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Writer's pictureTania Tenorio

Anticipate a a Verification Visit by the UIF as an Obligated Party under the Anti-Money Laundering Law (LFPIORPI)

Today, not only are tax authorities authorized to conduct home visits to individuals or legal entities, but also the Ministry of Labor and Social Welfare, as well as the UIF (Financial Intelligence Unit).

Without a doubt, receiving this type of administrative act at your business premises requires a significant investment of time, and without the necessary knowledge or experience, the likelihood of improperly handling a UIF verification visit increases.

For this reason, we have prepared this brief article to help you understand how to prepare for such visits.



First of all, you should know that the UIF, through the SAT (Tax Administration Service), is the authority authorized to carry out these visits and can do so on business days and during business hours, as indicated in the Federal Administrative Procedure Law, Article 28. These inspections may be conducted personally at the premises of the interested party. Therefore, if you are required to comply with the provisions of the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds (LFPIORPI), it is essential to at least consider the following points:

  1. Stay calm, as the authority may arrive without prior notice at the address you provided during your registration in the Anti-Money Laundering (AML) portal.

  2. Pre-designate a trained person in your internal policies and procedures to handle the visit. This could be the compliance officer or the individual who controls the documentation for the vulnerable activity. This person should verify that the SAT personnel are properly identified and listed in the respective visit order.

  3. Have all relevant information related to the vulnerable activity registered in the AML portal readily available, including the following documents, as they may be requested during the visit:

    • Registration in the AML portal.

    • Updates and/or modifications made in the AML portal.

    • Supporting documentation of the designation and acceptance of the compliance officer.

    • Internal policies and procedures established for customer and/or user identification and due diligence, as well as for compliance with the obligations set out in the LFPIORPI. Additionally, the guidelines for reviewing national and international lists of criminal individuals or organizations to ensure that clients are not listed (AML Manual).

    • Documentation supporting the threshold controls established by law.

    • Properly integrated and updated client and/or user identification files, especially for business relationships lasting over a year.

    • Monthly reports and/or notices submitted on time.

Recommendation:

It is crucial to keep this documentation properly integrated and updated. Failure to provide it on the day of the SAT inspection or within the following 5 business days could result in fines ranging from $21,000 to $7,000,000 during the 2024 fiscal year.

For more advice on this subject, contact our specialists, who are fully trained and certified to guide you and address your business needs. Avoid unnecessary complications and costs by staying prepared.


In terms of Article 89 of the Federal Tax Code in force, the content of this reproduction, presentation, program, or transmission, and/or the documents and/or examples used in this presentation may express positions that do not align with the criteria of Mexican tax or judicial authorities. This reproduction or presentation is not intended for, and cannot be used by, any person for the purpose of evading (i) a federal, local, or municipal tax, or (ii) the imposition of tax penalties in the United Mexican States. Consultores Cadena, Barrio y Asociados, S.C., is not responsible for the use or interpretation that any user may give to this material.

Furthermore, the writer guarantees the originality and content of this work to the company and is responsible for any third-party rights infringements that may arise. The writer agrees to indemnify the company for any damages or losses incurred as a result of these issues.

 

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