The Firm

An institutional advisory firm
built around compliance, risk
and regulated financial infrastructure.

Mercantil Financial Group is a specialist advisory firm focused on the operational, regulatory and compliance needs of regulated digital asset businesses, fintechs and modern financial institutions. We are not a traditional law firm — we are the operational layer between our clients and the institutional counterparties, supervisors and auditors they answer to.

01 — POSITION

Specialist, not generalist.

Mercantil is not a full-service law firm and does not pretend to be one. We do four things — compliance, regulatory, audit, infrastructure — and we do them for regulated digital asset and financial services businesses.

02 — OPERATING MODEL

Embedded with clients.

We do not deliver memos and disappear. Mercantil operates as the embedded compliance, regulatory and audit function for clients who require institutional-grade output but cannot internalize that capability immediately.

03 — STANDARD

Built for counterparty diligence.

Every deliverable is built to the standard a Tier-1 correspondent bank, fund administrator or supervisory examiner would expect to see. That is the benchmark, not local market practice.

Firm milestones

How the practice was built.

Mercantil's practice has matured alongside the regulatory frameworks it operates under. The milestones below reflect the firm's regulatory, governance and infrastructure evolution.

2014
Practice founded

Mercantil Financial Group established in Santo Domingo, Dominican Republic. Initial focus on AML/CFT compliance support for regulated FX, securities and banking entities operating under SIB and SIV supervision.

2016
First Compliance-as-a-Service program

Launch of the firm's embedded CCO operating model for non-bank financial institutions. The model becomes the firm's signature delivery format for clients requiring sustained compliance capability without full in-house build.

2018
FATF VASP recommendations — practice expansion

Following the publication of FATF's updated guidance on Virtual Asset Service Providers (R.15), the firm extends its practice to crypto-native businesses. First VASP advisory engagements undertaken in DR, Panama and offshore jurisdictions.

2019
Travel Rule advisory capability

Buildout of the firm's Travel Rule advisory practice in response to FATF R.16. First end-to-end Travel Rule implementations delivered for VASPs operating across U.S., EU and offshore corridors.

2020
Cross-border governance framework

Formalization of the multi-jurisdictional governance framework Mercantil applies to clients operating across home, host and counterparty supervisory regimes. Allied counsel network expanded to BVI, Cayman, Spain.

2021
Independent Audits practice formalized

Mercantil's AML independent testing, KYT effectiveness review and sanctions control testing practices formalized as a distinct service line. First annual independent AML testing programs delivered to regulated VASPs.

2022
FATF Mutual Evaluation support

Engagements supporting client readiness for FATF/GAFILAT mutual evaluation rounds in the LATAM region. Technical compliance and effectiveness readiness packages delivered across multiple supervised entities.

2023
Correspondent banking readiness practice

Formal launch of the Correspondent & Counterparty Readiness practice. Wolfsberg DDQ preparation, counterparty packs and onboarding remediation programs developed in response to de-risking pressure on crypto-native businesses.

2024
Compliance Command Center operating model

Mercantil consolidates its dashboards, monitoring, reporting and case management workflows into a single operating surface for retained clients — providing real-time visibility into compliance posture, alerts and remediation.

2025
200+ regulated counterparties

The firm's active book reaches over 200 regulated counterparties across 15+ jurisdictions, including VASPs, exchanges, OTC desks, PSPs, MSBs, neobanks, stablecoin issuers and cross-border payment operators.

2026
Institutional repositioning

The firm formally repositions as Compliance, Risk & Financial Infrastructure for Regulated Digital Asset Businesses — focused exclusively on the institutional segment and institutional counterparty readiness.

Leadership

Practice leadership.

The practice is led by a small senior team. Mercantil deliberately keeps a flat structure — clients work directly with the partners and senior counsel responsible for their matters.

MANAGING PARTNER · CCO

Marino A. Marrero Báez

CEO · Mercantil Financial Group
Co-Founder · AlfredPay
MAM

Managing Partner and Chief Compliance Officer of Mercantil Financial Group. Leads the firm's AML/CFT, VASP licensing and regulatory advisory mandates for institutional counterparties across LATAM and offshore jurisdictions. Senior advisor to digital asset operators, PSPs, exchanges and regulated financial institutions on financial crime prevention, independent AML testing and supervisory readiness.

CREDENTIALS
  • ACAMS Member · #1000830276
  • ACFCS Member · #21736
  • Maxwell Leadership Certified Team
SPECIALIZATIONS
AML/CFT Program Design VASP Compliance & Licensing Financial Crime Prevention Regulatory Advisory Independent AML Testing
PARTNER · COMPLIANCE

S. Acosta Lebrón

Head of AML/CFT & Travel Rule Practice
SA

Leads the firm's AML/CFT, KYT and Travel Rule practice. Senior compliance officer with prior tenure in regional and international banking — responsible for designing and operationalizing embedded compliance programs for VASPs, exchanges, payment service providers and cross-border operators. Focuses on FATF Recommendation 16 implementation, transaction monitoring effectiveness and sanctions screening governance for institutional counterparties.

FOCUS
AML/CFT KYT Travel Rule Sanctions
PARTNER · INDEPENDENT AUDITS

R. Almonte Reyes

Head of Independent Audits & Assurance
RA

Leads the firm's Independent Audits and Assurance practice. Background in risk advisory and internal audit for regulated financial institutions — specializes in annual AML independent testing, governance and control reviews, audit remediation programs and correspondent banking readiness packages produced to the standard expected by Tier-1 corresponding banks, fund administrators and supervisory examiners.

FOCUS
Independent Testing Governance Reviews DDQ Remediation
EXTENDED COUNSEL · 18 SENIOR PROFESSIONALS · DR · USA · PANAMA · COLOMBIA · MEXICO · EL SALVADOR · COSTA RICA
Standards & Frameworks

The standards we operate against.

Mercantil's programs, controls and operating procedures are designed around the leading international standards for compliance, security, risk and continuity. These are frameworks applied to client programs and infrastructure — not firm-level certifications.

ISO 37301
Compliance Management Systems
Framework-aligned
ISO 27001
Information Security Management
Framework-aligned
ISO 31000
Risk Management
Framework-aligned
ISO 22301
Business Continuity
Framework-aligned
FATF Recommendations
AML/CFT international standards
Built considering
Wolfsberg Principles
Correspondent banking, AML
Built considering
FinCEN-aligned controls
U.S. financial crime controls
Reference framework
Risk-Based Approach
FATF methodology
Applied across programs
Practice in numbers

The practice today.

200+
Regulated counterparties
15+
Jurisdictions covered
500+
AML & governance reviews
8
Years of practice
Institutional Access

Engage Mercantil.

Practice intake under NDA from the first conversation. Scope, fee structure and engagement letter typically returned within 5 business days.