The communication instructed those parties that perform vulnerable activities… to document all events that may cause delays in the filings of the notices. 

The Financial Intelligence Unit (Unidad de Inteligencia Financiera) of Mexico’s Tax Administration Service (Servicio de Administración Tributaria) (SAT) issued a communication relating to potential delays in the compliance of the provisions set forth in the Mexican Anti-Money Laundering Law (Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita) as a consequence of the COVID-19 pandemic.

The communication instructed those parties that perform vulnerable activities as described in article 17 of the Anti-Money Laundering Law to document all events that may cause delays in the filings of the notices of vulnerable activities contemplated by the law so that, if necessary, these parties may request an authorization from the SAT to implement a “Self-Regulation Program” which will include the activities performed as of March 1, 2020, and until the contingency measures decreed by the Mexican government are lifted.

The activities deemed as vulnerable by the Anti-Money Laundering Law are the following:

1. Gambling, contests or raffles.
2. Issuance or commercialization of service, credit or prepaid cards that constitute monetary value storage instruments.
3. Issuance of traveler’s checks from entities other than financial institutions.
4. Mutual or guarantee operations, granting loans or credits, with or without guarantees from institutions other than financial entities.
5. Merchandising or intermediation of precious metals, precious stones, jewelry or watches.
6. Auction or commercialization of works of art.
7. Merchandising or distributing air, sea or land vehicles, new or used.
8. Shielding land vehicles or properties, new or used.
9. Transfer services or custody of money.
10. Construction, development or intermediation of properties.
11. Providing professional services.
12. Providing public/legal services.
13. Receiving donations from associations and nonprofit societies.
14. Providing foreign trade services as an agent or customs agent.
15. Constitution of rights of use or enjoyment of real estate (monthly value).
16. Exchange of virtual assets from subjects other than financial entities.

About Duane Morris

Duane Morris has created a COVID-19 Strategy Team to help organizations plan, respond to and address this fast-moving situation. Contact your Duane Morris attorney for more information. Prior Alerts on the topic are available on the team’s webpage.

For More Information

If you have any questions about this Alert, please contact Eduardo Ramos-Gómez, Rosa M. Ertze, Miguel de Leon Perez, any of the attorneys in our Mexico Business Group, any member of the COVID-19 Strategy Team or the attorney in the firm with whom you are regularly in contact. 

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.