E duardo Apáez Davila


Mr. Apáez specializes in compliance with an emphasis in Anti-Money Laundering and Combat of the Financing of Terrorism (AML/ CFT). Prior to joining the firm, he was a civil servant in the Ministry of Finance and Public Credit, the Financial Intelligence Unit, the National Banking and Securities Commission, and the Bank of Mexico, where he oversaw the regulation and supervision of the AML/CFT regime.

Since 2008, he has participated in the issuance of the AML/CFT general provisions for the financial sector, as well as in the designing of the layouts for the filing of suspicious activity reports, currency transaction reports, among others. Also, he has issued technical opinions regarding the approval of interpretative criteria for the aforementioned normative instruments.

With the enactment of the Federal Anti-Money Laundering Law in 2012, he directed the drafting and issuing of its secondary regulation, as well as the issuance of interpretative criteria for Designated Non-Financial Businesses and Professions, also known as Vulnerable Activities at the Financial Intelligence Unit.

Likewise, during his tenure as General Director of the National Banking and Securities Commission, he was responsible of the on-site and off-site supervision of compliance of the AML/CFT regime by Banks, Brokerage Houses, Exchange Houses, Credit Unions, Sofipos, Socaps, and Regulated SOFOMES.

He has been counsel in terms of compliance with the Financial Action Task Force Recommendations, having participated as a Legal and Law Enforcement expert in the Mutual Evaluation Processes of Brazil and Aruba, and was also responsible of the coordination of Mexico’s own evaluation process conducted by the Financial Action Task Force (FATF), the Financial Action Task Force for Latin America (GAFILAT) andthe International Monetary Fund.

Mr. Apáez has been a guest-speaker in various national and international forums organized by the FATF, GAFILAT, the Mexican Banking Association (ABM); the Mexican Association of Brokerage Intermediaries (AMIB), the Mexican Council of Credit Unions (CONUNION), the Mexican Association of Popular Financial Societies (AMSOFIPO), the Mexican National Notary College, the Mexican Institute of Public Accountants, the Mexican Association of Automotive Distributors (AMDA), the Mexican Center for Philanthropy (CEMEFI) , among others.

He is professor of the Course for the Certification on Money Laundering Prevention at the Instituto Tecnológico Autónomo de México (ITAM).

Mr. Apáez obtained his Law degree (JD) from Universidad Marista. His native language is Spanish, and he is fluent in English.