Compliance & Anti-Money Laundering

Services

Ramos, Ripoll & Schuster (“RRS”) provides specialized counsel to both domestic and international clients in the development and implementation of regulatory compliance policies. We have extensive experience advising companies whose business models require compliance with the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds and the regulations applicable to financial institutions operating in Mexico.

At RRS, we believe that compliance measures are not only a legal obligation, but also a strategic advantage for businesses. Accordingly, we also assist companies in the design and implementation of best practices, even where specific compliance obligations are not legally mandated. Adopting these practices significantly reduces operational and legal risks, including:

1. Minimizing exposure to business relationships with individuals or entities linked to illicit activities, thereby avoiding direct or indirect involvement in money laundering or terrorist financing schemes.
2. Reducing the risk of engaging with individuals or entities sanctioned by domestic or international authorities.
3. Preventing potential corporate criminal liability.
4. Avoiding asset forfeiture proceedings that could result in the loss of assets whose lawful origin cannot be demonstrated.
5. Preserving and strengthening corporate reputation.

Financial Institutions

Our Firm provides legal counsel to ensure that financial institutions fully comply with the obligations imposed by applicable financial laws and secondary regulations governing their operations, including:

1. Drafting of Compliance Manuals.
2. Advisory support in the implementation of automated compliance systems and the appointment of Compliance Officers.
3. Design and delivery of compliance training and awareness programs.
4. Annual audits regarding anti-money laundering and counter-terrorist financing compliance.
5. Development of customer identification policies and forms.
6. Assistance in the implementation of Know Your Customer (KYC) procedures.
7. Regulatory authorization procedures for non-face-to-face customer identification before the relevant supervisory authorities.
8. Preparation of Risk-Based Approach methodologies and risk assessment models.
9. Assistance with the filing of reports with the Financial Intelligence Unit through the corresponding supervisory authorities.
10. Support in obtaining technical opinions issued by the National Banking and Securities Commission.
11. Advice regarding notices of change of control and changes in shareholding structures before the relevant supervisory authorities.
12. Assistance in updating periodic regulatory information before the National Commission for the Protection and Defense of Financial Services Users, including SIPRES, REUNE, RECA, REDECO, RECO and the Buró de Entidades Financieras, among others.

Vulnerable Activities

RRS advises companies whose lawful business activities are considered more exposed to money laundering and terrorist financing risks under Mexican law, commonly referred to as “Vulnerable Activities.” These include, among others, vehicle sales, trading of precious metals, gemstones, jewelry and watches, virtual asset transactions, art sales, lending and credit activities and real estate transactions.

Our services focus on ensuring compliance with the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds and its implementing regulations applicable to entities engaged in Vulnerable Activities, including:

1. Registration of Vulnerable Activities before the Mexican Tax Administration Service.
2. Drafting of Policies and Procedures Manuals.
3. Assistance with the filing of monthly reports before the Financial Intelligence Unit through the Mexican Tax Administration Service.
4. Guidance regarding the appointment of service providers and Compliance Representatives.
5. Design and implementation of compliance training programs.
6. Development of customer identification policies and forms.
7. Assistance in implementing customer identification procedures.
8. Annual anti-money laundering and counter-terrorist financing compliance audits.

General Compliance Services

Our Firm also provides broader regulatory compliance services, including:

1. Legal opinions regarding whether specific business models fall within regulatory compliance obligations under Mexican law.
2. Preparation of Anti-Money Laundering and Counter-Terrorist Financing Manuals, as well as Anti-Corruption Manuals and Codes of Conduct or Codes of Ethics as part of corporate best practices.
3. Development of regulatory compliance guidelines.
4. Regulatory and preventive audits in connection with potential mergers and acquisitions.
5. Adaptation of international compliance policies to Mexican law and local business practices.

Our team has been recognized by leading legal directories and publications, including Who’s Who Legal, Chambers and Partners, Best Lawyers and Latin Lawyer. In addition, our professionals hold compliance-related certifications issued by the National Banking and Securities Commission and the Financial Intelligence Unit.

Representative Matters

Our Firm has successfully advised a wide range of financial institutions, including banks, multi-purpose financial entities (SOFOMs), money transmitters, fintech institutions, popular financial institutions, investment funds and investment advisers, among others. We have also assisted clients across diverse industries and business models, including consumer lending companies, prepaid card issuers, real estate developers and sellers, art intermediaries and virtual asset businesses.

For these clients, we have provided services including the preparation of Compliance Manuals, the design and delivery of training programs, the performance of external audits, the development of customer identification policies and forms, the preparation of Risk-Based Approach methodologies, assistance with regulatory filings and reporting obligations before the relevant supervisory authorities, the development of regulatory compliance guidelines, legal opinions regarding business models, and regulatory and preventive due diligence audits for potential mergers and acquisitions, among other services.

RRS provides a comprehensive range of services that enable companies across all industries to establish and implement compliance mechanisms, policies, procedures and best practices tailored to the specific characteristics of their business models. These services are designed to ensure compliance with the Mexican regulatory framework, reduce legal and operational risks and promote a prevention-oriented corporate culture.

In addition, our services are delivered through a collaborative, multidisciplinary approach, integrating the Firm’s various specialized practice areas to develop truly tailored solutions that address each client’s particular needs and business objectives.