PRESS RELEASE
22 April 2025

Mexico’s Evolving AML/CFT Environment: FATF Review And FTO Designations

KI
K2 Integrity

Contributor

K2 Integrity is the preeminent risk, compliance, investigations, and monitoring firm built by industry leaders, driven by interdisciplinary teams, and supported by cutting-edge technology to safeguard our clients’ operations, reputations, and economic security. K2 Integrity represents the merger of K2 Intelligence, an industry-leading investigative, compliance, and cyber defense services firm founded in 2009 by Jeremy M. Kroll and Jules B. Kroll, the originator of the modern corporate investigations industry, and Financial Integrity Network (FIN), a premier strategic advisory firm founded by Juan Zarate and Chip Poncy dedicated to helping clients achieve their financial integrity goals.
U.S. and Mexican companies and financial institutions are seeking to navigate AML/CFT, sanctions, export control, and tariff and supply chain concerns...
Mexico

U.S. and Mexican companies and financial institutions are seeking to navigate AML/CFT, sanctions, export control, and tariff and supply chain concerns as their governments' make rapid changes around trade and tariffs and ramp up efforts to stop cartels and fentanyl trafficking, including through the recent U.S. FTO designations. Both countries also face upcoming FATF mutual evaluations against the backdrop of shifts in the regulatory and enforcement environment. K2 Integrity experts with experience in cross-border relations in the private sector will help participants understand the broader geostrategic risk environment, key legal and policy issues that might affect cross-border transactions and risks, best practices for managing those risks, and how best to assess AML/CFT and other risks.

You'll hear from moderator Himamauli Das, senior managing director and counsel at K2 Integrity; Juan Zarate, global co-managing partner and chief strategy officer at K2 Integrity; Mariano Federici, senior managing director at K2 Integrity; Narciso Campos Cuevas, Mexico City partner at White & Case; and Luis Urrutia, AML/CFT expert.

By the end of this session, you will be able to:

  • Describe the AML/CFT implications of the overall U.S.-Mexico relationship
  • Discuss key issues in the upcoming FATF mutual evaluation and implications for financial institutions
  • Explain the impact of the U.S. FTO and SDGT designations on AML/CFT compliance programs and risk management

Webinar Registration

Speakers

Narciso Campos Cuevas
Partner, Mexico City · White & Case

Narciso Campos is part of the Global Capital Markets Practice. His practice focuses on advising financial institutions on complex regulatory matters. He also has extensive experience in banking financings, capital markets and mergers & acquisitions transactions.

His regulatory practice encompasses all legal aspects of the operations of banks and financial groups, including authorizations, corporate structures; corporate governance; treasury transactions, capitalizations and optimizations of capital; compliance, risk consolidation, controls and regulatory matters related to AML/CFT, including sanctions; annual bank evaluation pursuant to the Banking Law; product development and matters related to consumer protection; revocation and resolution processes; related party transactions; payment systems and niche bank regulation.

Narciso served as Assistant Secretary for Banking, Securities and Savings at the Ministry of Finance and Public Credit in Mexico, where he oversaw public policy related to the development, supervision and regulation of the banking sector and the securities market, including financial groups, banks, stock exchanges, derivative exchanges, broker-dealers, credit bureaus, representation offices of foreign financial institutions, mutual funds, savings and loans entities, derivatives market makers and operators and other market participants, as well as foreign exchange houses and credit unions.

He was also in charge of the interpretation for administrative purposes of financial Laws, except for Laws related to insurance and pensions, as well as in charge of the authorization, concession and revocation of matters related to financial groups, stock exchanges, credit bureaus, bonded warehouses, currency exchanges, and other entities related to the securities market.

Himamauli Das
Senior managing director and counsel · K2 Integrity

Himamauli Das helps clients navigate geopolitical, legal, and compliance challenges, with a focus on the rapidly evolving economic security landscape. His background positions him uniquely to help guide clients through the convergence of sanctions, financial crimes, investment security, export controls, and trade/supply chain risks and regulatory demands. Him's expertise combines technical know-how with a global strategic perspective drawn from his roles as a senior government lawyer and decisionmaker.

Him most recently served as the acting director of the Financial Crimes Enforcement Network (FinCEN), where he oversaw the continued expansion and refinement of the U.S. anti-money laundering regime and represented the United States before the Egmont Group and with FIUs globally. He led the bureau's efforts to reform the U.S. AML/CFT framework through implementation of the Anti-Money Laundering Act of 2020 and the Corporate Transparency Act and to enhance cooperation with financial institutions, law enforcement, and civil society through the Bank Secrecy Act Advisory Group (BSAAG) and public-private exchanges. Him also provided direction on FinCEN's enforcement efforts and supervisory engagement with the Federal Banking Agencies (FBAs).

Previously, Him served at the White House in roles at the National Security Council and National Economic Council as the Senior Director for International Trade and Investment and as Deputy Legal Adviser. He also served as a senior lawyer and policy maker at the U.S. Treasury Department, where he served as acting Deputy Assistant Secretary for International Trade and Investment and Assistant General Counsel for International Affairs. He started his career at the State Department, where he worked as an attorney-adviser on economic sanctions, trade, and climate change negotiations.

Juan Zarate
K2 Integrity global co-managing partner and chief strategy officer; Consilient co-founder and chair of the board · K2 Integrity

The Honorable Juan Zarate is global co-managing partner and chief strategy officer at K2 Integrity. He is also the chair and co-founder of Consilient, an innovative fintech dedicated to establishing the next-generation AML/CFT system through the application of federated AI. Prior to K2 Integrity, Juan served as the deputy assistant to the president and deputy national security adviser for combating terrorism ("counterterrorism czar"), where he was responsible for developing and implementing the U.S. counterterrorism strategy and policies related to transnational security threats, including anti-money laundering, kleptocracy, and transnational organized crime.

He was the first-ever assistant secretary of the treasury for terrorist financing and financial crimes. In this role, he led the post-9/11 anti-money laundering and sanctions regime expansion in the United States; helped develop the international standards for AML/CFT and proliferation finance; supervised the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), and the Treasury's Executive Office for Asset Forfeiture (TEOAF); and drove the innovative use of the Treasury's national-security-related powers and ultimately the establishment of the Office of Terrorism and Financial Intelligence (TFI). Prior to 9/11, Juan served as a federal terrorism prosecutor, working on international terrorism cases like the bombings of the U.S. embassies in East Africa and the USS Cole.

Juan sits on the boards of Northwestern Mutual, Guardian Space Technology Solutions, and the National Endowment for Democracy (currently as NED's treasurer), and on the director's advisory board for the National Counterterrorism Center. Since 2014, he has served as an independent adviser to Coinbase, the United States' largest virtual asset service provider.

Mariano Federici
Senior managing director·K2 Integrity

Mariano Federici is a senior managing director at K2 Integrity, resident in the firm's Washington, DC office. He is a leading global expert in anti-money laundering and counter-terrorist financing (AML/CFT). Mariano advises clients, on complex sanctions, regulatory compliance, fraud investigation, and risk management matters. He helps clients design, establish, and maintain strong and effective financial intelligence units (FIUs); evaluate and enhance their existing AML/CFT policies and procedures; add advanced data management and analytics capabilities to assess and manage more complex financial and commercial risks; and implement new programs to ensure regulatory compliance.

A central actor in the development of the international AML/CFT framework, Mariano has worked in partnership with jurisdictions and government agencies to ensure those regimes meet the Financial Action Task Force (FATF) global standards. Mariano has approached the subject of financial integrity from the policy development, technical assistance/capacity building, and operational perspective as well as from country-, regional-, and global-specific standpoints, giving him a broad perspective on the topic, its challenges, and its opportunities.

Mariano demonstrates key expertise across both public entities and private institutions. He served as head of Argentina's Financial Intelligence Unit (FIU), during which time he held numerous international positions at global AML/CFT organizations, such as chair of the Egmont Group of FIUs; regional representative for the Americas at the Egmont Group; chair of FATF's Heads of FIU Forum; Co-chair of FATF's Risk, Trends, and Methods Working Group (RTMG); and co-chair of the Grupo de Acción Financiera de Latinoamerica (GAFILAT) Mutual Evaluations Working Group.

Luis Urrutia
AML/CFT Expert

From 2023 until 2025, Luis Urrutia served as a Deputy General Counsel at the International Monetary Fund where he oversaw the work by the legal team on prevention of money laundering and combatting the financing of terrorism and proliferation of weapons of mass destruction, and on governance and anti-corruption.

Before joining the IMF, Mr. Urrutia served as the general counsel of Mexico's central bank, Banco de México, from 2013 to 2023. Before leading the legal team at the central bank, he served as Director of Regulation and Supervision from 2010.

He also held the position of President of the Financial Action Task Force (FATF) in 2010-2011, and Vice-President in 2009-2010. In addition, Mr. Urrutia headed the Mexican Financial Intelligence Unit, a bureau of the Ministry of Finance and Public Credit, from 2007 to 2010, from which he coordinated the implementation in Mexico of the FATF standards. From 2009 to 2010 he was the Chair of the association of financial intelligence units, the Egmont Group, and in 2008 he acted as President of the Financial Action Task Force of South America (GAFISUD, now GAFILAT).

Previously Mr. Urrutia acted as Deputy Federal Fiscal Attorney for Financial Affairs in the Ministry of Finance for four years. In the initial part of his career, he served as staff member in the legal departments of the regional multilateral organization Andean Development Corporation and Banco de Mexico, and completed internships at the World Bank and the New York office of the law firm Cleary, Gottlieb, Steen and Hamilton. Mr. Urrutia holds a law degree from the Instituto Tecnológico Autónomo de México (ITAM), and a master's degree in public policy from the University of Chicago.

Contributor

K2 Integrity is the preeminent risk, compliance, investigations, and monitoring firm built by industry leaders, driven by interdisciplinary teams, and supported by cutting-edge technology to safeguard our clients’ operations, reputations, and economic security. K2 Integrity represents the merger of K2 Intelligence, an industry-leading investigative, compliance, and cyber defense services firm founded in 2009 by Jeremy M. Kroll and Jules B. Kroll, the originator of the modern corporate investigations industry, and Financial Integrity Network (FIN), a premier strategic advisory firm founded by Juan Zarate and Chip Poncy dedicated to helping clients achieve their financial integrity goals.

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