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Precedents · Commented

For referenceAnti-money laundering

Supreme Court upholds anonymity of anti-money-laundering officials

Prevention and identification of transactions with illicit proceeds. Article 41, last paragraph, of the relevant federal law does not violate the right to legal certainty.

Official heading (Spanish): PREVENCIÓN E IDENTIFICACIÓN DE OPERACIONES CON RECURSOS DE PROCEDENCIA ILÍCITA. EL ARTÍCULO 41, PÁRRAFO ÚLTIMO, DE LA LEY FEDERAL RELATIVA, NO VULNERA EL DERECHO A LA SEGURIDAD JURÍDICA.

The ruling

A company engaged in vulnerable activities was fined for failing to file notices and argued that article 41, last paragraph, of the federal anti-money-laundering law (LFPIORPI) violates legal certainty by keeping the identity of enforcing officials confidential. The full SCJN (Mexican Supreme Court) held the provision constitutional, as binding precedent (jurisprudencia).

Our take

This ruling shuts down a defense often used against anti-money-laundering fines: the absence of the signing official's name. The Court reasons that confidentiality does not relieve the authority from stating legal grounds and reasons or from proving its jurisdiction. The defense should therefore focus on those points and on the merits: whether the notice was required, whether the transaction exceeded the threshold, and whether the fine was properly calibrated. For companies engaged in vulnerable activities, the message is plain: notice compliance is monitored and enforced, and signature formalities will not save a fine.

What to do

  • Stop relying on official anonymity as a defense against anti-money-laundering fines.
  • Check the sanctioning authority's legal grounds, reasoning and jurisdiction.
  • Internally audit thresholds and notices filed over recent years.

Details

Court
SCJN Plenary
Type
Binding precedent (jurisprudencia)
Identifier
P./J. 166/2026 (12a.)
Digital registry
2032429
Published
July 10, 2026
Area
Anti-money laundering
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Prepared by Artegia for information only; not legal advice. Headings in English are unofficial translations. The official text is the one published in the Semanario Judicial de la Federación or the TFJA journal.