AML Senior Expert

About this role

ABOUT NU

Nu is the leading digital bank in Latin America, serving 135 million customers across Brazil, Mexico, and Colombia. The company has been leading an industry transformation by leveraging data and proprietary technology to develop innovative products and services.

Guided by its mission to fight complexity and empower people, Nu caters to customers’ complete financial journey, promoting financial access and advancement with responsible lending and transparency. The company is powered by an efficient and scalable business model that combines low cost to serve with growing returns.

Nu’s impact has been recognized in multiple awards, including Time 100 Most Influential Companies, Fast Company’s Most Innovative Companies, and Forbes World’s Best Banks. Visit our institutional page: https://www.nu.com/2026-en

About the Role

Nubank Mexico operates as a regulated financial institution under CNBV oversight, processing millions of transactions daily for millions of customers. Preventing money laundering and terrorism financing is not only a regulatory obligation — it is central to our license to operate and to the trust our customers place in us.

The Senior Expert AML is the foremost domain expert in Mexico's PLD/FT compliance. This role owns the design and ongoing improvement of Nubank Mexico's AML program and ensures full adherence to the Disposiciones de Carácter General (DCG) referidas en el Artículo 115 de la LIC and its 2024 amendments, the FATF 40 Recommendations, and the Evaluación Nacional de Riesgos.

Beyond regulatory compliance, this person shapes how AML controls are embedded into product development, automated monitoring systems, and risk models — making Nubank Mexico both a safe and efficient financial institution. They influence across Engineering, Product, Legal, and Data teams, and represent Nubank before the CNBV and SHCP/UIF in regulatory interactions.

You'll be responsible for

Program Ownership & Regulatory Compliance

- Design, maintain, and continuously improve the Nubank Mexico AML/PLD-FT compliance program, including the Manual de Cumplimiento, in line with DCG115 (Art. 115 LIC) and its August 2024 amendments.

- Own the enfoque basado en riesgos (risk-based approach) methodology: develop risk indicators for ML and TF separately, maintain the customer risk segmentation model, and submit the annual Reporte de Operatividad to CNBV.

- Ensure CNBV PLD/FT certification is current for yourself and all audit personnel; coordinate timely notifications to CNBV upon designations or revocations of compliance officers (within 10 business days).

- Lead preparation and response for CNBV annual audits and ad hoc inspections; manage remediation plans and track implementation of regulatory findings.

- Monitor FATF grey/black list updates, GAFI-flagged jurisdictions, and emerging typologies; adjust controls accordingly and apply reforzada due diligence to affected transactions and correspondents.

Transaction Monitoring & Reporting

- Oversee the design and tuning of automated transaction monitoring (ATM) systems, including differentiated monitoring rules for persons físicas, morales, and fideicomisos.

- Ensure ATM systems embed risk model execution and client classification as required by DCG115; lead biennial independent system evaluations.

- Supervise the alert-to-SAR pipeline: manage the investigation process for unusual operations, escalation criteria, and timely filing of Reportes de Operaciones Inusuales (ROU), Reportes de Operaciones Relevantes (ROR), and Reportes de Operaciones con Dólares (ROED) to SHCP/UIF via goAML.

- Define and maintain the reporting cadence for international fund transfer reports, including new requirements for concentrator accounts under the 2024 resolution.

KYC / Customer Due Diligence

- Own the KYC/CDD framework: set standards for client identification, expediente integration, transactional profile construction, and the enhanced due diligence process for PEPs, high-risk clients, and foreign correspondents.

- Oversee the dual-review process for customer files (reviewer independent from the person who integrated or updated the expediente) as mandated by DCG115.

- Define EDD protocols for customers exceeding low-risk transactional thresholds and ensure mandatory interviews (presencial o remota) are conducted.

- Manage PEPs and sanctions screening program (OFAC SDN, UN Security Council, SHCP blocked persons list); ensure real-time and periodic screening coverage.

Cross-functional Leadership & Product Compliance

- Partner with Product and Engineering to embed AML controls by design in new product features, account types, and onboarding flows — particularly for non-presential account opening and digital identity validation (INE/SRE verification, Firma Electrónica Avanzada).

- Advise on compliance implications of new product launches, partnerships, and geographic expansion in Mexico.

- Design and deliver the annual AML training program for all relevant personnel, including board-level awareness and role-specific modules.

- Represent the AML function internally and externally — including in product committees, risk forums, and regulatory interactions with CNBV and UIF.

We are looking for a person who has

Required experience & knowledge

- 7+ years of AML/PLD-FT compliance experience in regulated financial institutions, banks, or fintech companies operating in Mexico.

- Deep working knowledge of DCG referidas en el Artículo 115 de la LIC (including 2024 amendments), LFPIORPI, LGOAAC, and the SHCP/CNBV/UIF regulatory ecosystem.

- CNBV PLD/FT certification (vigente), or willingness to obtain within the regulatory deadline. High proficiency in the certification exam topics: KYC, transactional profiling, ROU/ROR/ROED filing, PEPs, and national/international AML regimes.

- Track record of building, scaling, or materially improving AML/compliance programs — especially in digital or high-volume transaction environme

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