This federal law, often referred to as the Anti-Money Laundering Law, is designed to protect Mexico’s financial system and national economy by establishing mechanisms to prevent, detect, and investigate operations involving illicit financial resources. Although it does not name the wire transfer regulations (WTR) or FATF Recommendation 16 directly, its structure lays a comprehensive foundation for WTR compliance, especially in the context of AML enforcement and the traceability of financial flows.

Definition & Oversight of Vulnerable Activities

The law introduces the term “Vulnerable Activities”, encompassing both regulated financial institutions and a wide range of non-financial sectors that may be exploited for money laundering. These include casinos, precious metals traders, real estate transactions, and—critically—money and securities transfer services and virtual asset service providers (VASPs) not covered by other financial laws.

Institutions and persons engaging in such activities are subject to strict reporting requirements, including transaction monitoring, customer identification, and the filing of “Notices” with the Ministry of Finance and Public Credit (SHCP). These are equivalent to reports on financial transfers that might trigger WTR obligations.

Key Requirements for Financial Entities

Financial institutions, including those regulated under the Credit Institutions Law and Fintech Law, are obliged to:

• Implement risk-based internal procedures to detect operations potentially involving illicit resources.

• Identify and verify the identity of clients and users, including beneficial owners.

• Submit reports on relevant financial operations, including internal misconduct or transactions that could violate AML rules.

• Maintain records for at least ten years, ensuring the traceability of wire transfers and client relationships.

These measures mirror the technical and procedural requirements expected under the Travel Rule, ensuring originator and beneficiary data are captured, stored, and made available for regulatory use.

Virtual Assets & the Travel Rule

Following a 2018 amendment, Section XVI of Article 17 brought virtual asset-related services under the scope of the law. Any non-financial entity offering virtual asset exchanges, storage, or transfer services must:

• File a Notice with SHCP if any single transaction per client exceeds the threshold (645 UMA).

• Maintain the capacity to trace and identify users, echoing FATF’s expectations for VASPs under the Travel Rule.

Furthermore, if Banco de México recognises specific virtual assets under the Fintech Law, providers must seek formal authorisation within defined timeframes—an essential step in creating Travel Rule–ready infrastructure.

Supervision, Sanctions & Information Exchange

Oversight responsibilities are shared among the CNBV, the Tax Administration Service (SAT), and specialised financial units within the Attorney General’s Office. These bodies may conduct verification visits, enforce sanctions, and collaborate with foreign authorities under international cooperation agreements.

The law criminalises:

• The deliberate provision of false transaction data

• The unauthorised disclosure of confidential financial information

• The non-compliance with reporting obligations

Sanctions range from substantial administrative fines to imprisonment, depending on the severity and recurrence of violations. This regulatory pressure ensures compliance with WTR-aligned obligations, particularly regarding data transmission and retention.

Use of Cash & Prohibited Transactions

The law restricts high-value transactions using cash or precious metals, enforcing mandatory use of traceable payment methods. These thresholds (defined in multiples of the minimum wage)ensure that significant transfers are routed through systems where originator and beneficiary information is recorded and verifiable, thus supporting WTR principles even outside conventional wire systems.

Conclusion: WTR Compliance Integration

While not naming the wire transfer regulation explicitly, the Federal Law for the Prevention & Identification of Operations with Resources of Illicit Origin is a cornerstone of Mexico’s AML/CFT framework. It establishes the institutional, procedural, and punitive infrastructure necessary to meet FATF Recommendation 16 objectives, ensuring that both financial and designated non-financial businesses and professions (DNFBPs) contribute to a transparent, monitored, and secure environment for the transmission of funds.