The amended Regulations implement obligations introduced by the 2025 reform, including changes concerning beneficial ownership, Politically Exposed Persons, transaction aggregation, audits, recordkeeping and enforcement proceedings.
On March 27, 2026, a decree amending the Regulations of the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds (“LFPIORPI”) was published in the evening edition of the Federal Official Gazette and entered into force on March 28, 2026.
The amended Regulations implement several changes introduced by the LFPIORPI reform effective since July 17, 2025, including new Vulnerable Activities, enhanced compliance obligations, updated thresholds and the incorporation of concepts such as Politically Exposed Persons (“PEPs”) and Beneficial Owners, with a reduced 25% ownership threshold.
Full implementation of the new framework, however, also requires amendments to the general rules. Until those rules are updated, certain obligations —including official forms, PEP consultation procedures and specific audit requirements— will continue to be governed by the provisions in effect as of July 17, 2025.
Key changes introduced by the amended Regulations include:
• New definitions. The Regulations incorporate the concepts of “Reports,” the “PEP List” and “Persons Entrusted with Public Faith.” The latter category includes, among others, notaries public, commercial brokers, public officials authorized to certify legal acts and facilitators under the General Law on Alternative Dispute Resolution Mechanisms.
• Expanded powers for the FIU and SAT. The Financial Intelligence Unit (“FIU”) may issue the format through which authorities provide information for the PEP List, establish exceptions through resolutions published in the Federal Official Gazette, promote specialized units within the states and safeguard Notices and Reports relating to Vulnerable Activities.
The Mexican Tax Administration Service (“SAT”) also receives broader verification and supervisory powers, including with respect to Notices, Reports, audit opinions and documentation addressing identified deficiencies. The Regulations further contemplate electronic notifications, requests for supporting documentation and, where applicable, the use of public force assistance.
• Aggregation of transactions. Transactions carried out over a period of up to six months may be aggregated to determine whether reporting thresholds are reached. A Notice must be filed once the final transaction causes the applicable threshold to be met or exceeded, without waiting for the six-month period to end.
• 24-hour Notices. The requirement is reinforced so that a Notice may be required even when a transaction is not completed, provided information is available regarding the person who attempted to carry it out. Practical implementation will depend on the corresponding updates to the official forms.
• Verification and enforcement proceedings. Specific deadlines are introduced for certain SAT actions. The Regulations also allow the authority to support its decisions with information contained in its own files and databases or provided by other authorities.
• Registration and audits. Registration obligations expressly extend to trusts and other legal arrangements. The Regulations also require the retention of internal or external audit reports and documentation evidencing remediation of identified observations.
• Beneficial Ownership. The terminology is updated to expressly refer to the Beneficial Owner, consistent with the amended statutory framework.
• Record retention. The retention period for Notices and Reports is extended from five to ten years, calculated from their filing and the issuance of the corresponding electronic acknowledgments.
One of the most significant developments is the introduction of a specific regime for Politically Exposed Persons.
The FIU will be responsible for compiling and classifying the PEP List based on information provided by the relevant authorities. Financial Institutions and persons carrying out Vulnerable Activities may also electronically consult the FIU to determine whether a Client or User qualifies as a PEP when such status cannot be established during the identification process.
Authorities required to provide information for the list must update it within five business days following any change.
The Regulations also introduce several additional clarifications:
• The date on which an act or transaction is deemed carried out will be determined in accordance with the general rules applicable to each Vulnerable Activity.
• Specific rules are established for identifying linked transactions in gambling, contests and sweepstakes, including those conducted through digital platforms.
• For loans and credit transactions, the relevant act will be deemed carried out when the funds are made available to the Client or User rather than upon execution of the agreement.
• Agreements with Collegiate Entities may remain in force for up to ten years and may be renewed subject to applicable requirements.
• A procedure is introduced for voluntarily acknowledging and remediating violations before SAT, supported by documentation demonstrating that the deficiencies have been corrected.
• The list of institutions authorized to issue AML/CFT training certificates is expanded.
The amended Regulations represent an important step in implementing Mexico’s new anti-money laundering and counter-terrorist financing framework. Their full operation will also depend on the amendment of the general rules, which are expected to address official forms, PEP consultation procedures, simplified identification measures, audit requirements and transaction-monitoring mechanisms.
Companies and persons carrying out Vulnerable Activities should therefore review their processes for customer and Beneficial Owner identification, transaction monitoring and aggregation, record retention, auditing, training and filing of Notices and Reports in order to align them with the new regulatory framework.
Von Wobeser y Sierra is available to assess the impact of these provisions and assist with the adaptation of AML/CFT compliance programs, controls and procedures.
The decree published in the Federal Official Gazette is available at:
https://www.dof.gob.mx/nota_detalle.php?codigo=5783547&fecha=27/03/2026#gsc.tab=0
