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The Guide to Corporate Compliance - First Edition

14. Anti Money Laundering and Counter-Terrorist Financing Law

Anti-money laundering (AML) and counter-terrorist financing (CTF) matters are of great relevance in Latin America. Several countries have adopted specific legislation, mostly following or trying to adapt to international practices and standards, such as those under the Financial Action Task Force (FATF) and its regional counterparts, and continue taking efforts to address their AML and CTF risks.

While some countries in the region have more developed and sophisticated rules than others, it is undeniable that money laundering continues to occur throughout the region. Efforts to prevent it, therefore, must be a source of concern in compliance programmes implemented by companies doing business in Latin American countries.

When talking about Latin America, companies must be aware that the reality in individual countries can be very different, not only regarding cultures and languages but, more importantly, regarding the relevant risks related to each market.

In that sense, AML compliance programmes implemented throughout Latin America must be country- and market-specific, according to local laws and peculiarities. Different risks and peculiarities may even vary in different regions of the same country.

The border area between Brazil, Paraguay and Argentina, for instance, has been identified as a high risk for money laundering. Because of the peculiarities of the region, an AML programme implemented in frontier cities would likely not be the same as one implemented in cities such as São Paulo, Asunción or Buenos Aires.

Nevertheless, as is discussed in this chapter, within a country- and region-specific approach, international cooperation and regionally established standards indicate common compliance checkpoints that could be useful for companies doing business throughout Latin America.

Specific issues and laws in Latin America

Latin American countries have historically faced serious issues with organised crime, drug trafficking and corruption. With the exception of Uruguay, the countries discussed in this chapter have achieved poor scores in the Corruption Perceptions Index, compiled by Transparency International.[2]

Specifically concerning money laundering and CTF, the performance of Latin American countries in the AML index released by the Basel Institute on Governance in 2019,[3] with some exceptions, are much more encouraging.

The Basel Institute provides risk scores based on the quality of a country’s AML and CTF framework, using data from publicly available sources such as the FATF, Transparency International, the World Bank and the World Economic Forum.

According to the Basel Institute ranking, Haiti is the Latin American country with the highest risk of money laundering and terrorist financing (sixth of 125 countries), followed by Paraguay (ranked 14th). Brazil is ranked 76th, with lower risk scores as compared to countries such as the United States and Japan. Chile and Uruguay are the highest ranked Latin American countries at 104th and 118th, respectively.

It is our perception that the improvement of AML systems in Latin America, evidenced by the aforementioned rankings, are strongly related to the participation of Latin American countries in international forums and groups and, consequently, their commitment to adopt international standards.

For instance, obligations and incentives to implement effective AML programmes have increasingly gained importance in Latin America in light of concepts such as gatekeepers[4] (professionals with the potential to identify illicit activities, owing to their function and duties in corporations), where private individuals have gradually experienced an increase in supervisory responsibilities.

Several Latin American countries are expanding AML obligations from the traditional financial sector operators to designated non-financial businesses and professionals (DNFBPs). In fact, as is discussed further in this chapter, much of the criticism that Latin American countries have received from organizations such as the Financial Action Task Force of Latin America (GAFILAT) is that they have not done enough to regulate and enforce regulations pertaining to DNFBPs.

The situation of DNFBPs is also an example of the continuing regulatory changes and innovations in AML compliance in Latin America. It should also be noted that these regulatory changes may also translate into compliance challenges for entities and individuals that are subject to AML obligations.

Institutions that conduct their services solely through the internet, for instance, and traditionally do not have face-to-face interactions with their customers, have to implement preventive measures procedures that, in certain countries, are almost identical to those imposed on businesses with more traditional customer relations, such as banks. Companies that render services through cellphones, for instance, are also facing similar challenges.

Questions such as how to conduct proper ‘know your customer’ procedures in those new environments, for example, have not been fully answered throughout Latin America.

Another topic that has been controversial throughout Latin America and is likely to spark debate is the inclusion of AML obligations for service providers, including attorneys and accountants. In some countries, AML obligations have been clearly defined; in others, AML regulations applicable to these services providers are yet to be enforced.

Several issues are recurrent in Latin America, while others are regional, in accordance to the situation in each country. We have selected four countries – Brazil, Uruguay, Colombia and Mexico – to illustrate the development of AML systems in Latin America.

Brazil

Brazil is a peculiar market in Latin America. Not only is there a language and cultural difference – the official language in Brazil is Portuguese whereas the majority of people in other countries speak Spanish – the size of its market and extension of its territory create additional AML challenges.

Although Brazil is historically marked by what could be called an endemic and institutionalised corruption problem, for the past few years, Brazilian authorities have intensified enforcement actions against companies doing business in Brazil that are involved corruption, including against foreign companies. This is mostly as a result of Operation Car Wash.

Operation Car Wash is a broad criminal investigation, initiated in 2014 by Brazilian federal law enforcement authorities (Federal Prosecutors and Federal Police) in the southern state of Paraná (city of Curitiba), that is focused on alleged acts of bribery and corruption. The Operation was originally based on contracts with state-owned oil company Petrobras. The reach of the investigations and related proceedings have extended beyond Petrobras, targeting several government employees, including high-ranking officials, congressmen, political parties, companies and related individuals.

Money laundering has a central role in this shift in law enforcement in Brazil for two main reasons. First, several of these investigations originated from intelligence reports by the Brazilian financial intelligence unit (FIU), and second because the corruption and financial investigations during the operation were often followed by money laundering allegations.

This has not always been the case.

Brazil’s Anti-Money Laundering Law (Law No. 9613/98 (the AML Law)) was implemented in 1998, defining the crime of money laundering as the concealment or disguise of the true nature, origin, location, disposition, movement or ownership of assets, rights and values that result directly or indirectly from a criminal offence.

Following international standards, the AML Law also provides a list of supervised actors (both legal and natural persons) on whom it imposes specific know your customer, record-keeping, monitoring and reporting administrative obligations. The specific obligations vary in accordance with specific regulations for individual markets, such as banks and financial institutions, jewellers, realtors and brokers.

AML obligations in Brazil are overseen by various organisations in respect of different markets, such as (1) the Brazilian Central Bank, for the financial market, (2) the Brazilian Securities Commission for the securities market and (3) the Superintendence of Private Insurance for the insurance market, among others. The competent regulating authorities are also responsible for enforcement and oversight of AML rules.

However, implementation of the AML Law had little effect on enforcement, in respect of both criminal investigations and AML obligations of private entities. It was not until 2003, with the creation of the National Strategy Against Corruption and Money Laundering (ENCCLA), a national network of Brazilian public authorities that aims to formulate and coordinate public policies, that Brazilian agencies intensified their enforcement efforts.

Annually, these authorities agree on a set of goals (Actions) and a working group is created to monitor the implementation of each of those Actions, by gathering empirical data, developing research, drafting bills or proposed regulations, among other things. For 2020, there are 11 Actions directed at reviewing and improving AML tools and controls that have been adopted.

In 2012, the AML Law underwent a relevant amendment through Federal Law No. 12863 of 2012, which eliminated the fixed list of predicated offences for the crime of money laundering and considerably broadened the list of businesses and professions subject to its administrative obligations, most of them DNFBPs.

On 1 October 2019, the National Justice Committee issued Regulation No. 88, regulating specific AML/CTF compliance requirements for notaries and registrars in Brazil.[5]

The business of notaries is highly unusual in Brazil as it involves a mixture of government and private sector functions. Notaries public are appointed by the government and, for several purposes under Brazilian law, are considered government officials. Concurrently, notaries public operate as private businesses and, among other attributions, they register all real estate transactions in the country, acting in fact as potential AML gatekeepers.

There are currently debates regarding how the AML regulation of notaries public will be enforced in Brazil. The regulation comes into force in February 2020 and many notaries are not yet aware of its existence; even those who aware are facing challenges regarding the implementation of an effective AML programme.

We have found that this is the case for several other regulated industries. The obligation of attorneys to report suspicious activities, for instance, is heavily debated. Although the legislative changes to the AML Law in 2012 imposed obligations on individuals and entities that provide consulting, accounting and auditing services, among others,[6] to date legal services have not been regulated to impose AML obligations under the terms of the Law.[7]

Another development in Brazil is that regulatory institutions such as the Brazilian Central Bank and the FIU are increasingly implementing AML regulations reflecting a risk-based approach. This policy provides greater flexibility for individuals and legal entities, by giving them the ability to implement AML programmes designed in accordance with their specific needs. However, the policy also increases the responsibility of those with AML obligations as they must conduct an effective risk analysis and enforce AML programmes accordingly.

Legislative and regulatory changes pertaining to AML and counter-terrorism legislation is likely to continue to develop in Brazil and it will be important for those doing business in the country to continuously monitor these changes.

Uruguay

As a regional financial centre, which has ‘regularly offered a number of attractive corporate and financial instruments for non-resident investors’,[8] Uruguay’s greatest threat in respect of money laundering is the proceeds of crimes committed abroad.

In fact, during the corruption investigations conducted in Brazil under Operation Car Wash, there have been several cases of concealment of proceeds of crime involving Uruguayan companies and financial institutions.

Uruguay has also recently experienced major changes in its AML legislation. In January 2018, Parliament approved a new Anti-Money Laundering Law (Law No. 19574 of 2018), which consolidates in one text all previous regulations relating to money laundering.

For compliance purposes, several relevant changes have been introduced. Law No. 19574 extends the list of predicate offences and the list of individuals and entities with AML obligations, ‘particularly certified public accountants, notaries, and non-profit organizations, such as political parties, churches, and soccer clubs’.[9]

The administrative obligations imposed on financial institutions are regulated by the Central Bank of Uruguay, whereas preventive measures applicable to DNFBPs are regulated by Decree 379/018, published in November 2018.

The inclusion of new entities with AML obligations under the law, including for the purposes of reporting suspicious activities, has opened a debate in Uruguay regarding professional privilege and confidentiality. Professional accountants, for instance, questioned their inclusion in the new law and consequent AML obligations.[10]

Uruguay was recently evaluated by GAFILAT. The Mutual Evaluation Report, issued on 22 January 2020,[11] has concluded that ‘national coordination and cooperation in anti-money laundering and counter terrorist financing is sound’.

Specifically regarding administrative obligations imposed on DNFBPs, the Report concluded that ‘there are DNFBPs that have a low level of reporting (accountants, lawyers, free trade zones, building companies, dealers in precious metals) and others that, due to their relevance in terms of risk, require improvement in the number and quality of reports (notaries, real estate agents, auctioneers and company service providers)’.[12]

Finally, as regards international cooperation, the Report concluded that ‘Uruguay has a legal and institutional framework that allows competent authorities to provide MLA and extraditions in a constructive manner’, but the country should focus on strengthening the ‘timely provision of international cooperation, particularly in terms of financial intelligence’.[13]

The efforts by Uruguay to improve its AML systems are corroborated by its position in the AML index release by the Basel Institute on Governance in 2019,[14] according to which Uruguay has the lowest AML risk in Latin America and one of the lowest in the world.

Colombia

The situation in Colombia reflects to a significant extent that of the majority of Latin America, with implementation of AML laws and procedures and their correlation with illicit drug-trafficking activities. Reports indicate that the production of cocaine in Colombia continues to be high,[15] which undeniably directly affects AML efforts and policies.

In 2016, Colombia produced its National Risk Assessment,[16] pursuant to FATF Recommendation No. 1 and concluded that it has a medium (0.57) risk of money laundering and terrorist financing. The threats raised by drug-trafficking, which reached an alarming high score of 0.90, continue to be of the most significant problems for the country.

These circumstances are also acknowledged by GAFILAT’s most recent evaluation of the country, which concluded in a report that the main threat in respect of money laundering is the proceeds generated by organised crime groups that perpetrate ‘drug trafficking, kidnapping, extortion and other crimes as sources of income’.[17]

Colombia initiated its AML efforts in the late 1990s. However, it was not until 2008 that the Financial Superintendency of Colombia passed Regulatory Circular 026 requiring financial institutions to implement internal money laundering prevention systems.[18]

As regards regulating AML obligations for professionals such as lawyers and accountants, in 2017, the Basic Legal Circular of the Superintendency of Corporations of Colombia modified by External Circular of 21 March 2017, extended AML obligations to companies deriving the majority of their profit from legal or accounting services with an annual gross income of 30 legal monthly minimum wages.[19]

An evaluation by GAFILAT in June 2017 found that ‘Colombia investigates and prosecutes ML effectively, but not in a manner that is commensurate with its ML risks’. It further concluded that ‘the AML/CFT supervisory systems and tools are not entirely in line with the risk-based approach, and there are significant gaps in the supervision of designated non-financial businesses and professions (DNFBPs)’.[20] According to the evaluation, ‘shortcomings were identified with respect to reporting attempted transactions among financial institutions and DNFBPs’ and ‘there are several categories of DNFBPs that, under the existing AML/CFT framework, are not considered reporting entities and are not subject to the AML/CFT obligations’.[21]

Despite the need for improvement, the US Department of Justice (Bureau of International Narcotics and Law Enforcement Affairs) has issued its International Narcotics Control Strategy Report in 2019, concluding that ‘Colombia has one of the strongest AML regimes in the region’.[22]

Mexico

Mexico ranks 130 of 180 in the Corruption Perceptions Index compiled by Transparency International,[23] with a low score of 29/100. In addition to corruption, Mexico has historically faced a serious problem in fighting drug-trafficking and organised crime. The most recent report by GAFILAT lists organised crime, corruption and tax evasion as the country’s main sources of illicit assets.[24]

The Mexican Anti-Money Laundering Law,[25] published on October 2012, came into force in 2013. The objective of the law is to ‘protect the financial system and national economy, establishing measures and procedures to prevent and detect acts or operations that involve illicit assets, though an interinstitutional coordination, that has as an end collect elements that are useful to investigate and prosecute the crimes of operations with illicit assets’.[26]

Among other aspects, the Law establishes what are called ‘Vulnerable Activities’, which include gambling, issuance of credit and debit cards, construction or development of real estate, commercialisation of jewellery and automobiles, notary services, among others.[27]

Those who carry out Vulnerable Activities are subject to AML obligations, including know your customer and reporting. [28]

In 2018, Mexican authorities, seeking to increase the conformity of individuals and entities subject to the AML Law, implemented a self-correction programme. This programme applied to activities carried out from July 2013 until December 2018 and included the possibility of waiving fines and penalties for those who were admitted.[29]

This was a noteworthy initiative by Mexican authorities to increase compliance with AML rules.

It will be important to monitor developments in Mexican AML rules and regulations and the effects of the self-correction programme, not only in terms of increased enforcement of entities and individuals that carry out Vulnerable Activities, but also in increased enforcement and supervision of competent government authorities.

International cooperation and regional bodies

International cooperation is ongoing and increasing in Latin America. Cases such as Operation Car Wash in Brazil have unveiled not only potential money laundering practices across borders in Latin America, but also the need for countries to exchange information, especially from their financial intelligence bodies.

International cooperation can take place through different global and regional channels in Latin America. Several countries are members of the Egmont Group, for instance, which is formed of 164 FIUs and provides a platform for the exchange of financial intelligence.[30]

In Brazil for instance, the exchange of intelligence information through the Egmont Group has assisted in relevant AML investigations.

The nature and admissibility as evidence of the intelligence information shared through FIUs through the Egmont Group, however, may be questioned in different jurisdictions.

The exchange of data through the Egmont Group is not regulated by a convention or international treaty, but solely through the internal norms and principle of the group, under the concept of ‘Soft Law’.[31] The formality of legal systems in certain countries in Latin America may challenge the submission of information obtained under what can be considered an informal system, as evidence in legal proceedings.

The exchange of information for purposes of investigating and prosecuting money laundering offences also occurs in Latin America through mutual legal assistance treaties such as the Interamerican Convention on Mutual Legal Assistance in Criminal Matters, the Interamerican Convention against Terrorism, the Interamerican Convention against Corruption, and potential bilateral treaties between different countries.

International cooperation in Latin America further takes place for purposes of technical assistance and definition of common regional standards through bodies such as GAFILAT and the Caribbean Financial Action Task Force (CFATF).

In 2000, GAFILAT (formerly GAFISUD) was created as a FATF regional counterpart to focus on Latin America issues. The organisation aims to enable Latin American countries to adapt their internal laws and regulations to FATF standards, as well as at promoting cooperation and exchange of information between these countries. Today, GAFILAT is composed of 17 countries: Argentina, Bolivia, Brazil, Chile, Colombia, Costa Rica, Cuba, Ecuador, Guatemala, Honduras, Mexico, Nicaragua, Panama, Paraguay, Peru, Dominican Republic and Uruguay.

In respect of the exchange of intelligence information, GAFILAT facilitates, for instance, memoranda of understanding (MOUs) between member countries. MOUs are agreements for cooperation and exchange of information entered into by regulating authorities in the different countries. The nature and purpose of MOUs can vary from the exchange of public information (i.e., regulatory information or data about companies) to the exchange of confidential information, for investigative purposes.[32] As mentioned in the discussion about the Egmont Group above, the exchange of confidential information through MOUs may raise legal questions in some Latin American jurisdictions, such as Brazil, regarding their admissibility as evidence in legal proceedings.

Similar to GAFILAT, the CFATF is a regional body of states and territories of the Caribbean region that have agreed to implement common counter-measures against money laundering and terrorism financing.[33] The CFATF was established as the result of two key meetings convened in Aruba and Jamaica in the early 1990s and currently has 25 members. It also is a FATF-style regional body and a platform for countries from the Caribbean basin to share technical information for the purpose of improving their AML systems.

The main objective of the CFATF is to achieve effective implementation of, and compliance with, FATF recommendations to prevent and eliminate money laundering, terrorist financing and proliferation financing.[34]

GAFILAT and CFATF, like FATF, have adopted the mutual evaluation process for implementing FATF recommendations.

Compliance checkpoints for companies

As indicated at the beginning of the chapter, AML compliance in Latin America should be country specific, considering the peculiarities and laws of each jurisdiction.

However, as has been discussed so far, most Latin American countries, much like countries in other parts of the world, are seeking to implement or adapt their local AML systems to global standards. In that sense, whether more elaborate and sophisticated, local laws and systems follow the FATF recommendations and other international standards. Hence, different AML rules and procedures throughout the region are generally based on the same principles.

Therefore, it is our opinion that, aside from identifying local laws and obligations, it is key for companies doing business in the region to understand the specific AML risks of each country and territory and implement AML programmes that, as much as possible under local laws, are based on those specific risks. This is in line with the FATF concept of risk-based approach (RBA).[35]

Also in line with RBA, companies that do business in Latin America must be aware of the potential regulation of their activities and specific AML obligations under that regulation. This understanding will be more or less straightforward depending on the area of activities of the company and the country in which they are operating.

As discussed above, there may be specific local debates regarding the application of AML obligations in particular markets and activities as is the case with accounting and legal services providers, among other DNFBPs.

Another important consideration for AML programmes is the potential individual liability of compliance officers and others responsible for the implementation and effectiveness of compliance programmes.

Under Brazil’s AML law, for instance, managers of legal entities who are found responsible for non-compliance with AML rules may be subject to sanctions that include a warning, a financial fine and a ban, for up to 10 years, on acting as a manager of legal entities subject to AML regulations.[36]

In that sense, some Latin American countries allow for AML programmes to be outsourced in whole or in part. In general, even where outsourcing is allowed, following FATF standards, the liability of the individual or legal entity is not outsourced, meaning that the individual or legal entity will be held liable for violations of obligations, even if conducted by an external service provider.

Finally, as demonstrated in the country-specific discussions above, changes in the AML and counter-terrorism systems in different Latin American countries are ongoing. Countries are seeking compliance with FATF recommendations and other international standards while confronting internal enforcement challenges and debates. It is therefore important for those doing business, or intending to do business, in Latin America to constantly monitor legislative and regulatory developments in the different countries.

In light of the foregoing, aside from country-specific requirements and regulations, effective AML programmes in Latin America should include the general standards established under the FATF recommendations, most importantly: (1) assessing risks and applying a risk-based approach, as discussed throughout this chapter; (2) customer due diligence, which includes the concept of knowing your customer and the true beneficial owner, and record-keeping; (3) monitoring and reporting suspicious transactions; and (4) internal controls.

Although obligations such as reporting and related procedures will differ according to the competent jurisdictions, general principles such as confidentiality obligations and concepts such as politically exposed persons should not vary greatly.

Finally, irrespective of local obligations and the specific aspects of different regulations, an effective AML compliance programme will seek to detect potential acts of money laundering or ‘indications’ of potential acts of money laundering within an organisation, in accordance with the knowledge that the entity has of its business and the market within which it operates.

Therefore, in essence, an effective compliance programme in Latin America will not differ from those implemented in other parts of the world, so long as international principles are applied to the risks and requirements specific to that country and that market.


[1] Ana Maria Belotto is a consultant and Antenor Madruga and Mariana Tumbiolo are partners at FeldensMadruga.

[2] ‘Corruption Perceptions Index 2019’ < https://www.transparency.org/cpi2019> (last accessed 27 January 2020). On a scale from 0 to 100, Mexico scored 29, Brazil scored 35 and Colombia scored 37 points.

[4] Financial Action Task Force [FATF], ‘Report on Money Laundering Typologies 2003-2004’, p. 28 < https://www.fatf-gafi.org/media/fatf/documents/reports/2003_2004_ML_Typologies_ENG.pdf>.

[5] Association of Notaries and Registrars of Brazil, Provision No. 88/2019 < https://www.anoreg.org.br/site/2019/10/01/provimento-no-88-2018-dispoe-sobre-procedimentos-extrajudiciais-no-combate-a-lavagem-de-dinheiro/> (last accessed 20 January 2020).

[6] Brazilian Federal Law No. 9613 of 1997 (Anti-Money Laundering Law) [AML Law], Article 9, XIV.

[7] Note that under Brazil’s AML Law, its terms will only become binding on individuals and entities subject to AML obligations once competent regulatory authorities regulate its terms.

[8] ‘Mutual Evaluation Report of the Eastern Republic of Uruguay’ < https://www.gafilat.org/index.php/es/biblioteca-virtual/miembros/uruguay-1/evaluaciones-mutuas-16/3726-mer-uruguay-jan-2020/file> (last accessed 27 January 2020).

[9] ‘International Narcotics Control Strategy Report’, 2018, Volume II: Money Laundering and Financial Crimes, US Department of State < https://uy.usembassy.gov/wp-content/uploads/sites/113/INCSR-2-Uruguay_English-VII.pdf>.

[10] ‘La historia tras el lío entre los contadores y el gobierno’, El País Uruguay < https://negocios.elpais.com.uy/noticias/historia-lio-contadores-gobierno.html> (last accessed 27 January 2020).

[11] ‘Mutual Evaluation Report of the Eastern Republic of Uruguay’ (footnote 8, above), p. 5.

[12] id., at p. 9.

[13] id., at p. 12.

[14] ‘Basel AML Index 2019: A country ranking and review of money laundering and terrorist financing risks around the world’ < https://www.baselgovernance.org/sites/default/files/2019-08/Basel%20AML%20Index%202019.pdf> (last accessed 27 January 2020).

[15] ‘Colombia’s Coca Acreage for Cocaine Production at All-Time High’, The New York Times, 20 September 2018 < https://www.nytimes.com/2018/09/20/world/americas/cocaine-colombia.html> (last accessed 27 January 2020) and ‘Colombia’s Drug Trade’, Colombia Reports, 12 January 2019 < https://colombiareports.com/colombia-drug-trafficking/>(last accessed 27 January 2020).

[16] ‘National Assessment of the Risk of Laundering of Assets and Financing of Terrorism: Executive Summary’ < https://www.uiaf.gov.co/sistema_nacional_ala_cft/evaluaciones_nacionales_riesgo/evaluacion_nacional_riesgo_2016&download=Y> (last accessed 27 January 2020).

[18] Sistema de Administración del Riesgo de Lavado de Activos y de la Financiación del Terrorismo (SARLAFT). See also Pablo Slutzky, Maurcio Villamizar-Villegas and Tomas Williams, ‘Drug Money and Bank Lending: The Unintended Consequences of Anti-Money Laundering Policies’, Institute for International Economic Policy Working Paper Series, Elliott School of International Affairs, The George Washington University (March 2019) < http://www2.gwu.edu/~iiep/assets/docs/papers/2019WP/WilliamsIIEP2019-5.pdf> (last accessed 27 January 2020).

[19] ‘Implementing the OECD Anti-Bribery Conventio. Phase 3 Report: Colombia’ (December 2019) < http://www.oecd.org/corruption/Colombia-Phase-3-Report-ENG.pdf> (last accessed 27 January 2020).

[20] ‘Mutual Evaluation Report of Colombia’ (footnote 17, above).

[21] id., at p. 13.

[22] ‘International Narcotics Control Strategy Report– Volume II: Money Laundering’ (March 2019), US Department of State < https://www.state.gov/wp-content/uploads/2019/03/INCSR-Vol-INCSR-Vol.-2-pdf.pdf> (last accessed 27 January 2020).

[23] ‘Corruption Perceptions Index 2019’ (footnote 2, above).

[24] ‘Mutual Evaluations Report: Anti-money laundering and anti-terrorist measures – Mexico’ < https://www.gafilat.org/index.php/es/biblioteca-virtual/miembros/mexico/evaluaciones-mutuas-10> (last accessed 27 February 2020).

[25] Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita.

[26] id., at Article 2.

[27] id., at Article 17.

[28] id., at Article 18.

[29] ‘SAT da plazo a actividades vulnerables para cumplir con ley antilavado’, El Economista (22 April 2019) < https://www.eleconomista.com.mx/economia/SAT-da-plazo-a-actividades-vulnerables-para-cumplir-con-ley-antilavado-20190422-0067.html> (last accessed 27 January 2020).

[30] < https://egmontgroup.org/en> (last accessed 27 January 2020).

[31] Adriano Teixeira, Carlos Whers and Antenor Madruga, ‘The Procedural Value of Financial Intelligence Information Obtained through the Egmont Group’, Jornal de Ciências Criminais, Vol.2, No. 2, pp. 7 to 30 (December 2019).

[33] < https://www.cfatf-gafic.org/> (last accessed 20 January 2020).

[34] ‘CFATF Annual Report 2017-2018’ < https://www.cfatf-gafic.org/home/cfatf-overview/cfatf-annual-reports/11214-annual-report-2017-2018/file> (last accessed 27 January 2020).

[36] AML Law, Article 12, III.

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The Guide to Corporate Compliance - First Edition