On July 16, 2025, amendments (the “Amendment”) to the Federal Law for the Prevention and Identification of Operations with Resources of Illicit Origin (“LFPIORPI” or “Anti-Money Laundering Law”) and the Federal Criminal Code (“CPF”) were published in the Federation Official Gazette. This amendment seeks to strengthen anti-money laundering controls and greater regulation of activities and operators vulnerable to this crime.
Among the most significant changes are the new definitions introduced in the Anti-Money Laundering Law, particularly the redefinition of the Ultimate Beneficial Owner (UBO) concept. The threshold for identifying a UBO has been lowered from 50% to 25% ownership of the share capital with voting rights, which implies increased regulatory oversight over such individuals. In addition, a new chapter establishes the obligation for all commercial companies to register the necessary information to identify their UBOs in the Commercial Companies Portal. Furthermore, any changes to the UBO’s ownership stake must be reported through this platform to the Ministry of Economy.
In addition, the figure of the Representative in Charge of Compliance is defined, who must undergo annual training in money laundering prevention and the concept of Politically Exposed Person (“PEP”) and the specific obligation to identify and monitor their operations is incorporated.
The Reform classifies new activities as vulnerable: real estate developments (from the initial phase of raising funds for sale or rent), operations with virtual assets (cryptocurrencies) and now trusts that carrying out vulnerable activities will be subject to the corresponding anti-money laundering obligations.
The threshold for notice before a public notary for real estate transaction (now 8,000 UMAs1, previously 16,000) and incorporation or modification of trusts transferring ownership and guarantee (4,000 UMAs2, previously 8,025) is reduced, and notice by the public notary becomes mandatory for corporate transactions such as incorporation of companies, mergers, spin-offs and purchase and sale of shares regardless of the amount as well as the general obligation to thoroughly verify the identity and documentation of their clients.
Companies that habitually carry out vulnerable activities in terms of the Anti-Money Laundering Law must carry out periodic risk assessments, know the transactional profile of clients, and establish an internal compliance manual, in addition, they must implement automated monitoring systems to detect operations outside the usual profile.
Likewise, these companies will have the obligation to provide annual training in money laundering prevention for key employees, as well as the obligation to develop processes for the selection of their employees. Likewise, companies with a high risk level will have mandatory annual internal or external audits and the obligation to keep records related to vulnerable operations for at least 10 years.
In addition to the previous obligations, the Amendment establishes the obligation to file suspicious transaction reports within 24 hours of detection, even if the transaction does not materialize, in accordance with the guidelines that will be issued at a later date by the Ministry of Finance and Public Credit (Secretaría de Hacienda y Crédito Público or “SHCP”).
In accordance with these amendments, criminal penalties are provided for those who provide illegible or erroneous information in the notices to the authority, with prison sentences of 2 to 8 years and fines of 5003 to 20004 UMA, however administrative sanctions may be contested by means of a review before the SHCP or the Federal Court of Administrative Justice (Tribunal Federal de Justicia Administrativa).
With respect to the CPF, the Public Prosecutor’s Office shall be empowered at all times to investigate financial institutions engaged in operations involving resources derived from illicit sources. To initiate criminal proceedings, a complaint by the SHCP will be required, which shall be considered the victim or aggrieved party. This implies that the Financial Intelligence Unit (Unidad de Inteligencia Financiera) will be recognized as the victim in money laundering crimes involving the use of financial services, thereby broadening the scope of legal actions in this area
Although the Amendment came into effect on July 17, 2025, certain obligations will be binding as of the general rules issued by the SHCP, expected within a maximum period of 12 months.
The Mexican Government seeks to strengthen the regulatory framework in the country in the area of Money Laundering Prevention, and requires companies and parties bound by the Anti-Money Laundering Law to substantially strengthen their internal controls and meet new obligations with due diligence, good internal control and transparency.
[1] 2025: MXN $905,120.00 / USD $48,259.00
[2] 2025: MXN $452,560.00 / USD $ 24,130.00
[3] 2025: MXN $56,570.00 / USD $3,016.00
[4] 2025: MXN $226,280.00 / USD $12,065.00
If required any further information regarding the content of this Alert, please contact:
Fernando Eraña
Juan Carlos Izaza
Alberto Díaz de León
Ana Méndez
Matisse Flores
