Martín Aylwin

Martín Aylwin advises national and multinational companies on the design, implementation, monitoring and audit of compliance programmes, with a focus on criminal compliance under Chilean Law No. 20,393 on Corporate Criminal Liability and Chile's Economic Crimes Law (Law No. 21,595), which significantly expanded the scope of corporate criminal liability in Chile from 2024 onwards.

Criminal Compliance Programme Design and Implementation:

Martín leads end-to-end mandates covering risk identification, risk matrix design, drafting of internal regulations, policies and control procedures, and the operationalisation of governance mechanisms including whistleblower channels and monitoring systems. A distinctive feature of his practice is the deployment of long-term implementation mandates, accompanying clients for periods of up to twelve months to ensure that compliance programmes are effectively embedded across all levels of the organisation, rather than remaining formal documents.

Compliance Audits and Programme Evaluation:

Martín conducts compliance audits against Chilean regulatory requirements and international standards, including ISO 37001 (Anti-Bribery Management Systems) and ISO 37301 (Compliance Management Systems). He is one of Chile's few legally accredited lead auditors for ISO 37001, and acts as legal auditor for AENOR, Spain's leading standardisation and certification body, in anti-bribery audits of regulated companies in Chile and Peru.

International and Cross-Border Compliance:

Martín advises multinational clients on the local implementation of international compliance frameworks, including requirements under the US Foreign Corrupt Practices Act (FCPA), UK Bribery Act, Canada's Corruption of Foreign Public Officials Act (CFPOA), and France's Loi Sapin II. He works with companies from the United Kingdom, Czech Republic, Canada, Argentina and Spain to align their Chilean operations with headquarters' global compliance standards.

Board-Level Governance and Training:

Martín designs and delivers tailored compliance training programmes for boards of directors, senior executives and employees, translating complex legal obligations into practical guidance for different organisational levels.

Internal Investigations:

In coordination with Aylwin Matta's criminal law partner, Martín supports companies in the conduct of internal investigations into alleged breaches of law or internal regulations, combining compliance and criminal law expertise within a single team.

Martín Aylwin's career reflects an uncommon trajectory in the Chilean legal market: from public sector legal work, through senior in-house compliance leadership at one of Latin America's largest corporate groups, to founding an independent compliance practice.

He began his career as an associate at Aylwin Abogados, before moving to the Legal Division of Chile's Ministry of Environment, where he developed expertise in environmental regulation and public enforcement, a foundation that continues to inform his environmental compliance advisory work.

He subsequently joined Falabella Group, the multinational retail and financial services conglomerate with operations across Latin America, where he spent several years in progressively senior compliance roles. He served as Senior Compliance Lawyer, Deputy Compliance Manager at Banco Falabella, and interim Corporate Compliance Manager at Falabella S.A. In these roles, he worked with business units across several countries on the rollout of the group's corporate compliance standards, advising boards and senior executives on risk and integrity matters.

This in-house experience gave Martín a direct understanding of the operational constraints facing compliance departments: the budget pressures, internal politics and organisational dynamics that determine whether compliance programmes work in practice or remain theoretical frameworks.

In 2023, he founded Aylwin Matta's compliance practice, channelling this institutional knowledge into an external advisory model built on practical, business-aligned solutions. The practice has grown rapidly, advising over 40 companies across more than 12 sectors, with several clients retaining the firm as permanent compliance advisor following the initial mandate.

Alongside his advisory practice, Martín holds a core faculty appointment at Universidad del Desarrollo Law School (a permanent academic position) where he teaches compliance and environmental law. He also lectures in postgraduate programmes at Pontifical Catholic University of Chile and Universidad San Sebastián.

Society of Corporate Compliance and Ethics (SCCE) — Certified Compliance and Ethics Professional – International (CCEP-I).

Aylwin Fernández, M. and Alfaro Cornejo, C., "Una revisión de la responsabilidad extendida del productor en Chile a diez años de la publicación de la Ley N.° 20.920", Actualidad Jurídica, No. 53, Universidad del Desarrollo, January 2026.

Aylwin Fernández, M. and Currie Ríos, R., "Desafíos para las empresas en un escenario de cambio climático: ¿El fin del business as usual?", Revista de Derecho Ambiental, No. 13, Universidad de Chile, 2020.

Aylwin Fernández, M., "Regulating Foreign Direct Investment in Chile: Is the New Regime a Step towards the Right Track?", ICSID Review — Foreign Investment Law Journal, Oxford University Press, 2019.

Aylwin Fernández, M., and Bornitck, D "La ley N° 20.920 y la era 'REP': Un cambio de paradigma en el manejo de residuos en Chile", Actualidad Jurídica, No. 36, Universidad del Desarrollo, 2017.

Martín advises a diverse client base including port and maritime terminal operators, salmon farming groups, energy generation and transmission companies, renewable energy developers, insurance and financial services groups, higher education institutions, entertainment and events operators, transport and logistics companies, and food and beverage producers. His clients include both Chilean corporates and local subsidiaries of multinational groups headquartered in the United Kingdom, Spain, Argentina, France, Czech Republic and Canada.

ISO 37001 Anti-Bribery Audits — Chile and Peru. Martín acted as accredited legal lead auditor for AENOR, Spain's leading standardisation and certification body, in a series of ISO 37001 anti-bribery management system audits conducted in Chile and Peru. The audited entities included Chile's largest water utility, a major energy provider, and Peru's state-owned oil company. This is an ongoing mandate involving recurring audits across the region.

Global Risk Management Framework and Crime Prevention Programme — UK Insurance Group (Chile). Martín advised the Chilean subsidiary of a global UK-based insurance broking and risk management group on two simultaneous mandates: the local implementation of the group's proprietary global risk management framework, particularly in relation to financial crime and anti-money laundering compliance; and the deployment of a crime prevention programme under Chile's Economic Crimes Law (Law No. 21,595).

Crime Prevention Programme — Private Port Operator (Chilean Patagonia). Martín advised a leading private port operator in Chilean Patagonia on the design and implementation of a crime prevention programme under Law No. 20,393. Following completion of the initial mandate, the client retained the firm as its permanent compliance advisor.

Partner, Compliance — Aylwin Matta (2023–present). Founded and leads the firm's compliance practice. Advises Chilean companies and the local subsidiaries of multinational groups on the design, implementation, audit and monitoring of criminal compliance programmes under Chilean Law No. 20,393 and the Economic Crimes Law (Law No. 21,595), as well as on international compliance standards including ISO 37001, ISO 37301, FCPA and UK Bribery Act requirements.

Interim Corporate Compliance Manager — Falabella S.A. Acted as the group's interim Chief Compliance Officer, with responsibility for overseeing compliance functions across one of Latin America's largest multinational retail conglomerates.

Deputy Compliance Manager — Banco Falabella. Led compliance operations for the financial services subsidiary of Falabella Group, managing regulatory relationships and supervising compliance teams.

Senior Compliance Lawyer — Falabella Group. Advised on compliance matters across the group's business units and countries.

Lawyer — Legal Division, Ministry of Environment of Chile. Focused on environmental regulation and public enforcement.

Associate — Aylwin Abogados. Worked in the firm's litigation and corporate practices.

Alberto Hurtado University

LL.B

2004 - 2009

University of Melbourne

Master of Laws (LL.M)

2015 - 2016

Excellence in Teaching Award — Academic Year 2021

Postgraduate Programme, Faculty of Law, Universidad del Desarrollo

2021

Martín advises companies across a broad range of industries. His sector experience includes energy (electricity generation, transmission and distribution; oil and gas; renewable energy), salmon aquaculture and fisheries, ports and maritime logistics, insurance and financial services, education (higher education institutions), entertainment and hospitality, food and consumer goods, transport and logistics (road and maritime), mining, telecommunications, retail, and water and sanitation utilities.

In several of these sectors, particularly energy, salmon aquaculture and ports, Martín has developed specific expertise in the risk profiles and regulatory dynamics that shape compliance requirements.

Chile is Martín's primary jurisdiction, where he advises on corporate compliance under Law No. 20,393 and the Economic Crimes Law (Law No. 21,595), as well as environmental compliance under Chilean regulatory frameworks.

Martín also works on cross-border mandates involving the local implementation of international compliance frameworks applicable to multinationals operating in Chile. This includes alignment with requirements under US (FCPA), UK (Bribery Act), Canadian (CFPOA) and French (Loi Sapin II) legislation, as well as global standards including ISO 37001 and ISO 37301. Clients have included companies headquartered in the United Kingdom, Czech Republic, Canada, Argentina and Spain.