Key Findings Summary:

The good...

  • Mexico has a mature AML/CFT regime, with a correspondingly well-developed legal and institutional framework.
  • Most of the key authorities have a good understanding of ML and terrorist financing (TF) risks, and there is generally good policy cooperation and coordination.
  • Financial intelligence and other relevant information are made available by the financial intelligence unit (FIU) and accessed on a regular basis by competent authorities.
  • Overall, Mexico has a solid institutional and legal framework in place to investigate and prosecute TF and impose targeted financial sanctions (TFS).

The bad...

  • Confiscation of proceeds and instrumentalities is not systematically pursued as a policy objective, and not commensurate with the ML/TF risks.
  • A serious concern across all sectors is that beneficial owners are being identified only to a limited extent, systematically weighing on entities’ effectiveness in assessing and managing ML/TF risks.
  • The low conviction rate also points to a low degree of effectiveness in the way in which investigations are initiated.
  • Proceeds and instrumentalities of crime are rarely confiscated, and are not pursued as a policy objective.