On June 30, 2025, Mexico’s House of Representatives voted in favor of the draft decree amending, supplementing, and repealing various provisions of the Federal Law for the Prevention and Identification of Operations with Illicit Proceeds (Ley Federal para la Prevención e Identificación de Operaciones con Recursos de Procedencia Ilícita “AML Law” or the “Law”), as published in the Parliamentary Gazette (the “Bill”). The Bill can be consulted here, and has already been approved by the Senate, so it is expected that it will shortly be published in Mexico’s Federal Official Gazette (Diario Oficial de la Federación).

It is worth noting that, during its discussion in the extraordinary session of the Senate, the expansion of the intended scope in the original Bill—which included combating the financing of terrorism for the purposes of the Law and the Federal Criminal Code—was removed.

This removal results in Mexico's deficient compliance with the standards of the Financial Action Task Force (“FATF”), which, it is worth noting, is currently evaluating Mexico.

1. Reporting Thresholds Amendment.

The Bill proposes to amend the applicable transaction reporting thresholds applicable to: (i) the issuance or commercialization of service or credit cards, prepaid cards, and instruments for the storage of monetary value; (ii) public notaries and public brokers; and (iii) virtual asset service providers, that must be filed to Mexico’s Tax Administration Service (Servicio de Administración Tributaria “SAT”) under the following terms:

The Law distinguishes the applicable transaction reporting threshold amounts, measured against the daily UMA¹, as per the following table:

Type	Conditions	Amounts
Service or credit cards	When the cumulative monthly expenditure equals or exceeds:	805 UMAs. $91,077.70
Prepaid cards	When their commercialization or fund loading equals or exceeds:	45 UMAs per transaction. $5,091.30
Monetary value storage instruments	When their issuance, commercialization, or fund loading equals or exceeds:	645 UMAs per transaction. $72,975.30

Regarding the notices that public notaries must file, the reporting threshold is reduced as follows:

Operations	Amounts
Transfer or establishment of real property rights (in acts or transactions where the agreed price, cadastral value, market value, or guaranteed principal amount equals or exceeds:	8,000 UMAs $905,120.00
Incorporating legal entities and trusts	4,000 UMAs $452,560.00

The reportable events and thresholds for virtual asset operations are also amended and reduced under Section XVI of Article 17 of the AML Law, under the following terms:

Scenario	Amounts
When the obligated entity’s client or user transaction amount equals or exceeds:	210 UMAs MXN$23,759.40
When transactions resulting in service fee collection (regardless of designation) equal or exceeds:	4 UMAs MXN$452,560.00

2. Extraterritoriality of the Law regarding Virtual Assets.

The AML Law will have extraterritorial effects with respect to the habitual and professional offering of virtual asset exchange services, in cases where such transactions are carried out with Mexican citizens located in another jurisdiction.

3. New obligations for DNFBPs AML Programs.

The proposal also includes an expansion of the catalog of anti-money laundering (“AML”) obligations applicable to individuals or entities engaging in the Designated Non-Financial Businesses and Professions (“DNFBPs”) as set forth in the AML Law.

Virtual asset service providers are additionally required to obtain, maintain, and make available to competent authorities information regarding virtual asset transactions, including information about the originator, recipient, and, where applicable, the beneficial owner.

Now then, those individuals who carry out DNFBPs under the terms of the AML Law will be subject to a new set of obligations within the framework of the recommendations of the FATF, among which the following stand out:

• Obligated entities must conduct a risk-based assessment to identify, analyze, and understand the money laundering risks to which they are exposed, in order to adequately mitigate them.

• Accordingly, they must conduct an annual audit to evaluate the effectiveness of their compliance with the Law. This audit may be conducted internally, unless a high-risk exposure is identified—in which case it must be external and independent.

• Entities are required to develop an internal policies and procedures manual for compliance with the AML Law.

• Annual training programs must be implemented to ensure compliance with the AML Law.

• Entities must have automated systems in place to monitor transactions, identify those that fall outside the transactional profile of their clients, and perform aggregation and enhanced monitoring of transactions involving clients who are Politically Exposed Persons (“PEPs”) or otherwise considered high-risk.

• The obligation to identify and report to the SAT any transaction suspected of being related to criminal activity is elevated to the level of law. Such reports must be filed within 24 hours of detection.

• The threshold for determining effective control over a legal entity is lowered from 50% to 25% of share capital for the purpose of identifying Beneficial Owners.

• In addition, all commercial legal entities, regardless of whether they engage in DNFBPs or not, have the following obligations:
  • Register their beneficial owners in the system of Mexico’s Ministry of Economy (Secretaría de Economía).
  • Submit notices upon transfer of ownership or creation of rights over the titles representing shareholding or equity interests in said system.

4. Expansion of Authorities’ Powers.

The proposed reform also involves changes regarding the participation and powers of authorities involved in the supervision and oversight of compliance with AML obligations, particularly highlighting the role of the National Guard (Guardia Nacional “GN”) and the Ministry of Security and Citizen Protection (Secretaría de Seguridad y Protección Ciudadana “SSPC”) in monitoring compliance with the AML Law.

The draft Decree proposes incorporating the GN and SSPC as obligated entities required to implement training programs on AML matters, as well as granting the Ministry of Finance and Public Credit (“SHCP”) authority to coordinate with these agencies “for the purposes of the Law.”

Based on the foregoing, it is foreseeable that these authorities will, in practice, carry out certain delegated oversight activities to verify compliance with the Law.

This would be the case even though the draft Decree proposes to establish in the Law that supervision, verification, and monitoring of compliance with the AML Law will be carried out by the SAT.

5. Sanctions.

• The benefits under Article 55 regarding the voluntary compliance of obligated parties engaged in DNFBPs will be extended so that the SHCP may refrain, on a one-time basis, from imposing sanctions for the total number of infringements committed by the obligated party, provided that said party discloses all unfulfilled obligations and acknowledges its non-compliance within the initial verification process period.

• On the other hand, a second paragraph will be added to provide that, once the benefit for the total number of infringements has already been applied, fines may be reduced by up to 50% for subsequent infringements, if the same timing criteria are met.

• The Bill establishes that, even when done unintentionally, providing false or illegible information, documentation, data, or images, or modifying or altering information, would constitute a criminal offense punishable by 2 to 8 years of imprisonment and a fine ranging from 500 to 2,000 daily UMA.

• Additionally, it is also proposed to include that noncompliance with the Law may result in the revocation of permits granted under the Federal Law of Games and Sweepstakes (Ley Federal de Juegos y Sorteos), and for the provision of armored transport and custody services.

• Similarly, it is proposed to amend the Law for it to provide the cancellation of SHCP authorizations granted to individuals or legal entities that promote customs clearance of goods without the involvement of a customs agent or agency.

• Finally, a proposal is also included to grant Mexico’s Financial Intelligence Unit (Unidad de Inteligencia Financiera) the status of victim or injured party in relation to the conduct contemplated under the offense of transactions with resources of illicit origin.

6. Transitory Provisions.

If approved, the reform would enter into force the day following its publication in the Official Gazette of the Federation in general terms. However, the following specific transitory provisions are contemplated with respect to the new effects under the Law:

• The SHCP, prior opinion from the SAT, will amend the general rules of the AML Law within twelve months following the effective date.

• The annual period for developing training programs and conducting annual audits will be understood as the calendar year; therefore, the first period will begin on January 1 of the year following the publication of the decree.

• The new obligations for parties engaged in DNFBPs contemplated in Sections VII to XI of Article 18 will enter into force within the timeframes to be established in the general rules of the AML Law to be published.

• State Legislatures will have 180 calendar days from the effective date to enact the necessary reforms to provide for the application of sanctioning procedures to public notaries in cases of evident non-compliance with their obligations, in accordance with the amendment to Article 58 of the Law.

¹ All figures are in Mexican Pesos. The reference value of the UMA is taken from its daily amount set for 2025 by Mexico’s Central Bank, the Banco de México, equal to $113.14.

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If you have any questions regarding the scope or implementation of this note, please do not hesitate to contact us.

Bernardo Mendoza
Partner
bmendoza@k-g.com

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

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