Obligation to identify clients
Possibility of carrying out digital onboarding
Characteristics of transactions subject to digital onboarding

This article discusses anti-money laundering (AML) provisions for financial entities, their obligation to identify clients, the possibilities to carry out digital onboarding, the characteristics of such transactions and the process that must be followed.

Obligation to identify clients

The main AML measure that financial entities must comply with is to design a client identification policy. This policy must be part of their compliance manual, a document in which the financial entities describe how they will comply with all AML provisions.

The client identification policy includes different obligations. The main obligation is to integrate and keep an identification file of each client before carrying out any operation. The integration of the identification files must fully comply with the requirements of AML provisions and varies depending on the type of financial entity and the type of client.

Possibility of carrying out digital onboarding

Currently, AML provisions allow financial entities to carry out digital onboarding processes to identify their clients, establishing different requirements that must be fully complied with and respecting certain limits for operations.

For most financial entities, digital onboarding has been regulated in Annex 2 of their AML provisions, except for banks and insurance and bonding entities, which regulate this matter in their prudential provisions.

The National Banking and Securities Commission (CNBV) mainly supervises and authorises these processes, but the National Insurance and Bonding Commission (CNSF) may also be involved.

In general terms, the digital onboarding processes established by the CNBV are similar; however, there are certain distinctive characteristics for each type of financial entity, and for some of them it is not yet possible to carry out digital onboarding. This is the case for:

  • general warehousing and retirement fund administrators;
  • investment companies specialised in retirement funds; and
  • currency exchange centres.

Characteristics of transactions subject to digital onboarding

The type of operations in which financial entities may carry out digital onboarding processes vary depending on the type of entity. Many of them have limited their operations to individuals and/or legal entities that are only of Mexican nationality and are considered low risk in relation to low transaction amounts.


The processes that financial entities should follow when carrying out the digital onboarding for their clients require CNBV or CNSF authorisation and vary depending on the financial entity. Some entities have the possibility of performing "simplified processes" for certain types of operations, while others must always perform "complete processes". Generally, however, the usual processes include the following:

  • requesting the general positioning system of the mobile device from which the operation is being performed;
  • obtaining consent through an electronic signature or an advanced electronic signature;
  • sending information and identification documentation;
  • taking a selfie;
  • verifying identification documents through the records of the National Electoral Institute (INE);
  • verifying the unique key of population registry through the National Population Registry;
  • conducting biometric verification of the photographs sent by the client (through any Mexican authority, eg, INE records);
  • conducting real-time communication with the client to identify any type of suspicious behaviour; and
  • obtaining proof that the client is alive.

For further information on this topic please contact Sofía Rojas Cuellár or Rodrigo Ramos Hopkins at Ramos, Ripoll & Schuster ​by telephone (+52 55 1518 0445) or email ([email protected] or [email protected]). The Ramos, Ripoll & Schuster website can be accessed at www.rrs.com.mx.