On March 27, 2026, the decree amending, adding, and repealing various provisions of the Reglamento de la Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita (Regulations of the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds) was published in the Diario Oficial de la Federación (Federal Official Gazette) (“DOF”).

• • According to the amendments to the Regulations of the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds (the “Regulations” and the “Law”), among other things, clarifying provisions are established regarding the filing of reports for cumulative transactions, indicating that these must be filed when the established thresholds are reached with respect to a client or user.

• It regulates the requirements for the integration of a list of domestic politically exposed persons (“PEPs”) by the Mexican Financial Intelligence Unit (“FIU”).

• An exception regime is established that facilitates the Servicio de Administración Tributaria (Tax Administration Service, “SAT”) to impose administrative sanctions without the need to exhaust an administrative proceeding, also indicating that all information already held by SAT may be used to support its resolutions.

• Also, when SAT exercises its verification authority, it will not be required to demonstrate which databases it consulted nor to disclose the results of such consultation, provided that it concerns information or documentation that was generated or provided by the obligated subject.

• Finally, the obligations regarding safeguarding and preservation of information are substantially expanded, establishing that reports, statements, and their supporting documentation must be preserved for a minimum period of 10 years.

• The transitional period for the issuance of new general rules originally provided in the Law's amendment is not modified; that is, these are expected to be issued on June 30, 2026.

I. Regulation Content.

I.1. General Aspects.

• According to the amendments, definitions are adjusted, including the express introduction of “Statements” as an obligation differentiated from “Reports” as well as the explicit inclusion of trusts and other legal entities as obligated subjects.

• Clarifying provisions regarding the filing of reports for cumulative transactions are included, establishing that the obligation to file the corresponding “Report” is triggered when, with respect to the same client or user, the applicable threshold is reached or exceeded, considering the accumulation of transactions within a period of up to six months, without the need to exhaust such period.

• Likewise, the obligation to file so-called “24-hour” reports is expressly introduced in the Regulations, even when the act or transaction has not been completed, provided there are sufficient elements to identify the person who attempted to carry out the transaction as a client or user, that is, what is known as a report for “attempt”.

• It is specified that the application of simplified identification measures for clients or users will only be appropriate when derived from their risk-based approach assessments at the entity level.

• Additionally, the specification regarding amounts, thresholds, and specific conditions applicable to vouchers, coupons, and electronic wallets is eliminated, suppressing the criteria that limited the filing of Reports, so that the applicability of identification and Report filing obligations must be determined exclusively based on the scenarios provided in the Law and, where applicable, in the general rules.

• Also, the criteria for determining the timing and amount of the act or transaction in certain non-financial designated businesses and professions (“DNFBPs”) are adjusted, establishing that, (i) in loan, lending, or credit transactions, these will be considered performed when the funds are effectively made available to the client, and that, (ii) in money or securities transfer or custody services, the lack of determination of value does not exempt from the obligation to file a Report, considering such transactions as reportable in all cases.

I.2. PEP List.

• The mechanisms for the integration, updating, and administration of the domestic PEP list under FIU's responsibility are regulated, establishing that competent authorities and public entities must provide, in the format and electronic medium defined in the general rules, information corresponding to public positions and persons who should be considered PEPs, as well as their updates within 5 business days following any relevant modification.

• For their part, it is provided that private parties and obligated subjects may only consult the FIU, through the electronic medium determined by the FIU, in a restricted manner and case-by-case basis, to verify whether a client or user person is included in the PEP list, without this implying access, reproduction, or disclosure of the complete content of the list.

• In this context, a strict confidentiality regime applicable to this list is established, specifying that such information must comply with the provisions of the Ley General de Transparencia y Acceso a la Información Pública (General Law on Transparency and Access to Public Information) and the Ley de Seguridad Nacional (National Security Law), so that information classified as reserved or confidential may not be shared with any person, authority, or entity, whether domestic or international.

• Along the same lines, the FIU may only share specific and necessary information from its PEP list with decentralized bodies of the Secretaría de Hacienda y Crédito Público (Ministry of Finance and Public Credit) that exercise supervisory functions in matters of money laundering prevention, and only following execution of the corresponding agreement, exclusively for the exercise of such powers.

I.3. Sanctions.

• Likewise, an exception regime is regulated that allows SAT to impose administrative sanctions without the need to exhaust an administrative sanctioning proceeding, when the following circumstances occur:

• Omission or late compliance with information requests,
  • Failure to file reports, statements, or mandatory documentation, or
  • Delivery of incomplete or different information than requested, even after the obligated subject has been required.

• It is also established that, when SAT exercises verification powers, it will not be required to demonstrate which databases it consulted or to communicate the results of such consultations, provided that it concerns information or documentation that was previously generated or provided by the obligated subject itself.

• Likewise, the procedure for spontaneous compliance through a signed writing addressed to SAT is established, with clear and complete acknowledgment of faults committed, corresponding transactions and periods, declaration under oath that irregularities have been completely corrected along with documentation evidencing such compliance, as a condition to access the benefits provided in Article 55 of the Law, subject to compliance with general administrative provisions.

• Finally, the amendments substantially expand obligations regarding safeguarding, preservation, and custody of information, establishing that Reports, Statements, supporting documentation, and electronic acknowledgments must be preserved for a minimum period of ten years, both by obligated subjects and by Collegiate Entities.

II. Transitory Regime.

Finally, transitional provisions are incorporated that regulate the entry into force and gradual application of various obligations, establishing specific rules for their implementation, among which the following stand out:

Obligation	Fecha de exigibilidad	Condición o consideraciones relevantes
Entry into force of the decree	Day following its publication in the DOF	Administrative provisions that oppose the decree are repealed.
Registration for DNFBPs	From July 17, 2025	Previous existing forms must be used until FIU publishes updated official forms contemplating new scenarios (trusts, legal entities, customs agencies, etc.).
Filing of Reports and Statements under new regulations	Gradual, according to obligation	Subject to updating of FIU's official annexes and new rules forms; in the meantime, existing forms apply.
Reports for notarizations or formalization (art. 17, sec. XII, A and B)	Deferred	Must be filed according to the specific format that FIU publishes through a resolution in the DOF.
Reports in Article 17, section XII, subsection A, items a), c), and d)	From July 17th, 2025	The new threshold or reporting scenario must be considered only with respect to acts or transactions performed from that date.
Reports of Article 17, section XII, subsection D	Deferred	Must be filed according to the specific format that FIU publishes through a resolution in the DOF.
Reports and Statements under Article 17, section V Bis	Transitional	Will continue to be filed according to existing Annex 5 B of the Regulations until it is modified or updated.
Reports under Article 17, section X, paragraph b) (transfer or custody)	Transitional	While the format is not updated, the value 0.01 must be declared in the corresponding field of Annex 10 of the Regulations.
Date of act or transaction (new rules of Article 5 of the Regulations)	Gradual	Applicable according to specific rules by DNFBP and to existing forms, until their update.
New reporting scenarios and thresholds (cumulation, scenarios)	From July 17th, 2025	Only apply to acts or transactions performed from that date, even when forms are not updated.
Information preservation and safeguarding (10 years)	From July 17th, 2025	Calculation of the new period is not retroactive; applies only to acts or transactions performed from that date.
24-hour Report (Article 7 Bis of the Regulations)	Conditioned	Its enforceability depends on updating of official annexes and forms contemplating such scenarios.
Mechanisms, systems, and alternative means issued by FIU	From their publications	Must be observed according to general administrative provisions in force as of July 17, 2025 and their subsequent modifications.

If you have any questions concerning the scope or implementation of this article, please contact us.

Bernardo Mendoza
Partner
bmendoza@k-g.com.mx

Dorothy Lerch
Counsel
dlerch@k-g.com.mx

Karla P. de la Torre
Associate
kdelatorre@k-g.com.mx

Gerardo H. Estrada
Attorney
gestrada@k-g.com.mx