How can we develop an effective risk-based approach to AML/CFT?

BANKING AND FINANCE / by Miguel Gallardo Guerra

Based on my experience as a lawyer in the financial and regulatory sector, one of the most critical—and least understood in practice—obligations is the development of a risk-based methodology that aids in the identification, assessment, measurement, and mitigation of money laundering and terrorist financing risks.

At Bello Gallardo Bonequi y García, S.C. (“bgbg”), we assist various financial institutions with this process. The challenge? Translating regulations into a functional, up-to-date, and automated control and compliance system. To achieve this, we recommend addressing the following key elements:

Risk identification: Beyond the regulatory framework, it is essential to map operational processes and consider risk factors and variables such as: product type, customer, channel, geographic region, country, and, increasingly, technological infrastructure.

Measurement: We have designed a clear and efficient calculation method to assess the level of risk associated with each client and the institution, taking into account statistics, probability of occurrence, transaction profiles, and risk variables linked to client characteristics and the institution’s operations…

Mitigation: We implement internal controls tailored to the institution’s risk profile, ranging from corporate governance and auditing to AML/CFT training programs.

Implementation and updating: A methodology is not static. It must be updated at least every 12 months to address new risks, regulatory changes, and developments in the financial ecosystem (including fintech and cryptoassets).

Updating, automating, and standardizing this methodology not only makes it easier to use but also strengthens regulatory and reputational compliance with supervisory authorities.

In an increasingly digital and demanding environment, having a robust risk-based methodology is not optional—it is a strategic differentiator.

Does your organization already have a truly risk-based approach?

Learn more about how we can help you at bgbg.mx or email me at mgallardo@bgbg.mx or dmacias@bgbg.mx