On July 16th, 2025, the Decree amending and addingvarious provisions to the Federal Law for the Preventionand Identification of Operations with Illicit Proceeds(“LFPIORPI”) was published in the Official Gazette of theFederation (“DOF”). With this publication, the reform hasformally entered into force, marking the beginning of aregulatory adjustment process for individuals and entitiesengaged in Vulnerable Activities.
Responds
The reform responds to observations made by the FATF,aiming to align Mexican regulations with its 40Recommendations on anti-money laundering (AML).
Redefines
The concept of Beneficial Owner is redefined,broadening the criteria for effective control and imposing new identification obligations for all transactions.
Replaces
The minimum wage is replaced by the UMA (Unidad deMedida y Actualización) as the unit of measure to determine thresholds in transactions and penalties.
Vulnerable Activity
New Vulnerable Activity: Real Estate Development, withthe obligation to submit a notice if funds exceeding 8,025 UMAs are received for the sale or rental of real estate.
Expands
Regulation on virtual assets is expanded, includingtransactions carried out from abroad by Mexican citizens and establishing new reporting thresholds (210 UMAs and 4 UMAs). Additionally, the implementation of the Travel Rule is incorporated, requiring the collection, retention, and disclosure to authorities of information on the originator, recipient, and Final Beneficiary of each transaction.
Obligation
Obligation to identify Politically Exposed Persons (PEPs)and monitor their transactions.
Documentation
Documentation related to Vulnerable Activities must bekept for at least 10 years, either physically or in electronic format, at the address registered with the SAT.
New Obligations
New obligations: independent audits, trainingprograms, personnel selection policies, risk-basedapproach, and automated monitoring mechanisms.
Expands
Restrictions on the use of cash transactions involvinghigh-value goods are expanded, even when the payment is made through a financial institution.
Authors:
Diego Ramos, Partner
Email:dramos@rrs.com.mx
Antonio Casas, Partner
Email: acasas@rrs.com.mx
Sofia Rojas, Associate
Email: srojas@rrs.com.mx
Alejandra Sánchez, Paralegal
Email: asanchez@rrs.com.mx