Certificación CNBV en materia de PLD/FT (Mexico)

In the classic three-stage model of money laundering used in CNBV and GAFI training materials, which sequence correctly describes the stages?

• AStructuring (pitufeo), concealment of the source, and repatriation of the funds
• BCustomer identification, reporting to the FIU, and freezing of assets
• CPlacement, layering and integration
• DPredicate offense, criminal conviction and confiscation of proceeds

A criminal group has several people deposit cash in amounts just below reporting thresholds into different bank accounts on the same day. Which laundering stage does this conduct mainly represent?

• APlacement
• BLayering
• CIntegration
• DNone, because deposits below the reporting threshold fall outside the laundering offense

Under Article 400 Bis of the Código Penal Federal (CPF), what is the basic penalty for the offense of operaciones con recursos de procedencia ilícita?

• A3 to 10 years in prison and 500 to 2,000 días multa
• B15 to 40 years in prison and a fine of 400 to 1,200 times the daily UMA value
• C1 to 9 years in prison and 100 to 300 días multa
• D5 to 15 years in prison and 1,000 to 5,000 días multa

A bank branch manager knowingly helps a client move fraud proceeds through the bank. Under Article 400 Bis 1 of the CPF, how does the manager's position affect the penalty?

• AThe penalty is doubled, because bank employees are treated as public servants responsible…
• BPenalties rise by one third up to one half, plus disqualification for a period equal to t…
• CNo effect: Article 400 Bis 1 increases penalties only for public servants and former publ…
• DThe penalty is reduced by one third if the bank itself later files an unusual-operation r…

Under Article 400 Bis of the CPF, as reformed in July 2025, what rule applies when the laundering conduct used the services of financial-system institutions?

• AOnly the CNBV may investigate these conducts, and it files the criminal complaint directl…
• BThe Ministerio Público may investigate only after the UIF places the suspect on the Lista…
• CThe Ministerio Público may always investigate, but criminal action requires an SHCP denun…
• DNo special rule applies: the offense is prosecuted ex officio, without any SHCP denuncia…

For the money laundering chapter of the CPF, when are resources considered 'producto de una actividad ilícita'?

• AWhen there are well-founded indications or certainty that they come from a crime and thei…
• BOnly when a final criminal judgment has already convicted someone of the predicate offens…
• CWhenever they are cash amounts equal to or above USD 7,500, because that is the legal pre…
• DOnly when they come from offenses the CPF lists as predicate crimes, such as drug traffic…

Which statement about terrorist financing under Article 139 Quáter of the CPF is correct?

• AIt applies only if the funds come from criminal activity, as with the laundering offense…
• BIt carries the same penalty as laundering under Article 400 Bis: 5 to 15 years in prison…
• CIt applies only once a terrorist act financed with the funds has actually been committed…
• DIt punishes providing or collecting funds of any origin, knowing they will support terror…

What conduct does Article 139 Quinquies of the CPF punish with 1 to 9 years in prison and 100 to 300 días multa?

• AFailing to send a 24-hour report to the SHCP through the CNBV when terrorist financing is…
• BConcealing a person who took part in terrorist financing under Article 139 Quáter
• CPaying for real estate in cash above the limit in Article 32 of the LFPIORPI
• DTelling a client that an unusual transaction report was filed about their operations

The CNBV's 2020 guide on detecting illicit-origin transactions derived from corruption cites Transparency International's definition of corruption. What is that definition?

• AAny transaction above the Operación Relevante threshold carried out by a public servant
• BAn entity's failure to report unusual transactions within the legal deadline
• CThe abuse of entrusted power for private gain
• DAny cash payment made to a government agency

Which GAFI Recommendation requires countries to implement targeted financial sanctions to comply with UN Security Council resolutions on preventing the proliferation of weapons of mass destruction and its financing (FPADM)?

• ARecommendation 7
• BRecommendation 10
• CRecommendation 16
• DRecommendation 29

What kind of body is the Grupo de Acción Financiera Internacional (GAFI/FATF)?

• AA United Nations specialized agency whose recommendations automatically become binding la…
• BA private association of global banks that publishes voluntary anti-money-laundering prin…
• CThe international network of financial intelligence units that exchanges case information…
• DAn intergovernmental body, created in 1989, that sets the 40 Recommendations and evaluate…

What does GAFI Recommendation 1 require of countries and financial institutions?

• AApply identical due diligence to every customer so that no customer is treated differentl…
• BIdentify, assess and understand their ML/TF risks and apply measures proportionate to them
• CTerminate every business relationship with customers who present above-average ML/TF risk
• DLeave risk assessment to supervisors, who assign each customer's risk level on the instit…

According to GAFI Recommendation 10, in which circumstances must a financial institution carry out customer due diligence (CDD)?

• AOnly when opening credit products with terms longer than three years, because deposits ca…
• BOnly when a customer sends a cross-border wire transfer above USD 50,000 or its equivalen…
• CWhen starting a relationship, for occasional transactions above the threshold, on suspici…
• DOnly after a judicial order or a formal request from the financial intelligence unit is r…

Under GAFI Recommendation 12, which measures must a financial institution apply to foreign politically exposed persons (PEPs), in addition to normal CDD?

• ADetermine PEP status, get senior management approval, establish source of wealth and fund…
• BFreeze the PEP's accounts as a precaution and report them to the financial intelligence u…
• CObtain a guarantee from the PEP's home government certifying the legitimate origin of all…
• DRefuse all business relationships with foreign PEPs and their relatives, because no enhan…

How does GAFI Recommendation 12 treat domestic PEPs and persons entrusted with prominent functions by international organizations, compared with foreign PEPs?

• AThey are exempt from PEP measures, because domestic anti-corruption authorities already o…
• BThey must be reported to the financial intelligence unit as suspicious whenever they open…
• CThe enhanced measures that apply to foreign PEPs apply to them only after they have left…
• DEnhanced measures apply when the relationship is higher risk; for foreign PEPs they apply…

What is the core requirement of GAFI Recommendation 16 on wire transfers?

• AIncoming transfers must be converted into local currency within 24 hours of reaching the…
• BOriginator and beneficiary information must be obtained and travel with the transfer alon…
• CEach cross-border transfer must be cleared in advance by the central bank of the destinat…
• DInstitutions must keep a paper receipt signed by the sender and the recipient for each in…

Under GAFI Recommendation 21, what are financial institutions, their directors and their employees prohibited from doing?

• ADisclosing that a suspicious transaction report or related information was filed with the…
• BFiling a suspicious transaction report with the FIU without first obtaining the customer'…
• CDeclining to carry out a transaction that they consider suspicious
• DInforming the compliance officer or the compliance committee about an internal alert on a…

Under GAFI Recommendation 6 on targeted financial sanctions related to terrorism and terrorist financing, how must freezing measures be applied?

• AAfter notifying the designated person 48 hours in advance so they can challenge the desig…
• BOnly once the designated person has been charged and then convicted by a final judgment o…
• CWithout delay and without prior notice, to comply with UN Security Council resolutions su…
• DOnly to state-owned enterprises of countries that are not GAFI members or regional-body m…

Under GAFI Recommendation 13 on correspondent banking, which relationship must a financial institution refuse to enter into or continue?

• AAny relationship with a respondent bank located in a jurisdiction under GAFI increased mo…
• BAny relationship with a respondent bank that itself provides correspondent services to ot…
• CAny relationship with a respondent bank that has no rating from an international credit r…
• DAny relationship with a shell bank that has no physical presence where it is incorporated

What does GAFI Recommendation 15 require regarding virtual assets and virtual asset service providers (VASPs)?

• AProhibit virtual assets and every related service, because their pseudonymity cannot be m…
• BEnsure VASPs are licensed or registered, supervised, and apply CDD, reporting and the tra…
• CApply CDD to VASP customers only when their transactions exceed USD 15,000, as for other…
• DRely on the transparency of public blockchains instead of requiring VASPs to identify and…

What standard do GAFI Recommendations 24 and 25 set for the beneficial ownership of legal persons and legal arrangements such as trusts (fideicomisos)?

• AAccurate, current beneficial ownership information must be available to authorities in a…
• BBeneficial ownership must be identified only when a company is dissolved or enters bankru…
• CBearer shares remain acceptable as long as the company files its tax returns and pays its…
• DBeneficial ownership information is required for trusts and similar arrangements, but not…

What is the difference between GAFI's 'high-risk jurisdictions subject to a call for action' (black list) and 'jurisdictions under increased monitoring' (grey list)?

• AGrey-list inclusion obliges GAFI members to terminate every correspondent banking relatio…
• BGrey-list jurisdictions face GAFI countermeasures, while black-list jurisdictions are onl…
• CBoth lists are permanent: once a jurisdiction is included, GAFI never removes it
• DBlack list: enhanced due diligence and, if serious, countermeasures; grey list: countries…

In a GAFI mutual evaluation, what is the difference between the 'technical compliance' assessment and the 'effectiveness' assessment?

• ATechnical compliance measures crime, prosecution and conviction statistics, while effecti…
• BPrivate audit firms assess technical compliance, and the evaluated country assesses its o…
• CTechnical compliance checks the legal and institutional framework; effectiveness checks r…
• DTechnical compliance applies to financial institutions, and effectiveness applies only to…

What is the Egmont Group, of which Mexico's UIF is a member?

• AThe intergovernmental body that issues the 40 Recommendations and conducts mutual evaluat…
• BAn international forum of FIUs, including Mexico's UIF, for cooperation and secure inform…
• CA supervisory college that inspects international banks' AML programs on behalf of centra…
• DAn association of global banks that publishes principles on private and correspondent ban…

What is the Wolfsberg Group known for in the AML/CFT field?

• AAn association of global banks that publishes financial crime guidance, such as its corre…
• BThe committee of central banks and supervisors that issues the Basel Core Principles for…
• CThe GAFI-style regional body that conducts mutual evaluations of Latin American countries
• DThe UN Security Council body that maintains the ISIL (Da'esh) and Al-Qaida sanctions list

What is GAFILAT, and how is Mexico related to it?

• AA regional anti-corruption treaty that replaced the UN Mérida Convention for Latin Americ…
• BThe regional office of Mexico's UIF that coordinates intelligence with Central American F…
• CA private body that certifies compliance officers in Latin America, including Mexico's CN…
• DThe GAFI-style regional body for Latin America; Mexico belongs to it and is also a full G…

What was the main contribution of the 1988 UN Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (Vienna Convention) to AML law?

• AIt created the Egmont Group of financial intelligence units to exchange information on dr…
• BIt set a worldwide cash limit of USD 10,000 per transaction for drug-producing and transi…
• CIt was the first treaty requiring states to criminalize the laundering of drug-traffickin…
• DIt extended the laundering offense to the proceeds of all serious crimes, not only drug t…

How did the 2000 UN Convention against Transnational Organized Crime (Palermo Convention) expand AML law?

• AIt limited laundering predicate offenses to terrorism and the financing of terrorist orga…
• BIt required applying the laundering offense to the widest range of predicate offenses, in…
• CIt required each country to create its financial intelligence unit within its armed force…
• DIt was the first treaty to oblige states to criminalize the laundering of drug-traffickin…

Which functions correspond to the Unidad de Inteligencia Financiera (UIF)?

• AAn SHCP unit that analyzes reports, produces financial intelligence, manages the blocked-…
• BA CNBV unit that inspects banks and imposes administrative fines when they fail to meet t…
• CAn autonomous federal court that hears money laundering cases and issues convictions and…
• DThe certifying authority that examines and certifies compliance officers and external aud…

What is the CNBV's role in Mexico's PLD/FT regime?

• AProsecuting money laundering offenses before federal criminal judges on behalf of the SHCP
• BReceiving and analyzing the monthly avisos that notaries, real estate agents and other Ac…
• CDeciding which persons are included in, or removed from, the Lista de Personas Bloqueadas
• DSupervising its financial entities' PLD/FT compliance, sanctioning breaches and certifyin…

In the LFPIORPI regime for Actividades Vulnerables, which authority receives the avisos and verifies compliance?

• AThe CNBV, through its PLD supervision units, which also inspect Actividades Vulnerables
• BThe Fiscalía General de la República, through its financial crimes unit
• CThe SHCP, through the SAT's electronic system; the SAT runs verification visits
• DBanco de México, through its payment systems area

Which authorities supervise PLD/FT compliance in the insurance and retirement savings sectors?

• AThe CNSF for insurers and sureties, and CONSAR for AFOREs
• BThe CNBV for both sectors, as the single financial supervisor
• CCONDUSEF for both sectors, as part of its user-protection powers
• DBanco de México for insurers and the IMSS for AFOREs

How is Mexico's regime for preventing illicit-origin transactions organized?

• AA single law, the LFPIORPI, governs both banks and non-financial businesses, and the CNBV…
• BFinancial entities follow sectoral laws and DCG; non-financial Actividades Vulnerables fo…
• COnly banks have mandatory AML obligations; the rest of the financial sector participates…
• DNon-financial businesses apply the banking DCG, but with lower thresholds and simplified…

According to the 1st provision of the DCG under Article 115 of the Ley de Instituciones de Crédito (DCG Bancos), what is the purpose of these Disposiciones?

• ATo set the capital that banks must hold against credit, market and operational risk, incl…
• BTo set minimum measures to prevent and detect acts linked to CPF Articles 139 Quáter or 4…
• CTo regulate the fees banks may charge for cash deposits and to limit the use of cash in t…
• DTo define the criminal offenses and penalties that apply when laundering is committed thr…

How do the DCG Bancos distinguish a 'Cliente' from a 'Usuario'?

• AA Cliente is a Mexican national and a Usuario is a foreign national who operates occasion…
• BA Cliente may pay only in cash at branches, while a Usuario must use a debit or credit ca…
• CThe terms are interchangeable, and the same identification rules apply to both types of c…
• DA Cliente has a contractual relationship with the entity; a Usuario operates without a pe…

Under the 4th provision of the DCG Bancos, what must the identification file of a Mexican natural-person Cliente include?

• AIdentification data (name, birth details, nationality, occupation, address, CURP, RFC) pl…
• BOnly the customer's full name, date of birth and a signature sample, as for any demand-de…
• CA credit bureau report and two personal references, in addition to the customer's officia…
• DThe customer's tax returns for the last three years and a notarized statement of assets a…

When opening an account for a Mexican company (persona moral), which information is essential for its identification file under the DCG?

• AThe resumes of all its employees and the company's product catalog, to confirm the busine…
• BOnly the company's RFC and tax-status certificate, because the SAT has already verified i…
• CCompany and incorporation data, RFC, address, representatives' powers and IDs, and who co…
• DA letter of recommendation from another bank that has already identified the company's ow…

Before starting a business relationship with a Cliente in person, what does the 7th provision of the DCG Bancos require?

• AA telephone call to the customer's employer to confirm their employment and declared inco…
• BA face-to-face interview with the customer or its representative, with the results record…
• CApproval of the new account by the Comité de Comunicación y Control at its monthly session
• DA prior consultation with the UIF to confirm the customer is not under investigation

Which prohibition does the 10th provision of the DCG Bancos establish?

• AEntities may not keep anonymous or fictitious-name accounts, or accounts whose Cliente or…
• BEntities may not open accounts for foreign nationals who lack permanent or temporary resi…
• CEntities may not accept any cash deposits from companies, whether in pesos or in foreign…
• DEntities may not open more than one demand-deposit account per customer at the same insti…

Under the 14th Bis provision of the DCG Bancos, which features describe a 'nivel 1' demand-deposit account opened by a natural person?

• AUp to 3,000 UDIs of deposits per month, with the full identification file and copies of d…
• BUnlimited deposits, as long as the account receives only payroll payments from a single e…
• CUp to 750 UDIs of credits per month, a 1,000 UDI maximum balance, and a file with only na…
• DA maximum balance of USD 1,000, with identification documents required only for foreign c…

A bank applies simplified identification to low-risk products. When does the 10th Bis provision of the DCG Bancos prohibit using those simplified measures?

• AWhen the customer is under 25 years old and has no prior credit or deposit history with t…
• BWhen there is a well-founded suspicion that the resources relate to Articles 139 Quáter o…
• CWhen the customer opens the account at a branch rather than through the mobile application
• DWhen the account is denominated in pesos rather than in US dollars or another foreign cur…

During onboarding, an analyst reasonably believes that continuing to request documents would alert the prospective customer that the bank suspects laundering. What does the 10th Ter provision of the DCG Bancos allow?

• AOpen the account anyway, and decide at the next Comité session whether an unusual report…
• BAsk the customer to explain in writing the origin of the funds before continuing with the…
• CSuspend identification and send a 24-hour unusual-operation report, which may be prepared…
• DRefer the customer to another bank without recording the interaction, to avoid any liabil…

According to the 24th provision of the DCG Bancos, what is a customer's transactional profile (perfil transaccional) based on?

• AThe customer's credit score, taken from a credit bureau, and the customer's income tax br…
• BThe average balance and number of operations of all customers served by the same branch
• CA fixed monthly amount that the CNBV sets for each customer segment in the DCG annexes
• DThe customer's own information and the entity's data on the amount, number, type, nature…

Under the 28th provision of the DCG Bancos, which customers must be classified at least as high risk (Grado de Riesgo alto)?

• ANon-resident private banking clients, foreign PEPs, and companies with US dollar cash ope…
• BAll customers who deposit more than USD 7,500 in cash during a calendar quarter
• CAll Mexican public servants and their relatives up to the second degree, whatever their p…
• DAll customers who open their accounts remotely through a mobile application

Before a bank opens an account for a customer it has classified as high risk, what approval does the 27th provision of the DCG Bancos require?

• APrior approval from the CNBV's PLD supervision area, requested through the entity's Ofici…
• BApproval by a majority vote of the board of directors at its next ordinary session
• CWritten or electronic approval from at least one directivo with specific authority, befor…
• DNo approval, as long as the customer signs a sworn statement on the lawful origin of the…

How often does the 21st provision of the DCG Bancos require an entity to verify that the identification files of high-risk customers contain all required, up-to-date data and documents?

• AEvery five years
• BAt least once a year
• COnly when the customer asks to close the account
• DEvery three months

A long-standing low-risk customer suddenly starts receiving frequent transfers from abroad that do not fit their declared activity, without any justification. Under the 21st provision of the DCG Bancos, what must the entity do, besides assessing whether to report?

• AClose the account immediately and return the balance, without further analysis
• BKeep the current risk level until the next scheduled annual review of the file
• CAsk the CNBV for authorization before continuing the relationship with the customer
• DReclassify the customer to a higher risk level and request updated data and documents