Financial Crime World

Mexico’s Bank Secrecy Act Regulations Impose Restrictions on US Currency Transactions

Mexico’s financial authorities have introduced new regulations to combat money laundering and terrorist financing by imposing restrictions on transactions involving US currency. These changes, which took effect earlier this month, will impact the operations of Mexican banks and may have significant implications for US financial institutions.

Overview of the New Regulations

The Financial Crimes Enforcement Network (FinCEN) issued an advisory in June outlining the new anti-money laundering (AML) regulations. The restrictions apply to transactions involving cash denominated in US dollars received by Mexican banks from individuals or legal entities.

Types of Transactions Affected

  • Cash transactions: Restrictions are placed on the amount of cash denominated in US dollars that Mexican banks can receive.
  • Non-cash transactions: Wire transfers and credit card payments are unaffected.

Effective Dates

  • Restrictions on transactions involving individuals took effect four business days after official publication, on June 16.
  • Restrictions on transactions involving legal entities and trusts will come into force 90 calendar days later, around September 14.

Purpose of the Regulations

The Mexican government introduced these measures to mitigate the risks of laundering proceeds from narcotics trafficking and organized crime. The changes may have a significant impact on US financial institutions, both directly and indirectly, as they may lead to changes in transaction activity and relationships with Mexican customers and financial institutions.

Implications for US Financial Institutions

  • Anticipate changes in transaction activity.
  • Consider the potential impact of these restrictions when reviewing financial activity and monitoring transactions.
  • Take into account other information such as transaction volumes and sources of funds when determining whether to file a suspicious activity report.

For more information on this topic, contact your examiner-in-charge or the OCC Compliance Policy Department at (202) 649-5740.