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FINANCE AND BANKING / by Miguel Gallardo Guerra The year 2026 is shaping up to be a period of regulatory consolidation in Mexico. After several years of reforms, administrative criteria, and operational adjustments, authorities are moving toward a more technology-driven, preventive, and risk-based model, particularly in the financial, fintech, technology, and digital services sectors. This …
FINANCE AND BANKING / by Miguel Gallardo Guerra The risk-based approach (RBA) is one of the fundamental pillars of the anti-money laundering and counter-terrorist financing system. As a result, it is also a core element of the AML/CFT audit and of the content of the Audit Report. The Guidelines provide that the auditor must support …
FINANCE AND BANKING / by Miguel Gallardo Guerra One of the elements that most frequently weakens an AML/CFT Audit Report is not the absence of policies or controls, but rather poor audit planning and an insufficient or overly generic work program. The Guidelines for the preparation of the Audit Report provide that the audit must …
FINANCE AND BANKING / by Miguel Gallardo Guerra A major error in compliance is assuming that the AML/CFT Audit Report is a flexible or free-format document. In reality, the Guidelines for preparing the Audit Report clearly specify its contents, structure, and the expected level of technical support. An incomplete, generic, or poorly structured report significantly …
FINANCE AND BANKING / by Miguel Gallardo Guerra In practice, it is common for financial institutions to confuse Anti-money Laundering and Countering the Financing of Terrorism (AML/CFT) auditing with supervision by the authority. Although both are related to regulatory compliance, they are not equivalent. They fulfill different functions and generate different consequences. Understanding this distinction …
FINANCE AND BANKING / by Miguel Gallardo Guerra The annual audit on Prevention of Money Laundering and Terrorist Financing (PLD/FT) constitutes an express regulatory obligation for financial entities subject to supervision by the Comisión Nacional Bancaria y de Valores. Pursuant to the applicable Guidelines governing the audit report, such report must be submitted within 60 …
FINANCE AND BANKING / by Miguel Gallardo Guerra As the financial landscape becomes more digital, regulatory compliance is evolving rapidly. It’s not just about adapting to new technologies, it’s about anticipating them. Looking ahead to 2026, here are some of the key trends shaping the future of legal compliance in Mexico and beyond: 1. Algorithmic …
FINANCE AND BANKING / by Miguel Gallardo Guerra The insurance sector has historically been one of the most conservative in adopting new technologies. However, in recent years, digitalization has significantly changed how insurers operate, issue policies, and interact with customers. One of the most notable advances has been the introduction of electronic signatures in the …
FINANCE AND BANKING / by Miguel Gallardo Guerra On October 30, 2025, the National Banking and Securities Commission (CNBV) published on its official website the draft “General Provisions Applicable to Payment Networks”, currently under public consultation. This project, developed in coordination with the Bank of Mexico (Banxico), seeks to transform the regulation of the card …
FINANCE AND BANKING / by Miguel Gallardo Guerra Artificial intelligence is rapidly transforming how financial institutions manage operations, risks, and compliance processes. From systems that detect suspicious transactions in real time to decision engines for credit scoring, AI is becoming a strategic tool in regulatory compliance. However, its use raises questions that go beyond technology …
