On July 16, 2025, relevant amendments to the Federal Law for the Prevention and Identification of Operations with Illicit Resources (LFPIORPI) and the Federal Criminal Code were published in the Official Gazette of the Federation (DOF). These reforms came into effect on July 17, 2025, and aim to strengthen Mexico’s legal framework for the prevention of money laundering and terrorist financing, in line with the latest international standards.
Key Changes
- Expansion of Vulnerable Activities.
- New transactions in the real estate sector are included, such as construction activities and the receipt of funds for real estate developments.
- Cryptocurrency transactions originating abroad but directed at Mexican citizens are now subject to reporting obligations.
- New Thresholds for Virtual Assets.
- The reporting threshold is reduced from 645 to 210 UMAs per transaction (approximately MXN $23,700.00).
- Any transaction generating a commission greater than 4 UMAs must be reported, regardless of the transaction amount.
- Adjustments for Public Notaries and Commercial Notary Public.
- A unified regulatory framework is established for Notary Public and Commercial Notary Public, eliminating prior regulatory discrepancies between both types of obligated entities.
- New reporting thresholds are introduced, such as for the incorporation of legal entities and the creation of trusts: reporting is now required for amounts starting at MXN $452,500.00.
- Client and Beneficial Owner Identification.
- Requirements to directly identify clients and collect official documents are reinforced.
- In the case of legal entities and trusts, the beneficial owner must be precisely identified.
- Redefinition of Beneficial Owner.
- A beneficial owner is now defined as any person holding more than 25% of direct or indirect ownership (previously 50%).
- The concept is aligned with the terms “ultimate beneficiary” and “actual owner.”
- Record-Keeping Obligations.
- The retention period for documentation is increased from 5 to 10 years.
- Mandatory Training.
- An annual training program is required for key personnel, including management and compliance officers.
- Changes to the Sanctions Regime.
- The requirement of intent is eliminated for certain violations, allowing sanctions for negligent omissions that were not timely corrected.
- The Ministry of Finance and Public Credit (SHCP) may alert the competent authority in case of compliance deficiencies, particularly regarding notaries and public brokers.
At VAHG, we are ready to help our clients adapt to this new regulation. We are committed to providing ongoing advice while identifying and mitigating risks that may affect their businesses. Our legal services cover a range of areas, including:
✅ Review and update of internal policies.
✅ Identification of beneficial owners.
✅ Preparation of compliance manuals.
✅ Specialized training for your team.
✅ Preventive legal advice and response to regulatory requirements.
In case you need advice, please contact any of our Compliance & Due Diligence Lawyers:
Elvia Ríos Saldaña | Partner
Compliance & Due Diligence
+52 (33) 38171731 Ext 228 | erios@vahg.mx
| Luis Andrés Estrada Intriago | Senior Associate
Compliance & Due Diligence +52 (33) 38171731 Ext 224 | lestrada@vahg.mx |
Fernando Hernández de la Torre | Associate
Compliance & Due Diligence +52 (33) 38171731 Ext 237 | fhdelatorre@vahg.mx |
**The publication of this document does not constitute legal, accounting or professional advice of any kind, nor is it intended to be applicable to particular cases. This document only refers to laws applicable in Mexico.