The National Banking and Securities Commission (CNBV) lays down the regulatory framework to be followed by financial institutions in Mexico for the identification and knowledge of their clients. To comply with these provisions is not only a legal obligation but an essential practice to prevent money laundering and to protect the financial system.
Applicable regulatory framework
The main provisions regulating an identity check in Mexico include:
- General provisions applicable to credit institutions (CUB)
- Federal Act for the Prevention and Identification of Transactions with Illawful Promises (LFPIORPI)
- Commission UIF about preventing money laundering
- Unique Circular of Banks and its amendments
Identification requirements for natural persons
To open an account or to establish a commercial relationship with an individual, an institution should seek and verify the following information:
Mandatory identification data
- Full name (without abbreviations)
- Date of birth
- Country of birth and nationality
- CURP (Unique Population Registration Key)
- RFC (Federal Loan Registry) as applicable
- Special address
- Occupation, profession or activity
- Telephone and e-mail
Identification documents accepted
The CNBV lays down valid documents for attesting to an identity:
Primary documents
- • Credit to vote (INE)
- • Current passport
- • Professional qualification
- • Migratory form (foreign)
Home checks
- • Reception of services (light, water, gas)
- • Bank statement
- • Constance of residence
- • Maximum age: 3 months
Non-face identity check
The provisions allow remote monitoring as long as specific safety requirements are met:
Requirements for remote monitoring:
- • Collection of an identity document with technology that verifies authenticity
- • Facial biometric comparison against document
- • Liveness detection (liveness detection) to confirm the presence of the incumbent
- • Validation against official databases (INE, RENAPO)
- • Geolocalisation of the device as applicable
Loan and tiered requirements
The Regulation lays down different levels of account with risk-proportional requirements:
| Level | Limits | Requirements |
|---|---|---|
| Level 1 | up to 750 monthly IDUs | Basic information, phone number |
| Level 2 | up to 3,000 IDUs monthly | Official identification, CURP |
| Level 3 | up to 10,000 monthly IDUs | Biometric check, home check |
| Level 4 | No limit | KYC complete, face check or equivalent |
Reporting obligations
Institutions should maintain complete checks:
- Conservation time: Minimum 10 years after end of relationship
- Format: Digitized documents with sufficient quality for reading
- Accessibility: Available for review of authorities within 72 hours
- Integrity: Mechanisms to ensure that they have been unchanged
Political Exposed Persons (PEPs)
Special attention is required to identify and manage relations with PEPs:
- Proactive identification through specialist database consultation
- Due care for PEPs and their close families
- high management approval to establish the relationship
- Continuous monitoring of transactions
- Documentation of the source of resources
Penalty for non-compliance
Non-compliance with the provisions may result in:
- • Administrative fines up to 100,000 MMUs
- • Suspension of operations for specific activities
- • License renewal in serious cases
- • Criminal liability for officials in cases of malfunctioning
Best practices for compliance
- Automate verification: Using document and biometric technologies in real time.
- To integrate official databases: Connect with INE, RENAPO and SAT for immediate validation.
- Implement alerts: Systems that automatically identify inconsistencies or risks.
- Training staff: Continuous training about regulations and fraud detection.
- Regular audits: Review processes regularly and update them accordingly.
- To document everything: Keep complete evidence of each check performed.
Conclusion
Compliance with provisions CNBV It should not be seen as a regulatory burden but as an opportunity to strengthen the relationship with customers and to protect the institution. Modern technology allows meeting all the requirements while offering an outstanding user experience. Institutions that invest in robust verification solutions will be better placed for the future.