AML Senior Expert

About Nu

Nu serves more than 140 million customers, guided by a mission to fight complexity and empower people. The company has been leading an industry transformation through innovative products and human-centered services.

Proprietary technology and data at scale power Nu’s digital platform, built to promote financial access, advancement, and transparency. Its business model thrives on customer love and lower costs, feeding a flywheel of growth and profitability. Visit our Institutional Page

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.