they have written in English).
• Fluency in both English and Spanish.

Data collection and

The research study will adhere to a do-no-harm policy, caring about not divulging confidential information and avoiding any work disruption for interviewees. It should respect the EU General Data Protection Regulation (GDPR), ensuring respect for personal privacy, the voluntary basis for participation and the right for participants to access data. The study will be registered with the Norwegian Centre for Research Data (SIKT) and U4 will advise the consultants on how to respect SIKT guidelines and how to manage and process the data. A letter of consent to participate in the study (prepared by U4) will be given to the consultant(s) if necessary. This letter of consent shall be signed by the interviewees..

Application process

We welcome applications from interested candidates, with the following instructions:

E-mail address
Please send your application/proposal electronically to both u4@cmi.no and rosa.loureirorevilla@cmi.no

E-mail subject line
Please set thee-mail subject to: Consultancy Peru IFF background study

Deadline
Please send your proposal on or before 3 July 2026.

Documents
We will only consider applications that contain all of the following documents:

1. Curriculum Vitae with a list of similar assignments undertaken.
2. Technical proposal (3–4 pages) with a clear methodological approach, outline, timeline, and description of the work plan.
3. Sample of a relevant text written by the applicant(s).

Evaluation criteria

Proposals will be assessed based on:

• Technical merit (50%)
• Relevant experience (50%)

Questions?

Please send any questions you may have to Rosa Loureiro-Revilla at rosa.loureirorevilla@cmi.no

About CMI and U4

The Chr. Michelsen Institute (CMI) is an independent multi-disciplinary development research institute in Norway addressing issues that shape global development and generating knowledge to fight poverty, advance human rights, and promote sustainable social development.

The U4 Anti‐Corruption Resource Centre (U4) was established at CMI in 2002 to promote a better understanding of anti‐corruption issues and approaches to international development. At U4, we work to reduce the harmful impact of corruption on society by sharing research and evidence to help international development actors get sustainable results. We communicate practical entry points for countering corruption – through dialogue, publications, online training, workshops, and a helpdesk.

Download PDF version of this call – English
Download PDF version of this call – Spanish (forthcoming)