Flash News: Reform to the Anti-Money Laundering Law (LFPIORPI) and Federal Penal Code. As we informed you in our communications from October 2024 and June 2025, the Congress of the Union approved, in an extraordinary session, the decree that substantially reforms the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (LFPIORPI) and the Federal Penal Code (CPF).
Flash News: Reform to the Anti-Money Laundering Law (LFPIORPI) and Federal Penal Code. As we informed you in our communications from October 2024 and June 2025, the Congress of the Union approved, in an extraordinary session, the decree that substantially reforms the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (LFPIORPI) and the Federal Penal Code (CPF). The decree was voted in the Chamber of Deputies on June 28, sent to the Executive and published today in the Official Gazette of the Federation (DOF), coming into force the day after its publication.
This approval occurs in a particularly sensitive context for the financial sector, following: (i) the recent measures adopted by the Financial Crimes Enforcement Network (FinCEN) of the United States Department of the Treasury, which identified three Mexican institutions as of primary concern in terms of money laundering, in relation to financing schemes for fentanyl trafficking and chemical precursors, and (ii) the evaluation of Mexico by the Financial Action Task Force (FATF) in 2025.
Although the reform seeks to strengthen the regulatory framework, the main concern of the sector is that this text equates, in regulatory and administrative burden, the Vulnerable Activities carried out by non-financial entities with financial institutions. The associated compliance costs and the severity of the sanctions raise doubts about whether the regulatory burden will generate useful and proportional information to the effort required by the new obligations.
What was approved and what changed? The published text retains several of the axes originally proposed in the reform initiative and detailed later. However, the last version discussed no longer incorporated the inclusion of terrorism financing within the object of the LFPIORPI, one of the initial pillars of the proposal. For this version discussed by the Chamber of Deputies, the Senate eliminated all reference to this component, leaving it out of the reformed provisions both in the LFPIORPI and in the CPF.
This reform incorporates very relevant technical clarifications and adjustments to the AML legislation, which we analyze below:
Key Points on Implementation:
A. Immediate entry into force with staggered deadlines: The decree comes into force the day after its publication in the DOF. However, some specific provisions, such as obligations in terms of training, auditing, evaluation under a Risk-Based Approach, Internal Policy Manual, personnel selection processes, and automated mechanisms for monitoring operations, will be subject to general rules that the Ministry of Finance and Public Credit (SHCP) must issue within 12 months following the publication in the DOF.
B. Supplementary Laws: The General Law of Credit Instruments and Operations is recognized and added as a supplementary law to the LFPIORPI.
C. Controlling Beneficiary. The reform modifies the definition of “Controlling Beneficiary” in the LFPIORPI, reducing the threshold for its identification regarding voting control in a company, from 50% to 25%. This modification implies that more individuals must be identified and registered as controlling beneficiaries by entities subject to the LFPIORPI. Commercial companies must also: (i) identify and register their Controlling Beneficiaries, and (ii) register any transfer of ownership or constitution of rights of any nature (e.g., pledge) over shares or stock, through the electronic system managed by the Ministry of Economy of Mexico. This registration adds on one hand, and complements on the other, both the update notice of partners and shareholders currently managed by the Tax Administration Service (SAT), and the notices contemplated in the General Law of Commercial Companies (LGSM) (arts. 73 and 129). However, unlike the LGSM, the LFPIORPI establishes sanctions for non-compliance with this registration to obligated subjects, with fines ranging from 2,000 to 10,000 times the UMA.
D. Politically Exposed Persons (PEPs) and similar. As in the prudential regulation for financial institutions, the concept of PEPs is included in the LFPIORPI, as well as a generic concept for similar persons (“…as well as persons related to them”), which will be limited by the SHCP through general rules.
E. Modifications to article 17 – Modification of thresholds and new vulnerable activities:
i. Art. 17 sec. II. – Service cards, credit, prepaid, and monetary value storage instruments: The conditions related to the issuer or merchant maintaining a business relationship with the acquirer, that the instruments allow fund transfer, or that their marketing is carried out occasionally, are removed from the section.
ii. Introduction of New Vulnerable Activities in the Real Estate Sector: Section V Bis of article 17 is added, classifying as a vulnerable activity the reception of resources destined for real estate developments for sale or rent purposes. This measure expands the scope of the law to cover both final transactions and the financing stage in real estate developments.
iii. Art. 17 sec. VI – Jewelry, metals, and precious stones: The notice threshold in the habitual commercialization of jewelry, metals, and precious stones is modified. Previously, the obligation to give notice only applied to cash transactions exceeding a certain amount. With the reform, the threshold is extended to any act or operation exceeding that amount, regardless of the payment method used.
iv. Art. 17 sec. X – Transfer or Custody
