Financial Intelligence Unit´s Interpretation on Outsourcing Services


Recently, the Mexican Financial Intelligence Unit (“UIF” for its acronym in Spanish), of the Treasury Ministry issued an interpretation regarding Outsourcing services. The UIF considered Outsourcing Services as a Vulnerable Activity under the Federal Act to Prevent and Identify Illegally-Funded Transactions (“Act”)
According to the referred interpretation, the render of independent professional services, on behalf and in representation of the client, for the administration and/or management of resources of the contracted service, is considered as Vulnerable Activity pursuant the Act.
As been considered as Vulnerable Activity, the operations of companies providing Outsourcing services, shall be subject of identification and report/notice, as established in the Act; highlighting that the identification as well as the report of the activities, shall be perform without exemptions, since there is no threshold provided by the Act.
Notwithstanding the foregoing, several opposite criteria derives from the Interpretation issued by the UIF, regarding if shall be subject to the referred provision, those companies that belongs to a Corporate Group and render its professional outsourcing services to another company of the same Corporate Group.
Experts on Administrative and Anti-Money Laundering Law are available to any further query or comments that may arise to the above.

Daniel Del Rio Loaiza
Rodolfo Barreda Alvarado

Mexico City, November 3rd 2016.