Anti-Money Laundering (AML)

We determine whether your activity is a vulnerable activity and handle your registration as an obligated party with the SAT (Mexico's federal tax authority).

• Identification and classification of vulnerable activities (designated non-financial activities) under Article 17 of the LFPIORPI
• Activities added or modified by the 2025 amendments: real estate development, virtual assets, and new thresholds
• Identification and reporting thresholds expressed in UMA (Unit of Measurement and Update, Mexico's reference index for fines and thresholds); restrictions on payments in cash and precious metals under Article 32
• Enrollment, updating, and deregistration on the SAT Anti-Money Laundering Portal
• Appointment and registration of the compliance officer (designated representative)
• Gap analysis between your current program and the new statutory and regulatory obligations

We design the risk methodology and the Internal Policies Manual required by the new regime.

• Your own risk methodology: transactions, customers, geographic areas, channels, and the National Risk Assessment
• Preparation and updating of the Internal Policies Manual, including customer risk classification
• Transaction profile and enhanced due diligence measures
• Policies for politically exposed persons (PEPs), high-risk customers, nonresidents, and high-risk jurisdictions
• Compliance policies for business groups, branches, and affiliates in line with FATF standards

We compile your customers' identification files and document the beneficial owner (beneficiario controlador) of each structure.

• Compilation of the single customer and user identification file (KYC file)
• Periodic verification and updating of customer information
• Beneficial ownership based on the threshold of more than 25% of voting rights or effective control, and the order of precedence
• Beneficial ownership obligations for legal entities and trusts, aligned with the Código Fiscal de la Federación (Federal Tax Code, CFF)
• Screening against the list referred to in Article 38 of the General Rules and PEP verification through the electronic tools of the UIF (Financial Intelligence Unit)

We file your reports and respond to requests from the SAT and the UIF within the legal deadlines.

• Monthly reports, nil reports, and aggregation reports for transactions accumulated over six months
• 24-hour report upon indications of illicit proceeds, even if the transaction is not completed
• Migration to the UIF report formats and annexes, including those on beneficial ownership
• Response to requests, electronic notices, and appearances before the SAT and the UIF
• Daily monitoring of the portal and of electronic notices

We strengthen your program with annual training, automated monitoring systems, and compliance audits.

• Annual training programs for governing bodies, senior management, the compliance officer, and staff
• Personnel selection criteria
• Advice on automated monitoring systems: alerts, transaction aggregation, PEPs, and transaction profile
• Coordination of the annual compliance audit, internal or independent external, depending on risk
• Follow-up on the remediation of findings and on the corresponding audit report
• Ten-year record retention policies with traceability of each transaction

We represent you in verification visits and enforcement proceedings, and manage your remediation.

• Representation in SAT verification visits and administrative enforcement proceedings, and in UIF information requests
• Defense against fines set in UMA and other penalties for noncompliance
• Management of voluntary compliance before the SAT: one-time waiver of penalty or reduction of fines
• Appeal for review (recurso de revisión), administrative litigation before the Federal Court of Administrative Justice, and amparo proceedings (constitutional protection suit) against penalties
• Criminal implications of the offense of transactions involving illicit proceeds (Article 400 Bis of the Federal Criminal Code)

We support strategic sectors in their transition to the regime of the General Rules as amended by Resolution 115/2026.

• Advice to notaries, corredores públicos (public commercial brokers), real estate developers and brokers, landlords, and trustees
• Advice to professional service providers and dealers in vehicles, jewelry, and precious metals
• Advice to authorized donees (nonprofits) and virtual asset service providers (VASPs)
• Phased plan for the amended General Rules, which enter into force on November 30, 2026
• Calendar of phased obligations during 2027 and 2028: methodology, manual, automated systems, notices, training, and audit
• Preparation for FATF standards and Mexico's mutual evaluation
• Legal opinions and compliance reports for corporate, real estate, and foreign investment transactions