Honduras KYC, KYB & AML compliance checklist
A practical, source-linked checklist for implementing KYC, KYB and AML requirements in Honduras.
- Last reviewed
- Last reviewed:
- Version
- Version 1.0
Direct answer
What does the Honduras compliance checklist cover?
The Honduras checklist translates primary KYC, KYB and AML rules into 11 control areas and 35 implementation checks. It identifies the relevant authorities, customer and beneficial-owner controls, reporting duties, recordkeeping expectations and evidence teams should retain.
Key regulatory facts
- FIU
- Unidad de Inteligencia Financiera (UIF), attached to the CNBS Presidency
- Primary framework
- Decree 144-2014; CNBS Resolution SB 348/27-04-2016
- Suspicion reporting
- To UIF regardless of amount; reconcile immediate statutory duty with 60/30-day regulatory case limits
- Periodic reports
- BCH-set thresholds; generally due within first 10 business days of the following month
- Retention
- At least 5 years after the relationship or transaction, as applicable
- FATF status
- Not on FATF public lists dated 13 February 2026; recheck live lists
Implementation detail
Honduras compliance requirements and actions
Open each control area to review the requirement, recommended implementation action, evidence to retain and the primary-source citation used by the research team.
01Scope, authorities, and licensingClassify each entity, activity and delivery model before applying sector rules.3 items+
Determine whether each activity is a supervised financial activity, APNFD or other obliged activity.
- Implementation action
- Map services and entities against Decrees 144-2014 and 131-2014 and the current CNBS, UIF/URMOPRELAFT and sector rules; obtain advice for uncertain scope.
- Evidence to retain
- Applicability memo, service map and authority or counsel confirmation.
- Primary citation
- Decree 144-2014 arts. 2, 18-19; Decree 131-2014
Treat UIF as the national financial intelligence unit and reporting recipient.
- Implementation action
- Register the compliance officer and approved reporting channels, test access and maintain current UIF contact and submission procedures.
- Evidence to retain
- Registration, access test, appointments and channel procedure.
- Primary citation
- Decree 144-2014 arts. 27-30
Obtain required authorisation before regulated financial, remittance, payment or electronic-money activity.
- Implementation action
- Classify the product under CNBS and BCH rules and secure the necessary licence, registration or approval before launch.
- Evidence to retain
- Licence analysis, approval and permitted-activity register.
- Primary citation
- Financial System Law; BCH electronic-money and payment rules; CNBS supervisory inventory
02Governance and risk assessmentThe prevention system must be proportionate, documented and overseen by accountable management.3 items+
Maintain a board-approved, risk-based compliance programme.
- Implementation action
- Cover policies, sanctions, ethics, training, monitoring and independent internal and external review; refresh for products and risk changes.
- Evidence to retain
- Board approvals, programme, training and audit reports.
- Primary citation
- Decree 144-2014 arts. 6, 10; CNBS Resolution SB 348/2016 arts. 5, 17-24
Appoint an independent senior compliance officer and appropriate committee or unit.
- Implementation action
- Document authority, resources, access, reporting line, substitution and UIF notification; justify any permitted proportional structure.
- Evidence to retain
- Appointments, UIF notice, job descriptions and minutes.
- Primary citation
- Decree 144-2014 art. 9; CNBS Resolution SB 348/2016 arts. 4-12
Assess customer, product, channel and geographic risks continuously.
- Implementation action
- Maintain enterprise and customer risk models, validate controls and record enhanced or simplified measures only where supported.
- Evidence to retain
- Risk assessment, model governance, scores and control mapping.
- Primary citation
- Decree 144-2014 art. 6; CNBS Resolution SB 348/2016 chs. V-VI
03Natural-person identificationIdentify and verify customers, users and representatives from reliable independent evidence.4 items+
Identify and verify each customer before or during establishment of the relationship under the approved risk procedure.
- Implementation action
- Collect official identity, address, occupation, economic activity, purpose and expected activity; authenticate documents and resolve inconsistencies.
- Evidence to retain
- Identity file, verification result, profile and approval.
- Primary citation
- Decree 144-2014 art. 7; CNBS Resolution SB 348/2016 arts. 27-30
Apply CDD to customers and occasional users without treating a reporting threshold as a safe harbour.
- Implementation action
- Configure relationship, transaction, suspicion and unreliable-data triggers; apply enhanced checks where risk requires.
- Evidence to retain
- CDD trigger matrix, linked-transaction logic and case files.
- Primary citation
- Decree 144-2014 arts. 6-7; CNBS Resolution SB 348/2016 arts. 27-35
Do not maintain anonymous, fictitious or concealed-identity accounts.
- Implementation action
- Reject false, anonymous or coded identities and verify every person acting for the customer and their authority.
- Evidence to retain
- Account controls, identity results and authority documents.
- Primary citation
- Decree 144-2014 art. 7(9); CNBS Resolution SB 348/2016 art. 29
Stop or end service when required identity evidence remains inconsistent or inadequate.
- Implementation action
- Document the failure, refuse or terminate as appropriate and assess a confidential ROS to UIF.
- Evidence to retain
- Decline or exit record, escalation and ROS decision.
- Primary citation
- Decree 144-2014 art. 7(5); CNBS Resolution SB 348/2016 art. 30
04KYB, registries, and beneficial ownershipRegistry evidence supports but does not replace ownership and control verification.4 items+
Verify legal existence, purpose, address, tax identity and authority to act.
- Implementation action
- Obtain current Mercantile Registry evidence, constitutive documents, RTN, directors, signatories and powers; verify through the competent registry.
- Evidence to retain
- Registry extract, constitutive documents, RTN and powers.
- Primary citation
- Commercial Code; Decree 144-2014 art. 7; CNBS Resolution SB 348/2016 arts. 29, 37
Identify the natural person who ultimately owns or controls the customer.
- Implementation action
- Trace ownership and effective control to natural persons and apply the regulation's control sequence; do not invent a universal percentage threshold.
- Evidence to retain
- Ownership chart, source records, control analysis and verified identities.
- Primary citation
- Decree 144-2014 arts. 2(5), 7(2); CNBS Resolution SB 348/2016 art. 38
Keep company and beneficial-owner information current and plausible.
- Implementation action
- Refresh on ownership, management, activity or risk change; escalate discrepancies and consider a ROS where explanations are inadequate.
- Evidence to retain
- Refresh log, change monitoring and discrepancy decisions.
- Primary citation
- Decree 144-2014 arts. 6-8; CNBS Resolution SB 348/2016 arts. 27-38
Do not assume one complete public national beneficial-ownership database.
- Implementation action
- Use the competent territorial Mercantile Registry and tax or sector evidence where lawfully accessible, then independently verify natural-person ownership and control.
- Evidence to retain
- Registry searches, access logs, customer evidence and discrepancy memo.
- Primary citation
- Commercial Code; Institute of Property / CCIT registry framework; GAFILAT Honduras follow-up
05PEPs, EDD, and remote onboardingHigher-risk relationships require senior oversight, provenance evidence and enhanced monitoring.3 items+
Detect domestic, foreign and international-organisation PEPs and relevant connected persons.
- Implementation action
- Screen customers and beneficial owners at onboarding and periodically and document match disposition.
- Evidence to retain
- Screening output, disposition and refresh schedule.
- Primary citation
- Decree 144-2014 art. 7(8); CNBS Resolution SB 348/2016 arts. 39-40
Apply enhanced PEP controls.
- Implementation action
- Obtain authorised senior approval, establish source of wealth and funds and conduct enhanced ongoing monitoring.
- Evidence to retain
- Approval, provenance file and monitoring plan.
- Primary citation
- CNBS Resolution SB 348/2016 arts. 39-40
Treat non-face-to-face onboarding as higher risk under the statutory rule.
- Implementation action
- Use enhanced document, liveness, device and first-payment controls and update relevant information at least annually where Decree 144-2014 art. 7(7) applies.
- Evidence to retain
- Remote-onboarding test, annual refresh and approval.
- Primary citation
- Decree 144-2014 art. 7(7); CNBS Resolution SB 348/2016 art. 35
06Monitoring and suspicious reportingSuspicion is independent of amount and reporting information is confidential.4 items+
Monitor activity against customer profile and risk.
- Implementation action
- Detect unusual, complex, linked and unjustified activity; investigate and preserve a confidential documented conclusion.
- Evidence to retain
- Alerts, investigation, disposition and rule governance.
- Primary citation
- Decree 144-2014 arts. 6-7, 27; CNBS Resolution SB 348/2016 arts. 55-58
Report suspicious operations to UIF regardless of amount or completion.
- Implementation action
- File attempted, rejected and completed activity using the live UIF channel; do not wait for a threshold or proof of crime.
- Evidence to retain
- ROS decision, supporting file, submission receipt and UIF reference.
- Primary citation
- Decree 144-2014 art. 27; CNBS Resolution SB 348/2016 arts. 58-59
Reconcile immediate statutory escalation with the regulation's outer case-processing periods.
- Implementation action
- Escalate suspicion immediately internally and to UIF where the statute requires; never use the 60-calendar-day first-ROS or 30-day supplemental limits to delay an urgent report, and document the applicable timeline.
- Evidence to retain
- Detection, escalation, decision and filing timestamps.
- Primary citation
- Decree 144-2014 art. 27; CNBS Resolution SB 348/2016 art. 59
Prevent tipping off and protect ROS confidentiality.
- Implementation action
- Restrict access, exclude ROS material from customer disclosures and train staff and agents on prohibited communications.
- Evidence to retain
- Access logs, confidentiality procedure and training.
- Primary citation
- Decree 144-2014 arts. 28, 31; CNBS Resolution SB 348/2016 art. 60
07Payments, wires, thresholds, and agentsBCH-set thresholds and UIF channels must be confirmed live and applied by report type.4 items+
Apply the current BCH threshold to required cash, multiple, non-cash, transfer and remittance reports.
- Implementation action
- Obtain the current operative BCH/UIF threshold and reporting specification before configuring controls; do not rely on an undated historical amount.
- Evidence to retain
- Current resolution, configuration approval and test results.
- Primary citation
- Decree 144-2014 arts. 23-25; CNBS Resolution SB 348/2016 arts. 62-64
Send periodic threshold reports within the applicable deadline.
- Implementation action
- Report through the authorised UIF method within the first ten business days of the following month unless a current sector rule specifies otherwise.
- Evidence to retain
- Submission log, receipt and exception record.
- Primary citation
- CNBS Resolution SB 348/2016 art. 62
Carry required originator and beneficiary information in transfers at or above the BCH-set amount.
- Implementation action
- Validate names, accounts, originator address or identification and amount; manage missing information under the approved risk procedure.
- Evidence to retain
- Payment message, validation and exception decision.
- Primary citation
- Decree 144-2014 art. 12; CNBS Resolution SB 348/2016 art. 36
Control agents, third parties and outsourced providers while retaining accountability.
- Implementation action
- Perform diligence, contract for record access and security, monitor performance and retrieve identity evidence without delay.
- Evidence to retain
- Due diligence, contracts, monitoring and retrieval tests.
- Primary citation
- Decree 144-2014 art. 13; CNBS Resolution SB 348/2016 arts. 48-50
08Targeted financial sanctionsUse current UN designations and UIF communications and preserve a controlled legal decision trail.3 items+
Screen customers, beneficial owners, counterparties and transactions against applicable UN designations.
- Implementation action
- Screen at onboarding, before execution and on list updates, including aliases and ownership or control; subscribe to UIF notices.
- Evidence to retain
- List source, update logs, match logic and dispositions.
- Primary citation
- Law Against Terrorist Financing art. 23; UIF UN sanctions portal and notices
Act without delay on a confirmed designation under the competent Honduran process.
- Implementation action
- Prevent movement or availability of assets, preserve the trail and notify UIF and other competent authorities using the live instruction; do not give advance notice.
- Evidence to retain
- Action timestamp, asset inventory, reports and restrictions.
- Primary citation
- Law Against Terrorist Financing; UIF sanctions communications; GAFILAT Honduras MER
Release blocked assets only on valid competent-authority instruction.
- Implementation action
- Document false-positive or delisting analysis and obtain the legally competent release, exemption or access instruction before action.
- Evidence to retain
- Match file, authority instruction and controlled release approval.
- Primary citation
- Law Against Terrorist Financing; GAFILAT Honduras MER, Recommendation 6 analysis
09Records and regulator accessRecords must reconstruct the relationship, transactions and compliance decisions.3 items+
Retain CDD and relationship records for at least five years after the relationship ends.
- Implementation action
- Preserve identity, beneficial ownership, authority, risk and refresh evidence in retrievable form.
- Evidence to retain
- Retention schedule, archive sample and deletion control.
- Primary citation
- Decree 144-2014 art. 8; CNBS Resolution SB 348/2016 art. 83
Retain transaction, monitoring, ROS and periodic-report support for at least five years.
- Implementation action
- Calculate the correct trigger and preserve complete records, analyses, submissions and receipts.
- Evidence to retain
- Transaction archive, case file and filing copies.
- Primary citation
- Decree 144-2014 arts. 8, 24; CNBS Resolution SB 348/2016 arts. 57, 62, 83
Respond completely and promptly to lawful UIF, CNBS, prosecutor or court requests.
- Implementation action
- Authenticate requests, preserve confidentiality, produce records and log disclosure and receipt.
- Evidence to retain
- Request, legal review, production log and acknowledgement.
- Primary citation
- Decree 144-2014 arts. 26, 30
10Privacy, biometrics, and transfersA comprehensive enacted general private-sector data-protection law was not confirmed; constitutional, transparency, secrecy and sector duties still apply.2 items+
Protect KYC data for defined necessary purposes.
- Implementation action
- Document collection purpose, access roles, security, accuracy and retention and obtain Honduran advice for biometrics, monitoring and cross-border hosting.
- Evidence to retain
- Data inventory, notices, access matrix, security and legal assessment.
- Primary citation
- Constitution arts. 76, 182; Transparency and Access to Public Information Law; financial secrecy duties
Do not present the IAIP draft personal-data bill as enacted law.
- Implementation action
- Track legislative status and assess every data flow under the rules actually in force; contract for confidentiality, security, incidents, deletion and regulator access.
- Evidence to retain
- Legislative check, transfer assessment, data-flow map and contracts.
- Primary citation
- IAIP Draft Law on Personal Data Protection and Habeas Data; Constitution art. 182
11Practical evidence packsKeep concise packs that let a reviewer reproduce each decision.2 items+
Maintain one reconstructable onboarding pack per customer.
- Implementation action
- Bundle identity, KYB, ownership, screening, risk, approvals and exceptions under stable identifiers.
- Evidence to retain
- Complete sampled onboarding pack.
- Primary citation
- Operational control supporting Decree 144-2014 and CNBS Resolution SB 348/2016
Maintain one reconstructable monitoring and reporting pack per case.
- Implementation action
- Link transactions, alerts, analysis, approvals, UIF submissions and post-filing controls while protecting ROS confidentiality.
- Evidence to retain
- Complete sampled case pack and access log.
- Primary citation
- Operational control supporting Decree 144-2014 arts. 27-31 and Resolution arts. 55-65
Primary-source register
12 sources used for this checklist
Use these links to verify the underlying legislation, regulator guidance, reporting procedures and international status statements.
- Special Law Against Money Laundering - Decree 144-2014Congress of Honduras / CNBS · Primary legislation
- Regulation of obligations and controls - Resolution SB 348/27-04-2016CNBS · Binding financial-sector regulation
- Law regulating designated non-financial activities and professions - Decree 131-2014Congress of Honduras / CNBS · Primary legislation
- CNBS national AML/CFT legal inventoryCNBS · Official legal inventory
- UIF guidance on suspicious-operation reportsUIF / CNBS · Official FIU guidance
- UIF data-reporting manualUIF / CNBS · Official reporting guidance
- UN sanctions list and current UIF communicationsUIF / CNBS · Official sanctions guidance
- Mercantile Registry of Francisco Morazan authority and servicesCCIT / Institute of Property · Official delegated registry guidance
- Constitution of Honduras, updated 2025Judicial Branch of Honduras · Primary constitutional text
- Draft Law on Personal Data Protection and Habeas DataIAIP · Official draft - not enacted law
- Honduras seventh enhanced follow-up reportFATF / GAFILAT · Authoritative regional assessment
- FATF black and grey lists - 13 February 2026FATF · Authoritative current status
Direct answers
Honduras KYC, KYB and AML questions
Who receives suspicious-operation reports in Honduras?+
The Unidad de Inteligencia Financiera (UIF), attached to the CNBS Presidency, through its authorised reporting channel.
What is the ROS deadline?+
Decree 144-2014 requires immediate communication. Resolution SB 348/2016 sets outer limits of 60 calendar days for a first ROS and 30 for supplements from the relevant activity; these limits should never be used to delay an urgent statutory report.
Is suspicion tied to a monetary threshold?+
No. A ROS is required regardless of amount, nature or customer type. Periodic transaction reports separately use BCH-set thresholds.
How long are AML records retained?+
At least five years after the relationship or transaction ends, depending on the record and applicable rule.
Is beneficial ownership only a registry check?+
No. The obliged entity must identify the natural person who ultimately owns or controls the customer and independently verify the ownership and control chain.
Is there one public national beneficial-ownership register?+
The reviewed official materials did not establish a single complete public database. Use the competent registry and independently obtain and verify ownership and control evidence.
Is the IAIP personal-data bill enacted?+
No enacted comprehensive general private-sector law was confirmed. The IAIP document is labelled as a draft; constitutional, secrecy, transparency and sector duties still apply.
Is Honduras on a FATF public list?+
Honduras was not named on FATF's 13 February 2026 increased-monitoring or call-for-action lists reviewed on 9 August 2026. Recheck the live lists before reliance.
Research and review method
VOVE ID Compliance Research maps the regulatory perimeter, translates obligations into operational controls, links each material claim to a source and records the date and version of every review.
General regulatory information, not legal advice or a licence determination. Reviewed 9 August 2026 and legally scoped as applicable on that date. Confirm live UIF reporting channels, BCH thresholds, APNFD rules, registry and beneficial-ownership access, sanctions release procedures, privacy requirements and product-specific licensing with the competent authority and qualified Honduran counsel before launch.