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Mexico: Credit Institutions Law 1990 (amended 2021)

The Credit Institutions Law provides the foundational legal basis for the regulation of fund transfers in Mexico. While it does not explicitly use the term 'wire transfer regulations', it outlines the powers and responsibilities of authorised credit institutions regarding the raising and movement of public funds. These include commercial and development banks, which are the only entities permitted to accept deposits and conduct financial intermediation involving the public. Such activities naturally encompass wire transfers and related payment instructions.


Regulatory Oversight & Institutional Responsibilities

The law empowers the National Banking & Securities Commission (CNBV) with broad supervisory authority over credit institutions. This includes the discretion to issue general provisions, inspect financial entities, and enforce compliance with operational and prudential regulations. These functions directly support the requirements of the FATF Travel Rule, particularly in ensuring that financial institutions transmit and retain full and accurate information on originators and beneficiaries of wire transfers. The CNBV’s authority allows it to enforce rules that uphold transparency, data integrity, and transaction traceability.


Governance, Risk & Compliance Structures

Credit institutions must implement rigorous governance frameworks, which are central to maintaining compliance with the FATF Travel Rule. The law mandates the establishment of internal control systems, audit committees, and boards of directors that meet specific independence and competence requirements. Institutions are also required to ensure the security and integrity of customer data and transactions. These provisions enable the operational enforcement of the WTR, such as ensuring that information accompanying wire transfers is complete and reliable.


Monitoring, Record-Keeping & AML Context

Although the law does not outline specific technical requirements for wire transfers, it implicitly supports the AML/CFT framework under which the FATF Travel Rule is implemented. Institutions are expected to monitor transactions, detect anomalies, and submit reports on suspicious operations. The CNBV may require financial institutions to provide data or adopt corrective measures if deficiencies are found. These mechanisms align with FATF Recommendation 16, which obliges financial institutions to detect and prevent misuse of wire transfers for illicit purposes.


Enabling Infrastructure for WTR Enforcement

The law also addresses technological and procedural standards for financial operations. Credit institutions may use automated systems, data networks, and digital authentication tools for transaction processing. This supports the technical implementation of the Travel Rule, as information accompanying wire transfers must be securely transmitted and verified in real time. Moreover, institutions are held responsible for the lawful conduct of third-party agents involved in their operations, including those who might handle or process wire transfers on their behalf.


Conclusion: WTR Compliance Integration

While the Mexican Credit Institutions Law does not reference the Wire Transfer Rule by name, it provides a robust regulatory infrastructure for its implementation. Through strict licensing, oversight by the CNBV, governance obligations, and embedded AML requirements, the law ensures that credit institutions are equipped to meet international standards on wire transfer transparency. This statutory foundation is critical to Mexico’s compliance with global anti-money laundering norms and its obligations under the FATF Travel Rule.

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