Anti-Money Laundering (AML/PLD) in Mexico: Key Compliance Insights

Introduction

In Mexico, PLD (Prevención de Lavado de Dinero) refers to the legal and regulatory framework aimed at preventing and detecting money laundering and the financing of terrorism. Given the country’s strategic geographic position, growing financial sector, and international business ties, AML compliance is not only a legal obligation but also a critical element of corporate governance, risk management, and financial transparency.

The Legal Framework

The cornerstone of Mexico’s AML regime is the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (LFPIORPI), enacted in 2012. This law complements provisions found in:

• The Federal Penal Code (money laundering offenses).
• The Credit Institutions Law and financial regulations.
• Guidelines issued by the National Banking and Securities Commission (CNBV), the Tax Administration Service (SAT), and other regulators.

Mexico’s AML rules align with the Financial Action Task Force (FATF/GAFI) international standards, reflecting the country’s commitment to global financial integrity.

Obligated Entities

Entities subject to AML/PLD compliance include both financial institutions and certain designated non-financial businesses and professions (DNFBPs), such as:

• Banks, brokerage houses, insurance companies, fintechs, and other financial intermediaries.
• Casinos, real estate developers, jewelry dealers, and notaries.
• Lawyers and accountants engaged in high-value transactions.

These entities are required to implement AML controls and report to the SAT through its official platform.

Core Compliance Obligations

Obligated parties must implement comprehensive PLD programs, which typically include:

1. Customer Due Diligence (CDD/KYC):
   Verification of client identity, beneficial ownership, and risk profiling.
2. Recordkeeping:
   Retention of client documentation and transaction data for at least five years.
3. Transaction Monitoring and Reporting:
   Identification and timely reporting of “unusual” or “relevant” transactions to the SAT.
4. Internal Policies and Training:
   Establishing written AML/PLD policies, training staff, and appointing a compliance officer.
5. Risk-Based Approach:
   Applying enhanced due diligence for high-risk customers, politically exposed persons (PEPs), and cross-border operations.

Enforcement and Penalties

Non-compliance with AML/PLD obligations can result in severe consequences, including:

• Administrative fines ranging from thousands to millions of pesos.
• Criminal liability in cases of willful misconduct or facilitation of money laundering.
• Reputational damage, which can limit access to banking and investment opportunities.

Regulators like the CNBV and SAT are increasingly active in supervision, audits, and enforcement actions.

Practical Considerations for Foreign Investors and Companies

Foreign individuals and businesses operating in Mexico must recognize that AML/PLD compliance extends beyond banks. For example:

• Buying or selling real estate above certain thresholds triggers reporting obligations.
• Payments made in cash above statutory limits are strictly prohibited.
• Companies must ensure suppliers, clients, and partners are screened against official blacklists.

For multinational groups, integrating Mexican AML requirements with global compliance programs is essential to avoid conflicts and duplication.

Conclusion

AML/PLD compliance in Mexico is a mandatory legal obligation and a best practice for corporate governance. By implementing robust internal controls, companies and individuals not only protect themselves from legal risks but also enhance trust with clients, investors, and regulators.

In a business environment where transparency and compliance drive long-term success, understanding and applying Mexico’s PLD framework is no longer optional—it is strategic.