AML Senior Expert

About Us

Nu is one of the largest digital financial platforms in the world, with more than 127 million customers across Brazil, Mexico, and Colombia. Guided by our mission to fight complexity and empower people, we are redefining financial services in Latin America. Listed on the NYSE (NU), we combine proprietary technology, data intelligence, and an efficient operating model to deliver financial products that are simple, accessible, and human.

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 environments.
• Hands-on experience managing transaction monitoring platforms: rule creation, threshold calibration, alert queue management, and model validation.
• Experience managing or supporting CNBV PLD/FT audits end-to-end, including pre-audit readiness, fieldwork support, and findings remediation.
• Strong analytical skills with experience working with large transaction datasets; comfort with SQL or Python for ad hoc investigations and reporting.
• Experience with PEPs screening, OFAC/UN/SHCP sanctions list management, and enhanced due diligence processes.
• Bilingual: Spanish (native) / English (professional working proficiency).

Nice to have

• CAMS (Certified Anti-Money Laundering Specialist) or equivalent international certification.
• Experience contributing to FATF mutual evaluations, national risk assessments, or GAFI working groups.
• Background with RegTech / compliance automation tools (e.g., automated screening, AI-based transaction monitoring).
• Experience at a high-growth tech company, neobank, or digital payments platform.
• Familiarity with virtual asset regulations and FATF Recommendation 15 (Travel Rule, VASPs).

Key Regulatory Framework

This role operates within — and must demonstrate mastery of — the following frameworks:

• Artículo 115 de la Ley de Instituciones de Crédito (LIC) and its Disposiciones de Carácter General (DCG), including the August 2024 resolution published in the DOF.
• Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (LFPIORPI).
• Ley General de Organizaciones y Actividades Auxiliares del Crédito (LGOAAC).
• FATF 40 Recommendations — particularly R.10 (CDD), R.12 (PEPs), R.15 (New Technologies), R.20 (Suspicious Transaction Reporting), and R.26–R.28 (Regulation, Supervision, FIU).
• Evaluación Nacional de Riesgos 2023 and sectoral risk typologies published by UIF/SHCP.
• NOM-151-SCFI (digitalization and preservation of data messages).

Benefits 

• 17 days paid vacation per year. 
• Life insurance. 
• Health insurance. 
• NuLanguage Program 
• NuCare Program 
• Extended Parental Leave 

Work Model

Hybrid — Our hybrid work model brings us to the office at least twice a week, on strategic days designed to maximize team connection and collaboration. For more details, visit building.nubank.com/nu-hybrid-work-model/

Explore how we build technology at Nubank: building.nubank.com.br · youtube.com/@building.nubank · Spotify: Nubank Stories