On July 16, 2025, a decree amending and supplementing various provisions of the Federal Law for the Prevention and Identification of Transactions Involving Illicit Proceeds (the “LFPIORPI” or “Anti-Money Laundering Law”) and Article 400 Bis of the Federal Criminal Code was published in the Official Gazette of the Federation (the “DOF”). This reform entered into force the day after its publication.

With this reform, Mexico strengthens its Anti-Money Laundering (AML) regime to align with the standards of the Financial Action Task Force (FATF), increasing oversight of vulnerable activities, tightening customer identification obligations, and imposing more severe sanctions for noncompliance, with implications not only for those carrying out vulnerable activities.

New Vulnerable Activity.

1. Receipt of Funds for Real Estate Development. The receipt of funds intended to carry out “real estate development” is added as a new vulnerable activity, defined as any project for the construction of buildings or the subdivision of plots for sale or rent.

Reinforced Obligations.

1. Identification of the Clients and their Beneficial Owners. The definition of “beneficial owner” is broadened to include, among other aspects, a lower ownership threshold (going from 50% down to 25%), potentially encompassing more individuals as “beneficial owners”. In addition, entities engaging in vulnerable activities must know their client and collect and retain information on both the client and their beneficial owner.
2. Retention of Information. Entities are now required to safeguard and prevent the destruction of records of transactions that allow for the reconstruction of individual operations, commercial correspondence, and KYC files. The retention period is extended from 5 to 10 years.
3. Use of Trusts (Fideicomisos). Special emphasis is placed on the obligations of those who carry out vulnerable activities through trusts.
4. Use of Cash. Cash use prohibitions are reinforced under certain conditions and thresholds, including when payment is made through a financial institution. The reform also sets the foundation for restrictions on payments made with fungible goods.
5. Strengthened sanctions. Authorities are empowered to suspend certain vulnerable activities and revoke licenses in certain cases. Additionally, new offenses are added to the list of crimes under the Anti-Money Laundering Law.

New Obligations for Those Engaged in Vulnerable Activities.

1. Registration in a Special Registry. A registry will be created for enrollment, registration and updates using official formats.
2. Politically Exposed Persons (“PEP”). Identified as the individuals who currently hold or formerly held public office in Mexico or abroad (and related persons), who must be specifically identified.
3. 24-Hour Suspicious Transaction Notices Entities must file reports within 24 hours when there are suspicions or indications that the funds involved may be of illicit origin.
4. Risk Assessments. Se deberán realizar evaluaciones con un enfoque basado en riesgos, para identificarlos y mitigarlos.
5. Internal Policies Manual. A manual containing the criteria, measures, and procedures necessary to comply with the Law, including obligations regarding PEPs, shall be prepared.
6. Training Programs. Annual training programs must be developed for senior management and the appointed Compliance Officer (who must be registered with the Ministry of Finance, SHCP).
7. Automated Monitoring. Entities must have automated mechanisms for continuous monitoring of operations and transactions.
8. Internal and External Audits. Entities must be reviewed by internal audit departments or an independent external auditor, depending on the risk level of their activities.
9. Spontaneous Voluntary Compliance. The authority may, on a one-time basis, waive sanctions when the entity complies spontaneously and before verification proceedings begin. If the benefit has already been used, fines may be reduced by up to 50%.

New Obligations for all Commercial Companies.

The inclusion of a new chapter in the Anti-Money Laundering Law imposes obligations on all commercial companies (sociedades mercantiles), regardless of whether they engage in vulnerable activities or not. These obligations relate to reporting through the Sistema de Publicaciones de Sociedades Mercantiles (PSM). The Ministry of Finance will oversee compliance, may conduct inspections, and impose sanctions for noncompliance. The new obligations include:

1. Notice of Transfers. Commercial companies must publish notices in the PSM system when ownership of shares or partnership interests is transferred or any rights over them are established and recorded in the company’s share or partner registry.
2. Registration of Beneficial Owners. Commercial companies must record the necessary information to identify their beneficial owners in the aforementioned system.

Next Steps

The reform entered into force the day after publication, with the following exceptions: (i) obligations relating to training and audits will become effective in 2026; and (ii) the Ministry of Finance has 12 months to adapt the general rules of the Anti-Money Laundering Law, which will outline timelines for the remaining obligations.

Although regulatory harmonization is still pending, organizations are advised to begin reviewing and updating their anti-money laundering policies and procedures, including:

1. Adjusting and strengthening internal policies and manuals to align with the new legal framework.
2. Evaluating their activities to determine if they fall within vulnerable activities, conducting a compliance diagnostic, and considering regularization through voluntary compliance.

Additionally, all business entities are advised to review their corporate processes to ensure compliance with the new reporting obligations.

Taking early action will be key to ensuring compliance and minimizing risks under the new regulation.

To view the decree, press here.

Our partner in charge of advising you and our expert in these matters (Carlos A. Chávez Pereda cacp@santoselizondo.com) and our team of lawyers, will be attentive to further define the new paradigms that this decision entails, as well as the way to face it in a timely and efficient manner.