Updating of the Financial Intelligence Unit´s Interpretation on Outsourcing Matter


The Mexican Financial Intelligence Unit (“UIF” for its acronym in Spanish), of the Treasury Ministry issued an interpretation regarding Outsourcing matter. The UIF considered this kind of activity, outsourcing, as a Vulnerable Activity under the Federal Act to Prevent and Identify Illegally-Funded Transactions, and therefore, subject of identification and reporting obligations.
To the query formulated by Basham, Ringe y Correa, S.C., regarding the treatment for the Corporate Group related to the interpretation on outsourcing matter; the UIF has informed -as a way of guidance solely- that when two or more companies or legal entities are part of the same Corporate Group, and between or among them, they render its professional services of outsourcing, it cannot be understood as a Vulnerable Activity under the Act aforementioned. This since Article 17 section XI of the Act establishes that the professional services rendering will be considered as Vulnerable Activity when they are independently performed.
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 delrio@basham.com.mx
Rodolfo Barreda rbarreda@basham.com.mx

Mexico City, November 14th 2016.